WILD HORSE HUB CENTRAL

SORRY, WRONG NUMBER….

Transporting horses during fires and other dangerous natural disasters is almost impossible to do without some help. I hope that you, me, and everyone else understands this as we may be called upon to do what we can to help rescue sites transport their horses, pets, and families out of harms way – no matter what the natural disaster, we are all we can depend on.

I hope this works. I am blogging some thoughts; and also trying to copy/paste the GAO form that I found that stated the BLM has almost 100,000 horses in holding. SO WHO IN THE U.S. IS SELLING THE HORSES TO SLAUGHTER? WELL, READ THE GAO REPORT WHICH I POST IN HUGE BOLD LETTERS, WHICH ALSO THROWS THE TYPE ALIGNMENT OFF, BUT IT HELPS YOU ABSORB THE ABSOLUTE LUNACY OF THIS GOV. AS THEY TRY TO KEEP TELLING US A LIE UNTIL WE BELIEVE IT. CAN YOU READ THIS NOW?

It’s been a very long day. It started out too early and ends always, early in the morning. Right now, it’s too early to mention. My coffee pot has been full all day. 

 

First, let me mention that having someone hack into my facebook account again is very frustrating, no it’s down right time to get mad about it. I did. It worked.

 

Second, I met a new friend who is also a blogger, but didn’t know about our site, as I just learned about his. So, I shared our site(s) and hopefully, someday, he and his friends will visit. Maybe they will find something they enjoy about wild horses and burros. Just looking at the pictures of these fantastically beautiful animals makes your heart pound. Maybe, this is the way to reach out to people; if they don’t know, how will they help change the out come of what can happen?

 

I see that the Canadians are fast at it again with their wondrous pipeline to that “Texas Tea”  albeit there won’t be any allowances for the natives, nay nay. As they plan in Canada to send the bag piper down here again, (BP and the Ruby Pipeline wasn’t enough) with plans for his greatest feat of stealing the town’s children, they town’s parents are packing the kids off to play with their Canadian cousins. Well, they should be, as much money as that oil costs they should have to at least babysit the kids. 

 

While these feats of wonder continue, our knowledge of what is happening will surely come to fruition  to quote the predecesor of the now SOI Jewel: “Wild horses don’t have a place on public lands.” I see it coming down the pipeline, and now it’s time for all of us to stop up the pipe and see if we can’t send this contaminated air back to Canada and the Queen of England so they can ruminate about what the subjects are doing in the new world. 

 

So far, as I know, there are several options. I must also tell you that I found a GAO Report that I downloaded which does not give me anything but a bad attitude. Since this “sequester” nothing is getting done that makes sense; and the only ones spending any money are the politicians who are traveling on their Royal Caribean and African Safari tours as we sleep and dream of the ducky scrooge counting his coins…clink clink clink. 

 

My pc locks up so many times it’s like trying to start an old jalopy: aaarrrarrraarrr aarraarraarr  can you flood a pc? 

 

I know I haven’t mentioned this wonderful group on this blog. But, I do on my other blog ( https://jagdb1957.wordpress.com ). She is one of the hardest working people I know (met her on twitter and asked her to work harder…boy, that was a hoot! A professional journalist who became my friend, and actually worked harder! Amazing. Just amazing.) Her site is called Protect Mustangs at Protect Mustangs.com and she also has it connected to twitter and facebook. It’s very professional. A gentle soul, though. Sometimes I wonder if she is cut out to deal with these cowboys who are always spitting and chewing tobacco and cursing their way to feed their cattle on public lands that we pay for so they can get rich. I just wonder if any one is since this country loves it’s beef. I try to pick up the slack and sometimes, it works, sometimes I just am at a loss for what to do at all. Check out Protect Mustangs.com you won’t be disappointed. 

 

Now, I have said that I would publish the GAO Report. Here it is:  GAO-11-228 Horse Welfare

Report to Congressional Committees

June 2011

HORSE WELFARE

Action Needed to

Address Unintended

Consequences from

Cessation of Domestic

Slaughter

GAO-11-228

United States Government Accountability Office

 

GAO

United States Government Accountability Office

Accountability • Integrity • Reliability

Highlights of GAO-11-228, a report to congressional committees

June 2011

HORSE WELFARE

Action Needed to Address Unintended Consequences from Cessation of Domestic Slaughter

Why GAO Did This Study

Since fiscal year 2006, Congress has annually prohibited the use of federal funds to inspect horses destined for food, effectively prohibiting domestic slaughter. The U.S. Department of Agriculture (USDA) is responsible for overseeing the welfare of horses transported for slaughter.

Congress directed GAO to examine horse welfare since cessation of domestic slaughter in 2007. GAO examined (1) the effect on the U.S. horse market, if any, since cessation; (2) any impact of these market changes on horse welfare and on states, local governments, tribes, and animal welfare organizations; and (3) challenges, if any, to USDA’s oversight of the transport and welfare of U.S. horses exported for slaughter. GAO analyzed horse price and shipping data, and interviewed officials from USDA, state and local governments, tribes, the livestock industry, and animal welfare organizations, and reviewed documents they provided.

What GAO Recommends

GAO suggests that Congress may wish to reconsider restrictions on the use of federal funds to inspect horses for slaughter or, instead, consider a permanent ban on horse slaughter. GAO recommends that USDA issue a final rule to protect horses through more of the transportation chain to slaughter and consider ways to better leverage resources for compliance activities. USDA agreed with GAO’s recommendations and noted specific actions it will take to implement them.

What GAO Found

Since domestic horse slaughter ceased in 2007, the slaughter horse market has shifted to Canada and Mexico. From 2006 through 2010, U.S. horse exports for slaughter increased by 148 and 660 percent to Canada and Mexico, respectively. As a result, nearly the same number of U.S. horses was transported to Canada and Mexico for slaughter in 2010—nearly 138,000—as was slaughtered before domestic slaughter ceased. Available data show that horse prices declined since 2007, mainly for the lower-priced horses that are more likely to be bought for slaughter. GAO analysis of horse sale data estimates that closing domestic horse slaughtering facilities significantly and negatively affected lower-to-medium priced horses by 8 to 21 percent; higher-priced horses appear not to have lost value for that reason. Also, GAO estimates the economic downturn reduced prices for all horses by 4 to 5 percent.

Comprehensive, national data are lacking, but state, local government, and animal welfare organizations report a rise in investigations for horse neglect and more abandoned horses since 2007. For example, Colorado data showed that investigations for horse neglect and abuse increased more than 60 percent from 975 in 2005 to 1,588 in 2009. Also, California, Texas, and Florida reported more horses abandoned on private or state land since 2007. These changes have strained resources, according to state data and officials that GAO interviewed. State, local, tribal, and horse industry officials generally attributed these increases in neglect and abandonments to cessation of domestic slaughter and the economic downturn. Others, including representatives from some animal welfare organizations, questioned the relevance of cessation of slaughter to these problems.

USDA faces three broad challenges in overseeing the welfare of horses during transport to slaughter. First, among other management challenges, the current transport regulation only applies to horses transported directly to slaughtering facilities. A 2007 proposed rule would more broadly include horses moved first to stockyards, assembly points, and feedlots before being transported to Canada and Mexico, but delays in issuing a final rule have prevented USDA from protecting horses during much of their transit to slaughtering facilities. In addition, GAO found that many owner/shipper certificates, which document compliance with the regulation, are being returned to USDA without key information, if they are returned at all. Second, annual legislative prohibitions on USDA’s use of federal funds for inspecting horses impede USDA’s ability to improve compliance with, and enforcement of, the transport regulation. Third, GAO analysis shows that U.S. horses intended for slaughter are now traveling significantly greater distances to reach their final destination, where they are not covered by U.S. humane slaughter protections. With cessation of domestic slaughter, USDA lacks staff and resources at the borders and foreign slaughtering facilities that it once had in domestic facilities to help identify problems with shipping paperwork or the condition of horses before they are slaughtered.

View GAO-11-228 or key components.

 

For more information, contact Lisa Shames at (202) 512-3841 or shamesl@gao.gov.

 

Page i GAO-11-228 Horse Welfare

Letter 1

Background 5

U.S. Slaughter Horse Market Has Changed Since Domestic

Slaughter Ceased in 2007 10

Horse Welfare Has Reportedly Declined, Although the Extent Is

Unknown, Straining the Resources of State and Local

Governments, Tribes, and Animal Welfare Organizations 18

USDA’s Oversight of the Welfare of Horses Transported for

Slaughter Is Complicated by Three Challenges 27

Conclusions 42

Matters for Congressional Consideration 44

Recommendations for Executive Action 45

Agency Comments and Our Evaluation 46

Appendix I Objectives, Scope, and Methodology 47

Appendix II Results of the Econometric Analysis of

Horse Sale Prices 56

Appendix III Comments from the U.S. Department of Agriculture 59

Appendix IV GAO Contact and Staff Acknowledgments 61

Related GAO Products 62

Tables

Table 1: Estimates for Effect of Cessation of Slaughter and

Economic Downturn on Horse Sale Prices by Sale Price

Category, Spring 2004 through Spring 2010 18

Table 2: Semi-log Coefficients for Hedonic Quantile Regression of

Horse Prices 58

 

Contents

Page i GAO-11-228 Horse Welfare

Letter 1

Background 5

U.S. Slaughter Horse Market Has Changed Since Domestic

Slaughter Ceased in 2007 10

Horse Welfare Has Reportedly Declined, Although the Extent Is

Unknown, Straining the Resources of State and Local

Governments, Tribes, and Animal Welfare Organizations 18

USDA’s Oversight of the Welfare of Horses Transported for

Slaughter Is Complicated by Three Challenges 27

Conclusions 42

Matters for Congressional Consideration 44

Recommendations for Executive Action 45

Agency Comments and Our Evaluation 46

Appendix I Objectives, Scope, and Methodology 47

Appendix II Results of the Econometric Analysis of

Horse Sale Prices 56

Appendix III Comments from the U.S. Department of Agriculture 59

Appendix IV GAO Contact and Staff Acknowledgments 61

Related GAO Products 62

Tables

Table 1: Estimates for Effect of Cessation of Slaughter and

Economic Downturn on Horse Sale Prices by Sale Price

Category, Spring 2004 through Spring 2010 18

Table 2: Semi-log Coefficients for Hedonic Quantile Regression of

Horse Prices 58

 

Contents

 

Page iii GAO-11-228 Horse Welfare

Abbreviations

APHIS Animal and Plant Health Inspection Service

BLM Bureau of Land Management

CFIA Canadian Food Inspection Agency

FSIS Food Safety Inspection Service

OIG Office of Inspector General

SAGARPA Secretaría de Agricultura, Ganadería, Desarrollo Rural,

Pesca y Alimentación (Mexico)

TRAGIS Transportation Routing Analysis Geographic Information

System

USDA U.S. Department of Agriculture

This is a work of the U.S. government and is not subject to copyright protection in the

United States. The published product may be reproduced and distributed in its entirety

without further permission from GAO. However, because this work may contain

copyrighted images or other material, permission from the copyright holder may be

 

necessary if you wish to reproduce this material separately.

 

Page 1 GAO-11-228 Horse Welfare

United States Government Accountability Office

Washington, DC 20548

June 22, 2011

The Honorable Herb Kohl

Chairman

The Honorable Roy Blunt

Ranking Member

Subcommittee on Agriculture, Rural Development,

Food and Drug Administration, and Related Agencies

Committee on Appropriations

United States Senate

The Honorable Jack Kingston

Chairman

The Honorable Sam Farr

Ranking Member

Subcommittee on Agriculture, Rural Development,

Food and Drug Administration, and Related Agencies

Committee on Appropriations

House of Representatives

Many countries consider horsemeat an appropriate part of human diets—

and horsemeat was consumed in the United States as recently as the mid-

1940s. However, the slaughter of horses for any purpose, especially for

human consumption, is now a very controversial issue in the United

States, stemming largely from differences in how the country’s estimated 9

million horses are viewed. For example, some, including animal rights

advocates, horse enthusiasts, and some state governments, oppose horse

slaughter, citing the horse’s iconic role in helping to settle the American

West; its former importance as a work and transportation animal on farms

and in rural communities; and its continued value as a show, racing, and

recreation animal. Moreover, for many, horses are companion animals,

similar to dogs, cats, or other domestic pets. In contrast, others, including

the livestock and meatpacking industries and other state governments,

support horse slaughter, noting a strong export market for horsemeat; the

economic and employment benefits to local communities of horse

slaughtering facilities; and limited alternative options for dealing with

unwanted horses. Moreover, for many proponents of slaughter, horses are

livestock, similar to cattle, sheep, swine, and other farm animals raised to

produce commodities for human consumption. At present, horses are not

slaughtered in the United States due to an annual prohibition on the use of federal funds to inspect horses at slaughter. However, horses may be

 

purchased at auctions or other sales and exported for slaughter to Canada

 

Page 2 GAO-11-228 Horse Welfare

and Mexico. Horse slaughtering facilities in these countries generally

export the meat to consumer markets in Europe and Asia.

Aside from the question as to whether it is appropriate to slaughter horses for human consumption, both sides of this issue have raised concerns about

unintended consequences of the cessation of domestic slaughter. For

example, both sides note that horses intended for slaughter must now travel

much farther distances to foreign slaughtering facilities, potentially, during some part of that trip, in conveyances designed for smaller animals and

without adequate rest, food, and water. This controversy has also attracted

media attention, with reports of the inhumane treatment of horses during

transit or at foreign slaughtering facilities. For those who oppose horse

slaughter, the solution is to ban both domestic horse slaughter and trade in horsemeat or horses intended for slaughter for human consumption, effectively ending the export of horses intended for slaughter. Bills were

introduced in the 107th and 108th Congresses to create such a ban, but none

were enacted into law. In contrast, for those who support horse slaughter,

the solution is to reopen domestic slaughtering facilities. Although Congress

has not acted to create an explicit ban on horse slaughter, starting in fiscal

year 2006, it included language in annual appropriations bills that prohibits

the use of federal funds for inspection by the U.S. Department of Agriculture

(USDA) of horses in transit to slaughter and at slaughtering facilities.1 In

debating this provision in the House of Representatives, opponents argued

that it would not end horse slaughter, but instead would move this slaughter

across the borders, hurting horse welfare by increasing the distances horses would travel to slaughter. However, proponents of the provision countered

that there was no evidence of decreased horse welfare in states that had

banned slaughter.

As recently as 2007, three domestic horse slaughtering facilities—two in Texas and one in Illinois—continued to operate despite the prohibition on using federal funds for inspecting horses at slaughter. These facilities stayed

open by paying for these inspections under a voluntary fee-for-service

1Federal law requires that all U.S. horses slaughtered for human consumption and placed in

 

commerce be inspected.

 

Page 3 GAO-11-228 Horse Welfare

program implemented by USDA in February 2006.2 However, in 2007, all three

facilities closed when courts upheld state laws in Texas and Illinois

prohibiting sale or possession of horsemeat and horse slaughter, respectively.

New horse slaughtering facilities have, in effect, been prohibited from opening in other states since then because Congress has continued the annual

prohibition on the expenditure of federal funds to inspect horses at slaughter, and it added a prohibition on the use of federal funds, beginning in fiscal year 2008, for implementation of the fee-for-service program as well. Although the

domestic slaughter of horses for human food has stopped, USDA’s Slaughter Horse Transport Program (transport program) continues to operate. The

program, established in 2001, is intended to ensure that horses traveling to slaughter are fit to travel and handled humanely enroute. Among other things, the program collects and reviews shipping documents and inspects

conveyances used to transport these horses. However, because of the

prohibition on using federal funds for inspecting horses transported to

slaughter, the transport program may not inspect the condition of horses

designated for slaughter during their transport.

The Senate Committee on Appropriations directed that GAO examine the

status of horse welfare in the United States since horse slaughter

operations ceased in 2007.3 Our objectives to address this issue were to

examine (1) the effect on the U.S. horse market, if any, since domestic

slaughter for food ceased in 2007; (2) the impact, if any, of market changes

on horse welfare and on states, local governments, tribes, and animal

welfare organizations; and (3) challenges, if any, to USDA’s oversight of

the transport and welfare of U.S. horses exported for slaughter.

To address these objectives, we interviewed officials from USDA and other federal agencies, state and local governments, and tribes and

representatives from the livestock industry and animal welfare

organizations and reviewed the documents that they provided. We also

reviewed published literature addressing issues related to the horse industry

2This program enabled slaughtering facilities to pay for inspections of horses prior to

slaughter so that horses could continue to be processed for human consumption without the use of appropriated funds. It was established under the Agricultural Marketing Act, which authorizes a voluntary inspection service, on a fee-for-service basis, for agricultural

products. USDA has used this authority to provide inspections for animals it deems exotic,

including reindeer, elk, deer, antelope, and water buffalo. In 2006, USDA extended this

authority to horses. Meat inspected and passed under this authority is branded with a

USDA mark of inspection and can be sold interstate or exported.

 

3S. Rep. No. 111-39, at 44 (2009).

 

Page 3 GAO-11-228 Horse Welfare

program implemented by USDA in February 2006.2 However, in 2007, all three

facilities closed when courts upheld state laws in Texas and Illinois

prohibiting sale or possession of horsemeat and horse slaughter, respectively.

New horse slaughtering facilities have, in effect, been prohibited from opening in other states since then because Congress has continued the annual

prohibition on the expenditure of federal funds to inspect horses at slaughter, and it added a prohibition on the use of federal funds, beginning in fiscal year 2008, for implementation of the fee-for-service program as well. Although the

domestic slaughter of horses for human food has stopped, USDA’s Slaughter Horse Transport Program (transport program) continues to operate. The

program, established in 2001, is intended to ensure that horses traveling to slaughter are fit to travel and handled humanely enroute. Among other things, the program collects and reviews shipping documents and inspects

conveyances used to transport these horses. However, because of the

prohibition on using federal funds for inspecting horses transported to

slaughter, the transport program may not inspect the condition of horses

designated for slaughter during their transport.

The Senate Committee on Appropriations directed that GAO examine the

status of horse welfare in the United States since horse slaughter

operations ceased in 2007.3 Our objectives to address this issue were to

examine (1) the effect on the U.S. horse market, if any, since domestic

slaughter for food ceased in 2007; (2) the impact, if any, of market changes

on horse welfare and on states, local governments, tribes, and animal

welfare organizations; and (3) challenges, if any, to USDA’s oversight of

the transport and welfare of U.S. horses exported for slaughter.

To address these objectives, we interviewed officials from USDA and other federal agencies, state and local governments, and tribes and

representatives from the livestock industry and animal welfare

organizations and reviewed the documents that they provided. We also

reviewed published literature addressing issues related to the horse industry

2This program enabled slaughtering facilities to pay for inspections of horses prior to

slaughter so that horses could continue to be processed for human consumption without the use of appropriated funds. It was established under the Agricultural Marketing Act, which authorizes a voluntary inspection service, on a fee-for-service basis, for agricultural

products. USDA has used this authority to provide inspections for animals it deems exotic,

including reindeer, elk, deer, antelope, and water buffalo. In 2006, USDA extended this

authority to horses. Meat inspected and passed under this authority is branded with a

USDA mark of inspection and can be sold interstate or exported.

 

3S. Rep. No. 111-39, at 44 (2009).

 

Page 5 GAO-11-228 Horse Welfare

We conducted this performance audit from April 2010 through June 2011,

in accordance with generally accepted government auditing standards.

Those standards require that we plan and perform the audit to obtain

sufficient, appropriate evidence to provide a reasonable basis for our

findings and conclusions based on our audit objectives. We believe that

the evidence obtained provides a reasonable basis for our findings and

conclusions based on our audit objectives.

The Federal Agriculture Improvement and Reform Act of 1996 (1996 Farm Bill) authorized USDA to issue guidelines for the regulation of the

commercial transportation of horses and other equines for slaughter by

persons regularly engaged in that activity within the United States. The

statute gives USDA authority to regulate the commercial transportation of

equines to slaughtering facilities, which the statute indicates include

assembly points, feedlots, or stockyards. The authority to carry out this

statute was delegated to USDA’s Animal and Plant Health Inspection

Service (APHIS). Pursuant to this authority, APHIS issued a regulation,

“Commercial Transportation of Equines to Slaughter” (transport

regulation), in 2001. In 2001, APHIS also established the transport

program. This program seeks to ensure that horses being shipped for

slaughter are transported safely and humanely. In addition, USDA’s Food

Safety Inspection Service (FSIS) carries out the Humane Methods of

Slaughter Act and related regulations, which require the humane handling

of livestock, including horses, in connection with slaughter.5

APHIS’s transport regulation establishes a number of requirements that

owners/shippers (shippers) must meet for horses transported to slaughter. The regulation states that shippers must (1) provide horses with food,

water, and rest for at least 6 hours prior to loading; (2) provide horses

adequate floor space in whatever conveyance (e.g., a trailer) is being used;

(3) segregate all stallions and other aggressive equines; and (4) ensure that

trailers are free of sharp protrusions, are not double-decked, and have

adequate ventilation. If a trip is longer than 28 hours, horses must be

unloaded and provided at least 6 hours of food, water, and rest before

5For more information on the Humane Methods of Slaughter Act, see GAO, Humane

Methods of Slaughter Act: Weaknesses in USDA Enforcement, GAO-10-487T (Washington, D.C.: Mar. 4, 2010); Humane Methods of Slaughter Act: Actions Are Needed to Strengthen Enforcement, GAO-10-203 (Washington, D.C.: Feb. 19, 2010); and Humane Methods of

Slaughter Act: USDA Inspectors’ Views on Enforcement, GAO-10-244SP (Washington, D.C.: Feb. 19, 2010).

 

Background

 

Page 6 GAO-11-228 Horse Welfare

being reloaded. Horses cannot be shipped to slaughter unless they are

accompanied by an “Owner/Shipper Certificate—Fitness to Travel to a Slaughter Facility” (owner/shipper certificate) certifying that the horses

are fit for travel. The certificate must state that horses are over 6 months

of age, are not blind in both eyes, can bear weight on all four limbs, are

able to walk unassisted, and are not likely to foal (i.e., give birth) during

transport. Figure 1 provides an example of this certificate. Shippers found

to be in violation of the transport regulation can face penalties of $5,000

 

per horse, per violation.

 

Page 8 GAO-11-228 Horse Welfare

As of fall 2007, the last three horse slaughtering facilities in the United

States were closed following unsuccessful challenges to state laws

banning the practice. According to USDA data, those facilities, two in

Texas and one in Illinois, slaughtered almost 105,000 horses in 2006—the

last full year of operations—and exported more than 17,000 metric tons of

horsemeat, which was valued at about $65 million at that time. Regarding the Texas facilities, in January 2007, the U.S. Court of Appeals for the Fifth

Circuit ruled that a 1949 Texas law banning the sale or possession of

horsemeat applied to them. They ceased operations in May 2007.

Regarding the Illinois facility, the state enacted a law in May 2007 making

it illegal to slaughter horses for human consumption. In September 2007, the U.S. Court of Appeals for the Seventh Circuit upheld this slaughter

ban, and the Illinois facility ceased operations that month.

Since fiscal year 2006, Congress also has taken annual actions in

appropriations legislation that have effectively prevented the operation of horse slaughtering facilities in the United States by prohibiting USDA’s use

of federal funds to (1) inspect horses being transported for slaughter and (2) inspect horses intended for human consumption at slaughtering

facilities. The 1996 Farm Bill authorized the issuance of guidelines for the

regulation of the commercial transportation of equines for slaughter as

well as the conduct of any inspections considered necessary to determine

compliance. The Federal Meat Inspection Act requires inspection of

certain animals, including cattle, sheep, swine, goats, and horses, before

they are slaughtered and processed into products for human food to

ensure that meat and meat products from those animals are unadulterated,

wholesome, and properly labeled. However, Congress prohibited USDA

from using appropriated funds to pay for these inspections, effective 120

days after enactment of the fiscal year 2006 appropriations legislation on

November 10, 2005.

Following the prohibitions, the three domestic slaughtering facilities open

at that time petitioned USDA to create a voluntary fee-for-service

inspection program for horses prior to slaughter, and USDA created such a

program in early 2006, allowing required inspections, and, thus, domestic

slaughtering, to continue. The congressional prohibition on use of

appropriated funds continued in fiscal year 2007, but, as previously 

 

Page 9 GAO-11-228 Horse Welfare

discussed, the plants had already been shut down by state law that year.6

In fiscal year 2008, Congress renewed the prohibition on the use of

appropriated funds for inspections on horses being transported to

slaughter and at slaughtering facilities, and it added a new prohibition on

the use of appropriated funds for implementation or enforcement of the

fee-for-service program. These prohibitions were continued in fiscal years

2009 through 2011. These prohibitions notwithstanding, U.S. horses

intended for slaughter are still allowed to be transported within the United

States under the oversight of USDA’s transport program and exported to

slaughtering facilities in Canada and Mexico.

In September 2010, USDA’s Office of Inspector General (OIG) reported, in part, on the operations of the transport program.7 The OIG found that

APHIS needs to improve its controls for ensuring that horses being

shipped to foreign facilities for slaughter are treated humanely. For

example, APHIS does not deny authorization to shippers with a record of

inhumanely transporting horses intended for slaughter from shipping

other loads of horses, even if unpaid fines are pending for previous

violations. The OIG also found deficiencies in how APHIS tags horses that

have been inspected and approved for shipment to foreign slaughtering

facilities. For example, the agency requires shippers to mark such horses

with backtags, which are intended to allow APHIS to trace horses back to

their owner and also to verify that horses have passed inspection by an accredited veterinarian. However, APHIS lacked an appropriate control to

track individual horses by backtag number on approved shipping

documents so that it could perform reconciliations, investigate violations,

and initiate enforcement actions, as appropriate. In addition, the OIG

noted that APHIS needs to obtain the resources necessary to adequately

oversee the transport program and issue in final a proposed rule that

would broaden the scope of the agency’s regulation of horses being

shipped to foreign slaughtering facilities. In its official response to the OIG

report, APHIS concurred with the OIG’s findings and recommendations

6Two plants in Texas were effectively closed when a court there upheld a state statute

prohibiting the sale or possession of horsemeat. Empacadora de Carnes de Fresnillo, S.A.

de C.V. v. Curry, 476 F. 3d 326 (5th Cir. 2007). A plant in Illinois closed after a court there upheld a state statute prohibiting horse slaughter. Cavel Int’l v. Madigan, 500 F. 3d 551 (7th Cir. 2007).

7U.S. Department of Agriculture, Office of Inspector General, Animal and Plant Health

Inspection Service Administration of the Horse Protection Program and the Slaughter

 

Horse Protection Program, Audit Report 33601-2-CK (Washington, D.C.: Sept. 30, 2010).

 

Page 10 GAO-11-228 Horse Welfare

related to the transport program, and APHIS proposed specific actions and

time frames for implementing the recommendations.8 For example, APHIS

agreed to work with USDA’s Office of General Counsel and complete by

May 31, 2011, an evaluation of “the best options to revise regulations

necessary that will establish an agencywide policy that those who have

violated the humane handling regulations and failed to pay the associated penalties shall not receive endorsement of any subsequently requested

shipping documents.”

The U.S. slaughter horse market has changed since domestic slaughter for

food ceased in 2007, particularly in terms of increased exports to Canada

and Mexico and lower domestic sales and prices, especially for lower-

value horses, according to our analysis of available trade data and horse

auction sales data.

The number of horses slaughtered in the United States decreased from

1990 (345,900 horses) through 2002 (42,312 horses), according to available

data from USDA’s National Agricultural Statistics Service. At the same

time, the reported number of slaughtering facilities dropped from at least

16 U.S. facilities that operated in the 1980s to 7 facilities in 1994 to as few

as 2 in 2002. Beginning in 2003, however, the number of horses slaughtered

began rising through 2006, the last full year of domestic slaughtering

operations, when nearly 105,000 horses were slaughtered in the United

States. According to USDA officials, this increase can be explained, in part, by the reopening of a horse slaughtering facility in DeKalb, Illinois, in 2004 that increased domestic slaughtering capacity. This facility had been closed for 2 years following a fire set by anti-slaughter arsonists. Because

all domestic slaughtering facilities closed by September 2007, however, the

number of horses being slaughtered in the United States dropped to zero by the end of that year. Figure 2 shows the changes in the number of

horses slaughtered in the United States from 1990 through 2007.

8APHIS’s official response may be found at the end of the OIG report.

U.S. Slaughter Horse Market Has Changed

Since Domestic Slaughter Ceased in

2007

Horse Exports to Canada

and Mexico Have

Increased with the

Cessation of Domestic

 

Slaughter

 

Page 11 GAO-11-228 Horse Welfare

Figure 2: Number of Horses Slaughtered in the United States, 1990 through 2007

Before 2007, horses were slaughtered in domestic slaughtering facilities

only when the horsemeat was destined for consumption by humans or zoo

animals. Currently, pet food and other products, including glue, may still

be obtained from the corpses of horses that are hauled to rendering plants for disposal. The production of these products is not covered by the

requirements of the Federal Meat Inspection Act and is therefore not

affected by the current ban on the use of appropriated funds for the ante-

mortem inspection of horses destined for human consumption. According

to a transport program official, USDA is not aware of any domestic facility

slaughtering horses for any purpose, including for zoos, as of the end of

2010. USDA identified at least three establishments—in Colorado,

Nebraska, and New Jersey—that import horsemeat for repackaging and

distribution to purchasers in the United States who feed the meat to

animals at zoos and circuses.

With the cessation of domestic slaughter, U.S. exports of horses intended for slaughter increased to Canada and Mexico, the current locations of all

North American horse slaughtering facilities. As of the end of 2010,

Canada had four such facilities, and Mexico three, that were the principal destinations of U.S. horses exported for slaughter. According to USDA

officials, this increase in exports began, in part, because shippers were

 

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0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007

 

Number of horses slaughtered

Source: GAO analysis of USDA’s National Agricultural Statistics Service data.

Year

Last full year of domestic slaughtering operations

345,900

276,700

243,500

169,900

107,000 109,200 105,000

87,200

72,120

62,813

47,134

56,332

42,312 50,062

66,183

94,037

104,899

 

29,767

 

Page 12 GAO-11-228 Horse Welfare

anticipating the closure of the three horse slaughtering facilities in the

United States at that time. From 2006 through 2010, Canadian and Mexican

imports increased by 148 percent and 660 percent, respectively, with the

total number of horses imported from the United States for slaughter

increasing from about 33,000 in 2006 to about 138,000 in 2010. In addition,

the total number of horses exported for all purposes, including breeding

and showing, also increased from 2006 through 2010, as shown in figure 3. According to USDA officials, some horses exported for purposes other

than slaughter were likely “feeder” horses that were ultimately sent to

slaughtering facilities at a later time. For example, feeder horses may be

sent to a Canadian or Mexican feedlot for fattening before subsequently

being sent to a slaughtering facility in that country. The extent to which

horses are exported as feeder horses is unknown, according to USDA

officials.

Figure 3: U.S. Exports of Horses Intended for Slaughter and Other Purposes, 2004

through 2010

Note: U.S. exports of horses intended for slaughter are unofficial estimates because official U.S.

export trade data do not specify the quantity or value of horses exported for slaughter. Thus, while

official U.S. trade data can be used to determine total U.S. live horse exports (the sum of horses

exported for slaughter or other purposes, such as breeding and showing), an estimate of horses

intended for slaughter can only be determined using Canadian and Mexican official trade statistics.

 

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Quantity (head)

Calendar year

Sources: GAO analysis of Department of Commerce Foreign Trade data and USDA Foreign Agricultural Service documents.

For other purposes

For slaughter

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

2004 2005 2006 2007 2008 2009 2010

23,782 25,145 32,789

May—Two Texas slaughter facilities closed

September—Illinois slaughter facility

closed

99,172

78,061

99,049 109,487

137,984

56,414 51,635 61,223

154,126 148,827

 

168,011

 

Page 13 GAO-11-228 Horse Welfare

The total number of U.S. horses sent to slaughter in 2006, the last full year

of domestic slaughter, was comprised of horses slaughtered domestically

(i.e., 104,899, as shown in fig. 2) and those sent for slaughter in Canada or Mexico (i.e., 32,789, as shown in fig. 3)—for a total of 137,688 horses.

Taken together, the 137,984 U.S. horses that were sent to slaughter in

Canada or Mexico in 2010 is approximately equal to the total number of

horses slaughtered in 2006.

Additional certification may affect Canadian and Mexican exports of

horsemeat to Europe and, in turn, may affect the future export of horses

intended for slaughter from the United States to these countries. In 2010,

the European Union began prohibiting the importation of horsemeat from

horses treated with certain drugs and requiring countries to document

withdrawal periods for horses treated with other drugs before meat from

such horses could be imported to the European Union. Those regulations

precipitated similar regulations in Canada and Mexico. For example,

Canadian requirements went into effect on July 31, 2010, banning specific medications, such as phenylbutazone—the most common anti-

inflammatory medication given to horses—and requiring a 180-day withdrawal period for other medications, such as fentanyl, an analgesic.

Also, since November 30, 2009, Mexico has required an affidavit by

transporters that horses have been free from certain medications for 180

days prior to shipment. Furthermore, effective July 31, 2013, the European

Union will require lifetime medication records for all horses slaughtered in

non-European Union countries before accepting imports of horsemeat

from those countries. According to APHIS and horse industry sources,

these requirements could result in shippers certifying that their horses are

free of medication residues without having first-hand knowledge or

documentation of the horses’ status for the previous 180 days.

With regard to sales, many of the State Veterinarians said that fewer horse

sales have occurred and fewer auctions have operated within their states

since 2007, in part, because of lower horse prices and sale commissions

since the cessation of domestic slaughter. As a result, they said, horse

owners have fewer options for getting rid of horses they no longer want.

There also has been reduction in the number of commercial shippers

doing business since the cessation of slaughter. In reviewing USDA

documentation, we found that more than 110 shippers operated from 2005

through 2006—the 2 years prior to the cessation of domestic slaughter in

2007—and fewer than 50 shippers operated from 2008 through 2009. Some in the horse industry, as well as the State Veterinarians, generally

attributed this decrease to the closing of horse auctions around the

Horse Sales and Prices

Have Declined Since 2007,

Especially for Lower-

Valued Horses

 

Page 14 GAO-11-228 Horse Welfare

country, reflecting a smaller market and the lower profit margins resulting

from the increased costs of transporting horses intended for slaughter to

Canada and Mexico.

Horse industry representatives also stated that the closing of domestic

slaughtering facilities has dramatically affected the prices of horses.

National data on horse prices do not exist, but data from individual auctions are available. For example, the Billings, Montana, horse auction, one of the

nation’s largest, which also sells horses purchased for slaughter, reported a

large increase in the percentage of lower-priced horses sold—the type of

horse that typically ends up at slaughter—and a general decrease in sale

prices. In May 2005, approximately 25 percent of “loose” horses—less

expensive horses that are run through the auction ring without a rider or saddle—sold for less than $200 at that auction, whereas in May 2010, about

50 percent of loose horses sold for less than that amount.

The economic downturn in the United States that started in December

2007 also likely affected horse prices, according to the academic experts

and industry representatives we consulted. Since many U.S. horses are

used for recreational purposes, they are generally thought to be luxury

goods, and their ownership is sensitive to upturns and downturns in the

general economy. Furthermore, some horse sellers could no longer afford to keep their horses, and potential buyers also were not able to offer as

much to buy horses or were not in the market to purchase horses at all,

according to some industry observers. In particular, a considerable

number of horse owners are from lower-to-moderate income households

and are less able to withstand the effects of a recession, according to

academic experts. For example, one study estimated that up to 45 percent

of horse owners have an annual household income of between $25,000 and

$75,000.9 According to several State Veterinarians, those owners are more

likely to have problems affording the care of their horses during an

economic downturn.

To estimate the impact of the cessation of domestic slaughter on horse

prices, we collected price data on more than 12,000 sale transactions from spring 2004 through spring 2010 from three large horse auctions located in

the western, southern, and eastern United States. Our analysis of these

9Ahern, J., Anderson, D., Bailey, D., Baker, L., Colette, W., Neibergs, J., North, M., Potter, G.,

& Stull, C. (2006), “The Unintended Consequences of a Ban on the Humane Slaughter

 

(Processing) of Horses in the United States,” Animal Welfare Council, Inc.

 

Page 15 GAO-11-228 Horse Welfare

data controlled for the economic downturn and other factors that are

auction- and horse-specific, such as a horse’s breed/type, age, and gender, which may also affect prices.10 Horse sale prices ranged from a minimum

of $4 to a maximum of $48,500, with most of these sales clustered at the lower end of the price range. Figure 4 shows the distribution of these sales

prices, including the median and average price per head.

Figure 4: Distribution of Horse Prices from the Horse Auctions Used in the

Analysis, Spring 2004 through Spring 2010

Our analysis also shows a statistically significant reduction in average sale price across all price categories after the cessation of slaughter in 2007, as shown in figure 5.11 For example, the average sale price for horses in the

lowest price category (20th percentile), dropped by about $110 per head

(from $433 to $323), and the average price for the highest price category

(80th percentile) dropped by about $140 per head (from $2,380 to $2,241).

10The other variables that we considered included season of year of the auction, auction

location, and percentage of “no sales” (horses that did not receive a bid acceptable to the seller) for each auction.

11For the purpose of this discussion, we use the term “category” to refer generally to the quantiles of price from our analysis.

Percent of horses

Source: GAO analysis of horse auction sales data.

 

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Price (in dollars)

20

10

5

3

2

1 1 1 1

17

37

Median

Median

$1,400

per head

Average

Average

$2,140

per head

0

<2 percent

5,500

6,500

7,500

8,500

9,500

10,500

11,500

12,500

4,500

3,500

2,500

1,500

500

48,500

0

5

10

15

20

25

30

35

 

40

 

Page 16 GAO-11-228 Horse Welfare

Figure 5: Average Horse Prices Before and After Cessation of Horse Slaughter for

Each Price Category, Spring 2004 through Spring 2010

Using these data and regression methods to isolate the impact on prices

for specific variables, our analysis indicates that the cessation of domestic

horse slaughter led to an 8- to 21-percent decline—depending on sale

price—in the per head price of horses sold at those auctions.12 As

illustrated in figure 6, we estimate that price reductions were greatest, in

percentage terms, for lowest-priced horses, gradually declined as prices

increased, and became insignificant for horses in the higher price

categories. For example, the average per head price decreased by nearly

21 percent for horses in the lowest price category (20th percentile) and

about 8 percent at the median, whereas the price change per head was not

statistically significant for higher price categories.

12Specifically, we used an econometric model and hedonic quantile regression methods. For a more detailed explanation, see appendix I.

 

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Source: GAO analysis of horse auction data.

0

250

500

750

1,000

1,250

1,500

1,750

2,000

2,250

2,500

20th 40th 50th 60th 80th

Before cessation (2004-2006)

After cessation (2007-2010)

Price per head (dollars)

Lower price category (percentile)Higher price category (percentile)

784

1,178

1,537

2,241

323

891

1,340

2,380

433

 

1,684

 

Page 17 GAO-11-228 Horse Welfare

Figure 6: Estimates of the Effect on Horse Prices from Closing Domestic

Slaughtering Facilities and the Economic Downturn for Each Price Category, Spring

2004 through Spring 2010

In contrast to the effects of closing slaughtering facilities—where the

percentage decrease in prices for lower-priced horses was greater than

that for higher-priced horses—our estimates show that the economic

downturn (represented by the change in the average unemployment rate

for the region where the auction was held) was associated with a

consistent decline of about 5 percent in price across all price categories

for those auctions. Table 1 provides our estimates of the price change per

head (in dollars and percentage decline) associated with the cessation of

slaughter and the economic downturn, along with the average sale price for each price category.

 

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Source: GAO analysis of horse auction data.

-25

-20

-15

-10

-5

0

5

10

15

20

25

20th 40th 50th 60th 80th

Effect (percent change)

Lower price category (percentile)Higher price category (percentile)

Effect on price from closing

horse slaughter facilities

Effect on price from economic downturn

NS

Not significant

-20.93%

-10.42%

-7.83%

 

NS NS

 

Page 18 GAO-11-228 Horse Welfare

Table 1: Estimates for Effect of Cessation of Slaughter and Economic Downturn on Horse Sale Prices by Sale Price Category,

Spring 2004 through Spring 2010

Effect by sale price category (percentile)

Variable Type of change 20th 40th50th (median) 60th 80th

Price change -$125.61 -$104.24-$109.58 a a Cessation of slaughter on

horse prices (per head) Percentage change -20.93 -10.42 -7.83 a a

Price change -$30.90-$52.26-$67.22 -$82.09-$142.91 Economic downturn on

horse prices (per head) Percentage change -5.15-5.23 -4.80 -4.69 -4.76

Upper bound for category

(price per head)

$600$1,000$1,400 $1,750$3,000

Source: GAO analysis of data from selected horse auctions and the Department of Labor’s Bureau of Labor Statistics.

aThe effect on price was not statistically significant for that category. These estimates suggest that the closing of domestic horse slaughtering

facilities had a significant and negative impact on horse prices at the low-

to-mid levels of price at these auctions, while relatively higher-priced

horses appear not to have lost their value due to the cessation of slaughter.

Appendix II provides further details on the results of our analysis.

Horse welfare in the United States has generally declined since 2007, as

evidenced by a reported increase in horse abandonments and an increase

in investigations for horse abuse and neglect. The extent of the decline is

unknown due to a lack of comprehensive, national data, but state officials

attributed the decline in horse welfare to many factors, but primarily to

the cessation of domestic slaughter and the U.S. economic downturn.

Abandoned, abused, and neglected horses present challenges for state and local governments, tribes, and animal welfare organizations. In response,

some states and tribes have taken several actions to address these

challenges and the demand on their resources.

Horse Welfare Has

Reportedly Declined,

Although the Extent

Is Unknown, Straining

the Resources of State

and Local

Governments, Tribes,

and Animal Welfare

 

Organizations

 

Page 19 GAO-11-228 Horse Welfare

In interviewing the 17 State Veterinarians, we asked whether the states

had data for cases of horse abandonments, abuse, and neglect. Most

veterinarians from these states, including some with the largest horse

populations—California, Florida, and Texas—said they do not routinely

collect such data because, in part, their resources are limited and

jurisdiction of animal welfare is usually a local (e.g., county) responsibility. Nearly all the State Veterinarians, however, reported

anecdotes indicating that cases of abandonments and abuse or neglect

have increased in recent years. For example, several State Veterinarians,

including those from California, Florida, and Texas, reported an increase

in horses abandoned on private or state park land since 2007, although

specific data quantifying those abandonments were not available.

In addition, states that do collect some data reported increases in

abandonments or investigations of abuse and neglect since the cessation of domestic slaughter. For example, data from Colorado showed a 50-

percent increase in investigations for abuse and neglect from 1,067 in 2005 to 1,588 in 2009. Similarly, data from Indiana indicated that horse abuse

and neglect investigations more than doubled from 20 in 2006 to 55 in

2009. In addition, organizations representing localities, especially counties

and sheriffs, have reported an increasing problem. For example, the

Montana Association of Counties reported that the number of horses being

abandoned by their owners has rapidly increased since horse slaughter for

human consumption was halted in the United States, but the association

did not have specific data. In addition, the National Association of

Counties reported that the increasing abandonment problem is not

exclusive to Montana or the West but is happening nationwide.

We also asked the 17 State Veterinarians whether horse welfare, in

general, had improved, declined, or remained about the same in their

states over the last 5 years. Without exception, these officials reported that

horse welfare had generally declined, as evidenced by a reported increase

in cases of horse abandonment and neglect. They most frequently cited

two factors that contributed to the decline in horse welfare—the cessation of domestic slaughter in 2007 and the economic downturn—although they

generally were careful not to pin the decline on any single factor. Other

factors that they generally cited include poor weather conditions (e.g.,

drought in western states); the cost of horse disposal methods (e.g.,

veterinarian-assisted euthanasia); the increasing costs of feeding and

caring for horses; and the lack of auction markets to sell horses.

Cases of Horse

Abandonments, Abuse,

and Neglect Have

Reportedly Increased

Since 2007

State Veterinarians

Attributed Decline in

Horse Welfare Primarily to

Cessation of Slaughter and

Economic Downturn, but

Representatives of Animal

Welfare Organizations

Question Cessation’s

 

Impact

 

Page 20 GAO-11-228 Horse Welfare

Among the factors affecting horse owners, the State Veterinarians said a

horse owner’s decision to abandon a horse generally related to (1)

cessation of domestic slaughter, (2) poor economic conditions, and (3)

low horse prices or lack of sale opportunities. They also said the factors

most often related to a horse owner’s neglect of a horse were (1) poor

economic conditions, (2) the cost of horse care and maintenance, and (3)

lower horse prices. Several State Veterinarians pointed out that, in their

professional experience, very few owners directly physically abuse their

horses, which would be a crime. More common, however, were owners

who neglected the feeding and proper care—such as providing farrier

services (i.e., hoof care) and vaccinations—of their horses. Thus, based on the information these officials provided, the primary drivers for the

increase in abandonment and neglect cases are the cessation of domestic

slaughter, causing lower horse prices and difficulty in selling horses, and

the economic downturn, affecting horse owners’ ability to properly care

for their animals. As discussed, our analysis also showed that the

cessation of slaughter and the economic downturn generally reduced

horse prices at our selected auctions; in particular, the cessation affected

prices for the low-to-mid range priced horses that are more frequently abandoned and neglected. Furthermore, regarding neglect, some State

Veterinarians, noting that people are more inclined to take care of that

which has value, said that the drop in horse prices affected some owners’

interest in caring for their animals, especially if their financial situation

had declined.

With regard to the entities most affected by the increase in abandoned and

neglected horses, the State Veterinarians generally said that counties,

including sheriffs, bear the responsibility for investigating potential cases

affecting horse welfare. Many State Veterinarians, particularly from western states, indicated that their offices did not have the resources to

support the counties beyond providing expert veterinary advice regarding

conditions of abandoned and neglected horses, such as opining on a

 

horse’s nutritional status (known as “body scoring”).

 

Page 21 GAO-11-228 Horse Welfare

State and local governments, tribes, and animal welfare organizations,

especially horse rescues, are facing growing pressures to care for

abandoned and neglected horses at a time of economic recession and tight

budgets. According to the State Veterinarians, counties and animal welfare

organizations bear the costs of collecting and caring for abandoned

horses, while county governments generally bear the costs of investigating

reports of neglect. These officials said horse rescue operations in their

states are at, or near, maximum capacity, with some taking on more

horses than they can properly care for since the cessation of domestic

slaughter. One State Veterinarian added that his office is reluctant to

pressure horse rescues in his state to take on additional animals because

of this problem, even though alternatives are lacking. Some State

Veterinarians also described situations in which counties and sheriff

departments were reluctant to investigate reports of abandoned or

neglected horses because these jurisdictions lacked resources to deal with

the consequences of finding such animals. In some cases, these officials

said local jurisdictions may lack the resources even to initiate such

investigations, let alone to take possession of and care for these animals.

And in cases where an investigation results in horse seizures, local

jurisdictions may have to appeal for the public’s help in caring for the

animals. For example, the Montana State Veterinarian and his staff

described a recent situation in their state involving the seizure of hundreds

of neglected horses, many of which had low body scores and would not

have survived the winter without intervention. These horses were seized

from a ranch owner near Billings, Montana, in January 2011 who was no

longer able to afford their care. Because of the strain placed on state and county resources to care for so many animals, these jurisdictions had to

seek private donations of hay to feed these horses. Figure 7 shows some of

the horses seized in this case.

State and Local

Governments, Tribes, and

Animal Welfare

Organizations Are Affected

by Neglected and

Abandoned Horses, as Is

 

the Federal Government

 

Page 22 GAO-11-228 Horse Welfare

Figure 7: A Band of Horses, Some of Hundreds That Have Been Neglected on

Montana Ranchland and Seized by the County after the Collapse of Their Owner’s

Ranching Company

Tribes also reported increases in abandonments on their land,

exacerbating the overpopulation of horse herds on tribal lands. According to 2009 data from the Northwest Tribal Horse Coalition (now the National

Tribal Horse Coalition), the number of horses on its tribal lands exceeded

30,000 horses. When we met with representatives of tribes in the western

United States, they showed us significant degradation of their lands as a

result of the over-grazing by large populations of wild horses, as shown in

figure 8. They explained that the increase in abandoned horses on their

lands has compounded the challenge of restoring native and religiously-

significant species of plants to their land—an effort often paid for, in part,

by the federal government. Moreover, domesticated horses abandoned on

public lands generally have poor survival prospects, according to officials from the Department of the Interior’s Bureau of Land Management (BLM).

These horses are unfamiliar with which wild plants are edible and are

likely to be shunned or hurt by wild horses. These abandoned horses may

also introduce diseases to wild herds.

 

Source: Larry Mayer/Billings Gazette. Photo used with permission.

*photo not published here*

 

Page 23 GAO-11-228 Horse Welfare

Figure 8: Wild Horse Herd on Degraded Land Owned by the Yakama Nation in Washington State The effects of the increasing number of abandoned or neglected horses

have been felt by local animal welfare organizations as well—in particular,

the horse rescues and local societies for the prevention of cruelty to

animals that work with local officials to place such horses, according to

the State Veterinarians. The total number of rescues and their capacities is

unknown because there is no national registry or association for horse

rescues. However, both the National Association of Counties and the

Unwanted Horse Coalition estimated that the nationwide capacity of

rescue facilities is about 6,000 horses. They also reported that the vast

majority of these facilities are already full. Some State Veterinarians told

us that some rescue organizations have taken on more horses than they can properly care for, especially in an economic environment in which

donations have declined; as a result, horses at some of these organizations’

facilities have been seized. For example, it has been reported that horse

rescues in California, Florida, New York, and West Virginia have recently

 

Source: GAO.

 

Page 24 GAO-11-228 Horse Welfare

had their animals seized by local authorities because they were not

properly caring for them, and others in New Hampshire and Pennsylvania closed due to financial difficulties.

In addition, the increase in unwanted domesticated horses available for

sale or being abandoned on public lands is affecting the federal

government’s ability to manage wild horse and burro populations. Most of these wild animals are found on lands managed by BLM and USDA’s

Forest Service in the western United States.13 From 1971 through 2007,

BLM removed over 267,000 wild horses and burros from these lands, and during the same period, approximately 235,700 of these animals were

adopted by the public under a BLM program that promotes these

adoptions. As we reported in 2008, BLM has, however, experienced a

steady decline in adoptions in recent years, which agency officials

attributed, in part, to the large number of domesticated horses flooding the

market.14 More recently, BLM officials said that annual adoptions had

fallen from about 8,000 in 2005 to about 3,000 in 2010. In an October 2010

Web message, the BLM Director estimated that the number of horses and

burros on lands the agency manages exceeds by about 12,000 the number

that would allow these lands to remain sustainable for other uses and

species.15 According to BLM officials, in addition to natural reproduction in

wild horse and burro herds, the increasing number of domesticated horses

being abandoned on public lands has contributed to this overpopulation

problem.

Other officials, including those from animal welfare organizations,

questioned the relevance of the cessation of domestic slaughter to the rise

in abandoned and neglected horses, which they attributed more to the

economic downturn. For example, in March 2010, Animal Welfare Institute

representatives said that since a 1998 California ban on dealing in horses

intended for slaughter, their organization has offered a $1,000 reward for

13BLM estimates, as of October 2010, that it is managing about 38,400 free-roaming wild

horses and burros on these lands, and it also is holding about 37,000 additional horses and

burros removed from these lands in short- and long-term holding facilities. BLM estimates

its feeding and care of animals in holding facilities cost the federal government more than

$36 million annually, more than half the wild horse and burro program’s budget in fiscal

year 2010.

14GAO, Bureau of Land Management: Effective Long-Term Options Needed to Manage

Unadoptable Wild Horses, GAO-09-77 (Washington, D.C.: Oct. 9, 2008).

15This Web message is available at http://www.blm.gov/wo/st/en/prog/

 

wild_horse_and_burro/national/about/director.print.html.

 

Page 25 GAO-11-228 Horse Welfare

notification of abandoned horses but has never received a tip. In addition, the Humane Society of the United States and the United Animal Nations

reported that there has been no documented rise in abuse and neglect

cases in California since the 1998 ban. United Animal Nations also

reported there was no documented rise in abuse and neglect cases in

Illinois following the 2-year closure of the horse slaughtering facility in

that state in 2002. Furthermore, Humane Society of the United States

officials said that owners who abandon horses are going to abandon them

regardless of having the option for domestic slaughter, adding that there were instances of horse abandonment near domestic horse slaughtering

facilities before they closed. These officials acknowledged that there are

no good data on horse abandonments but noted an increase in

abandonments of all kinds of domesticated animals as the economy

worsened.

Some states took actions related to horse welfare and slaughter even

before the cessation of domestic slaughter in 2007. For example, in 1998,

California made it illegal to export horses for the purpose of having them

slaughtered for human consumption outside the state. Specifically,

California law makes it unlawful for any person to possess; to import into

or export from the state; or to sell, buy, give away, hold, or accept any

horse with the intent of killing or having another kill that horse, if that

person knows or should have known that any part of that horse will be

used for human consumption. Several state officials told us that this ban is

difficult to enforce because it may be difficult to show when an owner

knew or should have known that a buyer intended that animal for

slaughter. For example, if an owner transports a horse to an auction in

another state (e.g., Montana or Texas), it may be difficult to prove that the

owner specifically intended to sell the horse for slaughter or should have

known that the buyer of the horse intended to sell the horse for slaughter.

In addition, since 2007, states and tribes have taken a variety of legislative

or other actions related to horse welfare or slaughter. For example, in

2009 Montana passed a law that allows horse owners to surrender horses

that they cannot afford to maintain to the state at a licensed livestock

market without being charged with animal cruelty. Also, Colorado

authorized the inclusion of a checkbox on state income tax return forms

allowing taxpayers to make a contribution to the Colorado Unwanted

Horse Alliance. In authorizing the program, the Colorado legislature found

that the number of unwanted horses is increasing; most horse rescue

facilities are operating at capacity and have limited ability to care for

additional horses; and incidences of horse abuse and neglect are rising. 

 

Page 26 GAO-11-228 Horse Welfare

addition, Kentucky passed a law in the spring of 2010 creating the

Kentucky Equine Health and Welfare Council and charged it with

developing regional centers of care for unwanted, abused, neglected, or

confiscated equines; creating a system of voluntary certification of equine rescue and retirement operations; and suggesting statutory changes

affecting equine health, welfare, abuse, and neglect issues. Also, in 2009,

the National Congress of American Indians and the Northwest Tribal

Horse Coalition passed resolutions supporting domestic slaughter to

manage overpopulated horse herds. A number of the 17 states that we

examined have also enacted laws related to horse welfare and slaughter

since the cessation of domestic slaughter. For example:

• Arkansas, Oklahoma, Utah, and Wyoming passed resolutions urging

Congress to facilitate the resumption of horse slaughtering in the

United States and oppose federal legislation that would ban domestic

slaughter. North Dakota and South Dakota passed similar resolutions

urging Congress to reinstate and fund federal inspection programs for

horse slaughter and processing.

• Montana passed a law that would make it easier to establish a horse

slaughtering facility by making it harder for those opposing such a

plant to get an injunction against it while challenging various permits

that the plant would need to operate. In his 2009 testimony in support

of the bill, the chair of Montana’s Farm Bureau cited rising numbers of

unwanted horses and associated costs.

• Wyoming amended its existing law to provide that strays, livestock, and

feral livestock, including horses, may be sent to slaughter as an

alternative to auction or destruction. The legislative changes also

provided that the state could enter into agreements with meat

processing plants whereby meat from livestock disposed of by

slaughter could be sold to state institutions or nonprofits at cost or to

for-profit entities at market rate.

Several states are seeking to reopen domestic horse slaughter facilities,

under a provision of the Food, Conservation, and Energy Act of 2008,

which authorized USDA to establish a new voluntary cooperative program

under which small state-inspected establishments would be eligible to ship meat and poultry products in interstate commerce. USDA recently

finalized a rule to implement the program, but USDA officials said that the

rule does not include horsemeat, because recent appropriations legislation

has prohibited the use of federal funds for inspecting horses prior to

 

slaughter. And although, under the proposed program, the inspections

 

Page 27 GAO-11-228 Horse Welfare

would be done by state officials, federal law requires USDA to reimburse

the state for at least 60 percent of the associated costs. However, as noted

by USDA officials, the prohibition in appropriations legislation against

using federal funds for inspecting horse at slaughter would preclude these

reimbursements. USDA officials said the same issue would preclude tribal slaughtering facilities from shipping horsemeat in interstate or

international commerce as well.

USDA faces three challenges in its oversight of the welfare of horses

during their transport for slaughter. First, APHIS faces several specific

management challenges in implementing the transport program. Second,

legislative prohibitions on using federal funds for inspecting horses prior

to slaughter impede USDA’s ability to ensure horse welfare. Third, the

cessation of domestic slaughter has diminished APHIS’s effectiveness in

overseeing the transport and welfare of horses intended for slaughter.

Several management challenges are affecting APHIS’s implementation of

the transport program. These challenges include (1) delays in issuing a

final rule to give the agency greater oversight over horses transported for

slaughter to protect their welfare; (2) limited staff and funding that

complicates the agency’s ability to ensure the completion, return, and

evaluation of owner/shipper certificates; and (3) a lack of current, formal

agreements with Canadian, Mexican, and state officials whose cooperation

is needed for program implementation.

APHIS’s transport regulation sets minimum care standards to protect

horse welfare, but it applies only when the horses are being moved

directly to slaughtering facilities, at which point shippers designate the

horses as “for slaughter” on an owner/shipper certificate and move the

horses directly to slaughtering facilities. Consequently, the regulation does

not apply to horses that are moved first to an assembly point, feedlot, or

stockyard before going to slaughter. For example, a horse’s journey to

slaughter may have covered several states, from point-of-purchase at an

auction to an assembly point, such as a farm; from the assembly point to a

feedlot or stockyard; and from the feedlot or stockyard to a point near a

slaughtering facility or a border crossing where the slaughter designation

was first made.

USDA’s Oversight of

the Welfare of Horses

Transported for

Slaughter Is

Complicated by Three

Challenges

Management Challenges

Affect APHIS’s

Implementation of the

Slaughter Horse Transport

Program

APHIS Has Not Issued a Final

Rule to Better Protect Horses

 

Transported for Slaughter

 

Page 28 GAO-11-228 Horse Welfare

In reviewing a generalizable sample of nearly 400 owner/shipper

certificates from before and after cessation of domestic slaughter in 2007,

we found that shippers usually designated horses as “for slaughter” on the

final leg of their journey to a slaughtering facility, as allowed under the

current regulation. For example, prior to cessation in 2007, shippers

sometimes designated horses near the U.S. facility in which they would be slaughtered. Specifically, we found cases in which horses shipped to the

slaughtering facility in DeKalb, Illinois, were designated for slaughter at a

point just a few miles from the plant. Similarly, since cessation in 2007,

shippers sometimes made this designation near border crossings with

Canada or Mexico. For example, since cessation, we found shipments of

horses being designated for slaughter in Shelby, Montana, about 36 miles

from the border crossing into Canada and in El Paso, Texas, about 10

miles from where they cross the border into Mexico. According to APHIS

officials, in virtually all of these cases, without a “for slaughter”

designation, it is likely that before reaching these designation points, the

horses already had traveled for long distances within the United States

without the protection of the APHIS transport regulation to ensure their

humane treatment. For example, some of the horses may have been

transported in double-deck trailers intended for smaller livestock animals; as discussed, the APHIS transport regulation prohibits the use of this type of trailer after the designation for slaughter is made.

To address this issue, APHIS proposed, in November 2007, to amend the

existing transport regulation to extend APHIS’s oversight of horses

transported for slaughter to more of the transportation chain that these

horses pass through. The proposed rule defines equine for slaughter as an

equine transported to intermediate assembly points, feedlots, and

stockyards, as well as directly to slaughtering facilities.16 The current

regulation does not define equine for slaughter and only applies to those

equines being transported directly to slaughtering facilities. APHIS has

experienced repeated delays in issuing a final rule that would extend

APHIS’s oversight of horses being transported for slaughter. According to

USDA officials, the delay is the result of a number of factors, including,

competing priorities and the need to address substantive, public

comments on the proposed rule that resulted in reclassifying it as

16This proposed regulatory change is consistent with the definition of equine for slaughter

 

in the Federal Agriculture Improvement and Reform Act of 1996.

 

Page 29 GAO-11-228 Horse Welfare

significant under Executive Order 12866.17 As of June 2011, USDA officials

said they anticipate issuing the final rule by the end of calendar year 2011. APHIS officials noted that this change to the transport regulation could

help address another issue as well. Specifically, the regulation currently

does not apply to shippers transporting horses to Canada as feeder

horses.18 As discussed, some U.S. horses exported for purposes other than

slaughter (i.e., not designated for slaughter on an owner/shipper

certificate) may be feeder horses that are ultimately sent to slaughtering

facilities at a later time. According to APHIS officials, the number of feeder

horses has likely grown with the increase in total horse exports to Canada

since 2007. Because feeder horses are not designated for slaughter before crossing the border, they are not covered by the transport regulation at

any point in their journey. If the transport regulation is amended, however,

as APHIS has proposed, the designation “equine for slaughter” would

apply to these animals during the leg of their trip from the U.S. auction

where they were purchased to the border crossing, including any

intermediate stops within the United States at assembly points, feedlots,

and stockyards. Such a designation would place those animals under the

protection afforded by APHIS’s oversight. APHIS officials also noted that

the provision of the 1996 Farm Bill authorizing the transport regulation is the only federal statute that regulates the transportation of horses, and

they commented on the irony that horses designated for slaughter are

provided greater protection, under current federal law and the transport

regulation, than other horses in commercial transit.

Over the past 6 fiscal years, the transport program’s annual funding has

varied, generally declining from a high of over $306,000 in fiscal year 2005

to about $204,000 in fiscal year 2010. This funding primarily provides for

the salaries and expenses of two staff, one of whom is the national

compliance officer, who inspects conveyances and owner/shipper

17Executive Order 12866 defines significant regulatory actions as those that are likely to

result in a rule that may, among other things, raise novel legal or policy issues arising out of

legal mandates, the President’s priorities, or the principles set forth in the order. Such rules

require additional review by the Office of Information and Regulatory Affairs within the Office of Management and Budget.

18Shippers may send horses across the border as “feeder” horses to a feedlot to add weight

to these animals, enhancing their slaughter value. Moreover, as a practical matter, because

of the European Union’s new restrictions on drug residues in horsemeat, it may be

necessary to hold U.S. horses at a Canadian feedlot for several months before slaughtering

to ensure they are purged of drug residues.

Limited Staff and Funding

Complicates Program

 

Implementation

 

Page 30 GAO-11-228 Horse Welfare

certificates for compliance with the transport regulation, with the

remainder going to travel costs.19 The two program officials stated that the program’s limited funding, particularly for travel, has significantly

curtailed their ability to provide coverage at border crossings and to work

with shippers and inspectors in foreign slaughtering facilities to ensure

compliance with the transport regulation. For example, with one

compliance officer, the program cannot adequately cover the numerous

border crossings on the Canadian and Mexican borders through which

shipments of horses intended for slaughter move. In April 2011, transport

program officials said they recently had begun training inspectors in

APHIS’s Western region and Texas area office to assist the program at

southern border crossings by, in part, collecting owner/shipper certificates

and returning them to APHIS headquarters. However, these officials said

they did not have a written plan or other document that describes this

initiative, including the number of staff to be involved, their anticipated

duties to support the transport program, and the time frames for

implementing the initiative. Hence, while this appears to be a positive step,

we were unable to evaluate the potential usefulness of this initiative.

Figure 9 provides information on the transport program’s funding for fiscal

years 2005 through 2010.

19The Compliance Officer’s duties include inspecting paperwork and conveyances at U.S.

border crossings and other inspection points and visiting auctions to work with

 

owner/shippers to gain compliance with the regulation.

 

Page 31 GAO-11-228 Horse Welfare

Figure 9: Slaughter Horse Transport Program’s Budget Obligations, Fiscal Years

2005 through 2010

According to program officials, the reduction in funds in 2009 was the result

of a cut in travel funds that were allocated to other APHIS programs. The

program officials added that the seesaw nature of the program’s funding, as well as the fact the program has just two staff, has affected their ability to ensure compliance with, and enforce, the transport regulation and

contributed to year-to-year variations in the number of violations found. In

addition, because of limited staff and funding, APHIS stopped entering

information from owner/shipper certificates into an automated database in 2005. Agency officials said that the database was used in the early years of

the transport program to document demographic information, such as the

identity of shippers and origin of horses they shipped. However, after

several years, this information was well established, and there was no need

to continue to collect data for this purpose. They also said that the database did not provide beneficial information for protecting horse welfare that justified the cost of maintaining the database. Nonetheless, automating the

certificate data would make it easier for the agency to analyze them to, for

example, identify potential problem areas for management attention and

possible enforcement action, such as patterns of violations or other

problems associated with particular shippers, border crossings, or slaughtering facilities. It would also allow the agency to easily identify

buying trends and common shipping routes. Furthermore, automating data

Obligations (in dollars)

 

*GRAFT UNABLE TO PUBLISH ON THIS BLOG*

Source: USDA’s Slaughter Horse Transport Program.

Fiscal year

306,475.01

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

2005 2006 2007 2008 2009 2010

269,901.69

216,456.02

256,505.31

204,189.33

 

118,876.82

 

 

Page 32 GAO-11-228 Horse Welfare

from the certificates on the number of horses in each shipment could

potentially provide USDA a more accurate count of the number of U.S.

horses exported for slaughter. At present, to estimate the number of horses

exported for this purpose, USDA’s Foreign Agricultural Service pieces

together Canadian and Mexican data on horses imported for slaughter and

makes certain extrapolations to arrive at an approximate number since no

official U.S. trade data exist on horses exported for slaughter.

Federal internal control standards call for agencies to obtain, maintain,

and use relevant, reliable, and timely information for program oversight

and decision making, as well as for measuring progress toward meeting

agency performance goals.20 Furthermore, the Office of Management and

Budget’s implementing guidance directs agency managers to take timely

and effective action to correct internal control deficiencies.21 APHIS’s lack

of a reliable means of collecting, tracking, and analyzing owner/shipper

certificates constitutes an internal control weakness and leaves the agency without key information and an important management tool for

enforcement of the transport regulation.

With the cessation of domestic slaughter and the transport program’s

limited staff and funding, APHIS relies on the cooperation of officials from Canada and Mexico working at border crossings and in their countries’

slaughtering facilities to help the agency implement the transport regulation.

APHIS has sought similar cooperation from officials working for the Texas

Department of Agriculture regarding horses exported through Texas border crossings. The effectiveness of these cooperative arrangements has been

uneven, in part because APHIS lacks current, formal written agreements

with its foreign and state counterparts to better define the parameters of this cooperation and ensure continuity over time as the personnel involved

change. We have previously reported that by using informal coordination

mechanisms, agencies may rely on relationships with individual officials to

ensure effective collaboration and that these informal relationships could

end once personnel move to their next assignments.22

20GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

21Office of Management and Budget, Executive Office of the President, OMB Circular No.

A-123, Management’s Responsibility for Internal Control (Dec. 21, 2004).

22GAO, National Security: Key Challenges and Solutions to Strengthen Interagency

Collaboration, GAO-10-822T (Washington, D.C.: June 9, 2010).

Uneven Cooperation with

Canadian, Mexican, and State

 

Officials Impedes Oversight

 

Page 33 GAO-11-228 Horse Welfare

Regarding Canada, representatives of APHIS and the Canadian Food

Inspection Agency (CFIA) signed a letter of intent in October 2002 outlining their shared responsibilities for enforcement of the transport

regulation. Each country pledged to help the other enforce its regulations.

For example, to assist APHIS, CFIA agreed to ensure, either at points of

entry or slaughtering facilities, the following regarding shipments of U.S.

horses to Canada for slaughter:

• health certificates for the horses are endorsed by USDA-accredited

veterinarians within the 30 days prior to export;

• horses are clinically healthy, fit for travel, and transported humanely to

the points of entry;

• owner/shipper certificates are properly completed, including the date, time, and location the horses were loaded;

• horses are listed correctly on the owner/shipper certificate, so that for

example, the backtags on the horses match the backtags listed on the

certificate;

• an ante-mortem inspection of each horse is performed;

• date and time the shipment arrived at the facility is noted on the

certificate; and

• copies of all relevant documents (e.g., owner/shipper certificates) are

returned to APHIS each month.

APHIS officials said they rely on owner/shipper certificates, properly

completed by shippers and CFIA officials, as appropriate, and returned by CFIA to APHIS for compliance and enforcement purposes. For example,

APHIS needs information on the timing of the loading and off-loading of a

shipment of horses to assess whether a shipper complied with regulatory

requirements related to the amount of time a shipment is in transit. Figure

10 highlights sections of the owner/shipper certificate that are to be

 

completed by shippers or Canadian or Mexican officials.

 

Page 35 GAO-11-228 Horse Welfare

In reviewing a generalizable sample of certificates returned by CFIA from 2005 through 2009, however, we found instances in which certificates

were not properly completed by either the shipper or CFIA officials. Based

on the results of our review, we estimate that about 52 percent of

certificates were missing key information that should have been filled in

by either the shipper (e.g., loading date and time, or certification that the

horses were fit for transport) or CFIA (e.g., arrival date and time, or

slaughtering facility identification). In addition, we estimate that about 29

percent of certificates returned to APHIS were missing some or all of the

information to be provided by CFIA officials at the slaughtering facility.23

Moreover, in our review of these certificates we noted that the extent to

which they were returned incomplete from CFIA to APHIS increased over

time. For example, from 2005 through 2006, the 2 years prior to the

cessation of domestic slaughter in the United States, we estimate that

about 48 percent of certificates were missing key information that should

have been completed by either the shippers or CFIA officials. However,

from 2008 through 2009, the 2 years after the cessation, we estimate that

about 60 percent of certificates were missing key information.24 This

increase suggests that the growth in U.S. horse exports for slaughter since

the cessation has been accompanied by an increase in problems with

owner/shipper certificates needed by APHIS for enforcement purposes.

However, APHIS and CFIA have not revisited this agreement since 2002 to

reflect changes since the cessation of slaughter in 2007, when the volume of horses exported to Canada increased significantly and APHIS became

more dependent upon cooperation from Canadian border officials and

CFIA inspectors in slaughtering facilities.

Regarding Mexico, APHIS lacks a written agreement with its relevant counterpart, Mexico’s Secretaría de Agricultura, Ganadería, Desarrollo

Rural, Pesca y Alimentación (SAGARPA), to promote cross-border

cooperation.25 APHIS officials said that they drafted an agreement in 2002,

similar to the one with CFIA, and that APHIS had contacts with SAGARPA

23All estimates from our review of owner/shipper certificates are subject to sampling error.

The 95-percent confidence intervals for our estimates of 52 percent and 29 percent are 44 to 61 percent and 21 to 36 percent, respectively.

24The 95-percent confidence intervals for our estimates of 48 percent and 60 percent are 28 to 69 percent and 49 to 71 percent, respectively.

25In English, this would be the Secretary of Agriculture, Livestock Production, Rural

 

Development, Fishery, and Food; this is Mexico’s agriculture department.

 

Page 36 GAO-11-228 Horse Welfare

about finalizing it during 2002 and 2003. However, according to APHIS

officials, the Mexican agency did not provide a response consenting to the

agreement, and APHIS has not renewed the effort to get an agreement

since 2003. Thus, these officials said, enforcing the transport regulation

along the southern border is more difficult than along the northern border

with Canada. Moreover, while shippers on the northern border can drive

their conveyances directly into Canada, U.S. shippers generally are not

insured to travel into Mexico. As a result, shippers unload their horses

before crossing the border, where SAGARPA officials inspect the horses.

The horses are subsequently loaded onto a Mexican conveyance for

transport to a Mexican slaughtering facility.

In the absence of a formal, written agreement between APHIS and

SAGAPRA or the Texas Department of Agriculture, APHIS does not

receive official cooperation from Mexican or Texas officials. As a

consequence, owner/shipper certificates may not be correctly filled out by

the shippers and collected, completed, and returned to APHIS from either

the border crossing or the Mexican slaughtering facility with information

about shipment dates and times and horse conditions. In some cases,

APHIS had an informal understanding with SAGARPA officials at a border

crossing that they would collect and return the certificates to APHIS. In

other cases, at Texas border crossings, employees of the Texas

Department of Agriculture informally cooperated with APHIS by collecting

and returning the certificates to the agency and alerting it to possible

violations of the transport regulation. However, these informal

arrangements have not been sustained over time and have not been

sufficient to ensure the return of certificates to APHIS. For example, as of March 2011, APHIS transport program officials said they have not received

any owner/shipper certificates from Texas border crossings in more than a

year. Although some U.S. horses intended for slaughter are exported

through a border crossing in New Mexico, the majority of horses bound

for Mexico pass through the Texas crossings.26 Thus, program officials said

their ability to enforce the transport regulation for shipments of horses

exported through these border crossings has been severely hampered.

In addition to the more recent problem with certificates not being returned

from the Texas border crossings, we reviewed a generalizable sample of

owner/shipper certificates returned from the southern border from 2005

 

26Regarding the New Mexico border crossing, the transport program relies on the help of the APHIS Port Veterinarian to collect and return owner/shipper certificates.

 

Page 37 GAO-11-228 Horse Welfare

through 2009 to determine the extent to which they were correctly

completed by shippers and SAGARPA officials. Based on the results of our

review, we estimate that about 48 percent of these certificates from 2005

through 2009 were missing key information to be provided by either

shippers or SAGARPA officials. Moreover, about 54 percent of certificates

from 2008 through 2009 were missing such information, suggesting an

increase in problems associated with the recent increase in exports to

Mexico of horses intended for slaughter. In addition, we estimate that

about 39 percent of certificates returned to APHIS were missing some or

all information, including the date and time the horses were unloaded at

the border, to be provided by SAGARPA officials.27

Legislative prohibitions have impeded USDA’s ability to protect horse welfare since fiscal year 2006. First, as discussed, appropriations bills for

fiscal years 2006 through 2010 have prohibited APHIS from using federal funds to inspect horses being transported for slaughter. As a result, according to agency officials, the transport program’s compliance officer

may only inspect the owner/shipper certificates associated with the shipment of horses and the conveyance on which the horses are

transported. That is, only while inspecting these items may the officer also incidentally observe any potential violations of the transport regulation regarding the physical condition of the horses because of the

annual prohibition on the expenditure of federal funds on inspecting

horses. The compliance officer said this makes it difficult to ensure that horses are transported humanely to slaughter and to collect information

on potential violations that is needed for APHIS to pursue enforcement actions. For example, while inspecting a conveyance being used to

transport horses intended for slaughter in 2010, the compliance officer

found that a mare in the shipment had given birth to a foal. Because the

transport regulation requires shippers to verify that horses are not likely to give birth during shipment, the birth of a foal in transit represented a potential violation. However, because of the prohibition on using funds to inspect horses, the officer was unable to inspect the horses to determine which mare had given birth. Thus, the opportunity was lost to document a potential violation of the regulation by the shipper. Moreover, according to the officer, compliance probably has suffered because shippers are aware that transport program officials cannot

27The 95-percent confidence intervals for our estimates of 48 percent, 54 percent, and 39

percent are 36 to 60 percent, 37 to 71 percent, and 27 to 50 percent, respectively.

Legislative Prohibitions

Impede USDA’s Ability to

 

Ensure Horse Welfare

 

Page 38 GAO-11-228 Horse Welfare

inspect horses in transit to substantiate potential violations. According to APHIS officials, another impediment to their investigations of potential violations of the transport regulation is USDA’s lack of subpoena

authority to access the records of alleged violators or to compel persons

to testify in administrative hearings and to produce documentary evidence for such hearings. Specifically, although USDA has such authority under several other APHIS-administered statutes (e.g., Animal Health Protection Act, Horse Protection Act, and Plant Protection Act), it does not have this authority under the authorizing legislation for the

transport regulation—the 1996 Farm Bill. According to APHIS officials,

the agency would welcome the addition of subpoena authority to promote enforcement of the slaughter horse transport regulation.

Second, USDA also has been prohibited from using federal funds to

inspect horses prior to slaughter for human consumption at slaughtering

facilities. As discussed, the Federal Meat Inspection Act requires

inspection of all cattle, sheep, swine, goats, and horses before they are slaughtered and processed into products for human food and to ensure

that meat and meat products from these animals are unadulterated,

wholesome, and properly labeled. Prior to the appropriations prohibition, and before the cessation of domestic slaughter, FSIS officials in U.S.

slaughtering facilities inspected the condition of horses before slaughter

as well as the horsemeat after slaughter. The prohibition on the use of

funds for required inspections has, in effect, banned the slaughter of

horses for food in the United States, and, as a consequence, moved this

slaughter to other countries where USDA lacks jurisdiction and where the

Humane Methods of Slaughter Act does not apply. Therefore, USDA is less

able to ensure the welfare of horses at slaughter. And, as was the case with

horses in transit to slaughter, APHIS officials speculated that compliance

with the transport regulation has suffered because shippers are aware that

the program can no longer leverage the assistance of USDA personnel in

slaughtering facilities to ensure the completion of shipping paperwork or

note the condition of individual horses in a shipment. This view seems

consistent with our analysis of shipping certificates which found, as

discussed, a statistically significant increase in incomplete certificates

after the cessation of domestic slaughter. In addition, these officials noted

that the loss of FSIS’s assistance in slaughtering facilities, as well as the

prohibition on APHIS’s inspections of horses in transit, has led to a general

decline in investigation cases since 2007. Figure 11 shows the number of

 

investigation cases and alleged violators for fiscal years 2005 through 2010.

 

Page 39 GAO-11-228 Horse Welfare

Figure 11: Number of Investigation Cases and Alleged Violators of the Slaughter

Horse Transport Program Regulation, Fiscal Years 2005 through 2010

Note: According to APHIS officials, the number of alleged violators exceeds the number of

investigation cases because some investigations may reveal that multiple violators were responsible

for a single violation and some investigations do not substantiate that a violation occurred.

According to APHIS and animal protection officials, horse welfare is likely

to suffer as a consequence of horses traveling significantly farther to

slaughter since the cessation of domestic slaughter, including an increased

possibility of injuries when horses are confined in a conveyance with other

horses over longer transport distances and travel times. As these officials

explained, horses are by nature fight or flight animals, and when grouped in confinement, they tend to sort out dominance. In the tight quarters of a

conveyance, weaker horses are unable to escape from more dominant and

aggressive animals and, thus, are more prone to sustaining injuries from

kicks, bites, or bumping into other horses or the walls of the conveyance. Moreover, once a shipment of U.S. horses has crossed the border into

Canada or Mexico, APHIS no longer has authority to oversee their welfare,

and these animals may be in transit for long distances in these countries

before reaching a slaughtering facility. For example, the slaughtering

facilities in Mexico that process U.S. horses are located near Mexico City, Cessation of Domestic

Slaughter Has Diminished

 

*GRAPH UNABLE TO POST ON THIS BLOG*

APHIS’s Ability to

Implement the Transport

Regulation to Protect

Horse Welfare

Alleged violators

Investigation cases

0

18

36

54

72

90

108

126

144

162

180

2005 2006 2007 2008 2009 2010

Number

Source: GAO analysis of USDA’s APHIS data.

 

Fiscal year

 

 

Page 41 GAO-11-228 Horse Welfare

Figure 12: Example of Transport of Horses to Slaughtering Facilities Before and After Domestic Slaughter Ceased

 

*MAP OF U.S. AND POINTS OF SALE TO SLAUGHTER FACILITIES, FEEDLOTS, AND TRANSPORT GRAPH UNABLE TO POST ON THIS BLOG*

 

In addition, since the cessation of domestic slaughter, USDA has been less

able to help BLM prevent the slaughter of wild horses and burros. Wild

horses and burros may be adopted, but title does not pass to the adopter

until 1 year after the adoption, upon a determination that the adopter has

provided humane conditions, treatment, and care for the animal over that

Source: GAO analysis of USDA documents; Art Explosion (images); MapArt (map).

Slaughtering facility

Feedlot/stockyard

Transport of horses before domestic slaughter ceased.

Transport of horses after domestic slaughter ceased.

Assembly point/farm

 

Auction/sale point

 

Page 42 GAO-11-228 Horse Welfare

period. Upon transfer of title, the animals lose their status as wild free-

roaming horses and burros. As we reported in 2008,29 from 2002 through

the end of domestic slaughter in September 2007, about 2,000 former BLM

horses were slaughtered by owners to whom title to the horses had

passed.30 When horses were slaughtered domestically, FSIS inspectors in

slaughtering facilities watched for horses bearing the BLM freeze mark

indicative of the wild horse and burro program. They would then alert

BLM officials so that the title status of these animals could be checked to

ensure that BLM horses were not slaughtered. As a result of FSIS’s

assistance during the same time period, at least 90 adopted wild horses

that were still owned by the government were retrieved from slaughtering

facilities before they could be slaughtered. However, now that the

slaughter of U.S. horses occurs in Canada and Mexico, FSIS can no longer

provide this assistance. Furthermore, shippers are not required to identify BLM horses on owner/shipper certificates, but in reviewing nearly 400

owner/shipper certificates, we found indications that six adopted BLM

horses had been shipped across the border for slaughter. Because

inspection officials in foreign slaughtering facilities have no obligation to

check with BLM or other U.S. authorities before slaughtering these

animals, it is unknown whether title for those animals had passed to the

adopter or how many more BLM horses may have been shipped across the

border for slaughter.

The slaughter of horses for any purpose, especially for human

consumption, is a controversial issue in the United States that stems

largely from how horses are viewed, whether from an historic, work,

show, recreation, or commodity point of view. As a result, there is tension

between federal law mandating the inspection of horses and certain other

animals at slaughter (i.e., the Federal Meat Inspection Act) and annual

appropriations acts prohibiting the use of funds to inspect horses at, or

being transported to, slaughtering facilities.

What may be agreed upon, however, is that the number of U.S. horses that

are purchased for slaughter has not decreased since domestic slaughter

29GAO-09-77.

30BLM is not required to protect animals after ownership has passed to adopters or buyers. However, since the spring of 2005, BLM has required adopters to sign a statement that they do not intend to slaughter the animals to help address concerns by horse advocates about

 

horses being slaughtered. Conclusions

 

Page 43 GAO-11-228 Horse Welfare

ceased in 2007. Furthermore, an unintended consequence of the cessation

of domestic slaughter is that those horses are traveling farther to meet the same end in foreign slaughtering facilities where U.S. humane slaughtering protections do not apply. Their journey from point-of-purchase to

slaughtering facilities in other countries, with multiple potential stops in-

between at assembly points, feedlots, and stockyards, includes the

possibility of being shipped in conveyances designed for smaller animals

or confined in these conveyances for excessive time periods. The current

transport regulation, the Commercial Transportation of Equines to

Slaughter regulation, does not apply until a shipment is designated for

slaughter, which can be the last leg of a longer journey. A 2007 proposed

rule to amend the regulation, which would define “equines for slaughter”

and extend APHIS’s oversight and the regulation’s protections to more of

the transportation chain, has not been issued as final as of June 2011.

To adequately implement the transport regulation and oversee the welfare

of horses intended for slaughter, the horse transport program must ensure

that owner/shipper certificates are completed, returned, and evaluated for

enforcement purposes. Many certificates are not now returned, and others

are returned incomplete. Furthermore, because of limited staff and

funding and these missing and incomplete certificates, the program is less

able to identify potential violations of the transport regulation. The

program also stopped automating certificate data. Even with the present

limitations of incomplete and missing certificates, automating these data is important for management oversight of compliance with the regulation

and to direct scarce program resources to the most serious problem areas.

Moreover, in time, as corrective actions are taken, these data will likely

become even more useful for oversight purposes. If the proposed rule to

extend APHIS’s authority to more of the transportation chain is issued as

final, the program’s credibility will be further challenged unless APHIS

identifies ways to leverage other agency resources to ensure compliance

with the transport regulation.

With U.S. horses now being shipped to Canada and Mexico for slaughter,

APHIS depends upon cooperation with these countries, or state officials at the borders, to help it implement the transport regulation, but it does not

have effective agreements that make clear each party’s obligations and that

help ensure cooperation will continue as personnel change. APHIS

developed an agreement with Canadian officials in 2002, but recently the

agency has been receiving incomplete owner/shipper certificates from them,

raising questions about the current agreement’s effectiveness and whether

 

both APHIS and Canadian officials have the same understanding about the assistance APHIS seeks. Furthermore, APHIS does not have formal

 

Page 44 GAO-11-228 Horse Welfare

cooperative agreements with its Mexican counterpart and the Texas

Department of Agriculture—the entities that oversee most U.S. horses exported to Mexico for slaughter. APHIS has not received any

owner/shipper certificates from either of these entities in more than a year.

Recent, annual congressional actions to prohibit the use of federal funds to inspect horses in transit or at slaughtering facilities have complicated

APHIS’s ability to implement the transport regulation, thus horses now

travel longer distances to foreign slaughtering facilities. APHIS lacks

jurisdiction in these countries, and it can no longer depend on the help it

once received from other USDA officials present in domestic slaughtering

facilities to catch potential violations of the transport regulation. Even

after the recent economic downturn is taken into account, horse

abandonment and neglect cases are reportedly up, and appear to be

straining state, local, tribal, and animal rescue resources. Clearly, the

cessation of domestic slaughter has had unintended consequences, most

importantly, perhaps, the decline in horse welfare in United States.

In light of the unintended consequences on horse welfare from the

cessation of domestic horse slaughter, Congress may wish to reconsider

the annual restrictions first instituted in fiscal year 2006 on USDA’s use of

appropriated funds to inspect horses in transit to, and at, domestic

slaughtering facilities. Specifically, to allow USDA to better ensure horse

welfare and identify potential violations of the Commercial Transportation

of Equines to Slaughter regulation, Congress may wish to consider

allowing USDA to again use appropriated funds to inspect U.S. horses

being transported to slaughter. Also, Congress may wish to consider

allowing USDA to again use appropriated funds to inspect horses at

domestic slaughtering facilities, as authorized by the Federal Meat

Inspection Act. Alternatively, Congress may wish to consider instituting an explicit ban on the domestic slaughter of horses and export of U.S. horses

intended for slaughter in foreign countries.

Matters for

Congressional

 

Consideration

 

Page 45 GAO-11-228 Horse Welfare

To better protect the welfare of horses transported to slaughter, we

recommend that the Secretary of Agriculture direct the Administrator of

APHIS to take the following four actions:

• Issue as final a proposed rule to amend the Commercial Transportation

of Equines to Slaughter regulation to define “equines for slaughter” so

that USDA’s oversight and the regulation’s protections extend to more

of the transportation chain.

• In light of the transport program’s limited staff and funding, consider

and implement options to leverage other agency resources to assist the

program to better ensure the completion, return, and evaluation of

owner/shipper certificates needed for enforcement purposes, such as

using other APHIS staff to assist with compliance activities and for

automating certificate data to identify potential problems requiring

management attention.

• Revisit, as appropriate, the formal cooperative agreement between

APHIS and CFIA to better ensure that the agencies have a mutual

understanding of the assistance APHIS seeks from CFIA on the

inspection of U.S. horses intended for slaughter at Canadian

slaughtering facilities, including the completion and return of

owner/shipper certificates from these facilities.

• Seek a formal cooperative agreement with SAGARPA that describes

the agencies’ mutual understanding of the assistance APHIS seeks from SAGARPA on the inspection of U.S. horses intended for slaughter at

Mexican border crossings and slaughtering facilities and the

completion and return of owner/shipper certificates from these

facilities. In the event that SAGARPA declines to enter into a formal

cooperative agreement, seek such an agreement with the Texas

Department of Agriculture to ensure that this agency will cooperate

with the completion, collection, and return of owner/shipper

certificates from Texas border crossings through which most

shipments of U.S. horses intended for slaughter in Mexico pass.

Recommendations for

 

Executive Action

 

Page 46 GAO-11-228 Horse Welfare

We provided a draft of this report to USDA for review and comment. In

written comments, which are included in appendix III, USDA agreed with the report’s recommendations. Regarding the first recommendation, USDA

said it will move as quickly as possible to issue a final rule, but first it must

formally consult with the Tribal Nations that are experiencing particularly

serious impacts from abandoned horses. USDA said that if it can

successfully conclude these negotiations in the next 2 months, it would

publish the final rule by the end of calendar year 2011. However, USDA

also said that it needs time to thoughtfully consider those consultations in

regards to the regulation’s implementation. Regarding the second

recommendation, USDA noted it is training additional APHIS port

personnel in Slaughter Horse Transport Program enforcement activities at

Texas ports of embarkation and plans to expand this effort in fiscal year

2012 within the allocated budget. USDA also stated it is training

administrative personnel to evaluate owner/shipper certificates for

enforcement purposes, and it will explore whether new technologies have

made the process of entering information from those certificates into a

database less costly in order to do so within existing funding. Regarding the third recommendation, USDA said it would consult with CFIA and

propose revisions to the current cooperative agreement. Regarding the

fourth recommendation, USDA indicated it will consult with SAGARPA

and the Texas Department of Agriculture and propose the development of

formal agreements with one or both. We are sending copies of this report to the appropriate congressional

committees, the Secretary of Agriculture, and other interested parties. In

addition, the report will be available at no charge on GAO’s Web site at

http://www.gao.gov.

If you or your staff members have any questions about this report, please

contact me at (202) 512-3841 or shamesl@gao.gov. Contact points for our

Offices of Congressional Relations and Public Affairs may be found on the

last page of this report. GAO staff who made major contributions to this

report are listed in appendix IV.

Lisa Shames

Director, Natural Resources

and Environment

Agency Comments

 

and Our Evaluation

 

Appendix I: Objectives, Scope, and

Methodology

Page 47 GAO-11-228 Horse Welfare

Our report objectives were to examine (1) the effect on the U.S. horse

market, if any, since domestic slaughter of horses for food ceased in 2007;

(2) the impact, if any, of these changes on horse welfare and on states,

local governments, tribes, and animal welfare organizations; and (3)

challenges, if any, to the U.S. Department of Agriculture’s (USDA)

oversight of the transport and welfare of U.S. horses exported for

slaughter.

In general, to address these objectives, we reviewed documents and/or

interviewed officials from

• USDA, including the Animal and Plant Health Inspection Service

(APHIS), Food Safety Inspection Service, Foreign Agricultural Service,

National Agricultural Statistics Service, and the Office of Inspector

General;

• other federal agencies such as the Department of the Interior’s Bureau

of Land Management, Department of Commerce, Department of

Labor’s Bureau of Labor Statistics, and Congressional Research

Service;

• state and local governments, including the National Association of

State Departments of Agriculture, Montana Association of Counties,

National Association of Counties, National Sheriffs Association, and

Western State Sheriffs Association; and

• Native American tribes, including several Great Plains Tribes, the

Northwest Tribal Horse Coalition, and several Southwestern Tribes.1

We also reviewed documents and/or interviewed representatives from

• livestock industry organizations, including the American Association of

Equine Practitioners, American Horse Council, American Veterinary

Medical Association, Florida Animal Industry Technical Council,

Maryland Horse Industry Board, Livestock Marketing Association,

United Horsemen’s Front, United Organizations of the Horse,

Unwanted Horse Coalition, and commercial horse auctions located in

1The Northwest Tribal Horse Coalition consists of tribes from five reservations–the

Confederated Tribes of the Colville Reservation, Washington; the Confederated Tribes of

the Umatilla Reservation, Oregon; the Confederated Tribes of the Warm Springs

Reservation of Oregon; the Confederated Tribes and Bands of the Yakama Nation,

Washington; and the Shoshone-Bannock Tribes of the Fort Hall Reservation of Idaho.

Appendix I: Objectives, Scope, and

 

Methodology

 

Appendix I: Objectives, Scope, and

Methodology

Page 48 GAO-11-228 Horse Welfare

various states, including Alabama, Arkansas, Montana, Oklahoma,

Pennsylvania, and Virginia; and

• animal welfare organizations, including the American Society for the

Prevention of Cruelty to Animals, Animal Law Coalition, Animal

Welfare Institute, Equine Welfare Alliance, and Humane Society of the

United States.

In addition, we reviewed published literature related to the horse industry

and livestock slaughter, and we interviewed academic experts who have

researched and written about these issues. Furthermore, we reviewed

relevant federal and state legislation regarding horse inspection, slaughter,

transport, and/or welfare, including bills proposed but not enacted in the

111th U.S. Congress and by state legislatures, and related federal

regulations, including USDA’s Commercial Transportation of Equines to

Slaughter regulation and related guidance. To determine the extent to

which slaughter for non-food purposes occurs in the United States, we

identified facilities that had been reported to slaughter horses for other

purposes (e.g., food for animals at zoos and circuses) and interviewed the

Slaughter Horse Transport Program’s compliance officer about the

officer’s examinations into these facilities’ operations. We also visited

border crossings in New Mexico and Texas, horse auctions in Montana

and Pennsylvania, and tribal lands in the northwest United States to

observe the handling of horse shipments at the border, horse sale

procedures, and wild and abandoned horse management challenges,

respectively. To further examine the effect on the U.S. horse market, if any, since the

cessation of domestic slaughter, we used an econometric analysis and

regression methods to estimate the effect of the cessation on horse prices,

while considering the effects of the U.S. economic downturn (i.e.,

recession) and horse- and auction-specific variables.2 We did this analysis

because we found few current studies addressing the effect of the

cessation on horse prices in the economic literature. In undertaking this

work, we collaborated with Dr. Mykel Taylor, Assistant Professor and

Extension Economist in the School of Economic Sciences at Washington

2“Econometric” refers to the application of statistical methods to the study of economic

data, and “regression” is a statistical method used in econometrics that can isolate the impact of one variable on a particular outcome while considering the impact of other variables. In this case, the variable and outcome of particular interest are the cessation of

 

domestic slaughter and changes in horse prices, respectively.

 

Appendix I: Objectives, Scope, and

Methodology

Page 49 GAO-11-228 Horse Welfare

State University, who was studying this issue at the time we began our

work and previously had modeled and written about the determinants of

horse prices.

We obtained data for our analysis from multiple sources. Regarding horse

prices, we obtained sale price and horse characteristic data on 12,003 sale transactions from spring 2004 through spring 2010 at three large horse

auctions located in Montana, Oklahoma, and Virginia. Specifically, we

extracted data from price sheets and catalogue information published or

otherwise provided by the owners of these auctions. We chose these

auctions because they were located in geographically diverse parts of the

country. In addition, these auctions regularly sell lower-value horses, as

well as more expensive horses valued for leisure, work, or show purposes.

Some, but not all, of the lower-valued horses in the data are bought for

slaughter, including some referred to as “grade” or “loose” horses. We

assumed that if there was an effect from the cessation of domestic horse

slaughter, prices for lower-valued horses would be most impacted.

Consequently, we did not include data in our analysis from auctions

catering to very high-priced racing and show horses. We also obtained

data from the Department of Labor’s Bureau of Labor Statistics on

changes in unemployment in each of the regions in which the horse

auctions we selected are located. We used these unemployment data as a

proxy for the economic downturn experienced in recent years. We

performed quality tests and interviewed knowledgeable agency officials

and auction representatives about the sources of the data and the controls in place to maintain the data’s integrity, and we found the data to be

sufficiently reliable for the purposes of this report.

Using these data, we analyzed whether there was a significant reduction in average sale price per head after the cessation of domestic slaughter. For

purposes of our analysis, the period prior to cessation included spring

2004 through 2006, and the period after cessation included 2007 through

spring 2010 (because most domestic slaughtering facilities were closed by early 2007). To evaluate the potential reasons for this reduction in price,

we also developed a hedonic model, which allows one to describe the

price of a good (e.g., a horse) as a function of the value of intrinsic

characteristics of that good (e.g., a horse’s breed, age, and gender).3 Thus,

we specified a horse’s sale price as a function of variables that describe its

3In a hedonic model, the individual coefficients of the regression variables represent the

 

implicit price of each characteristic found in that good.

 

Appendix I: Objectives, Scope, and

Methodology

Page 50 GAO-11-228 Horse Welfare

physical attributes, such as breed, age, and gender; auction-specific

variables, such as region of the country and season of the year; and other

variables, such as the cessation of domestic slaughter and economic

downturn. We used the quantile regression technique to derive coefficients

to explain the impact on horse prices for each variable in the model.

Quantile regression is a statistical method that provides information about

the relationship between an outcome variable (e.g., horse prices) and

explanatory variables (e.g., cessation of slaughter) at different points in

the distribution of the outcome variable.4 This type of regression is more

appropriate than standard linear regression for several reasons. For

example, we wanted to determine the estimated effects of the cessation at

various points across the entire distribution of sales prices in our data,

instead of on just the average value (i.e., mean), as in linear regression.5

Also, the approach is more appropriate when using data from separate

sources, such as the three auctions in different parts of the country. In

addition, because our price data were highly skewed (i.e., included mostly

lower- and mid-priced horses), we transformed prices to a natural

logarithmic scale in the regression in order to obtain a better statistical fit

for our model.6

There are several potential limitations to this type of modeling. For

example, all of the variables influencing an outcome may not be known,

and there are likely to be limitations in the data available for the analysis.

For example, the price of a horse may also be related to other attributes

such as quality of pedigree and performance characteristics (e.g.,

championships or titles won), but information on these variables was not

available for all horses in our analysis. In addition, other characteristics of

a horse, such as health, demeanor, and general appearance may also affect

the price buyers are willing to pay, but those characteristics are difficult to

measure and, therefore, were not available for our analysis. Nevertheless,

despite these limitations, this type of regression is useful for developing 4Quantiles and percentiles are synonymous—for instance, the 0.80 quantile is the 80th percentile. The median, or the middle value of the ranked dataset, is the 0.50 quantile or

50th percentile.

5Standard linear regression models the relationship between one or more explanatory variables, X, and the mean of an outcome variable, Y. In contrast, quantile regression

models the relationship between X and the quantiles of Y, and it is especially useful in

applications where low and high values in the distribution of Y are important.

6One common transformation of data used in econometric (or regression) analysis is the

natural logarithmic scale (ln). It is often used to transform highly-skewed data into a more

 

normal (or symmetric) distribution.

 

Appendix I: Objectives, Scope, and

Methodology

Page 51 GAO-11-228 Horse Welfare

estimates of the impacts from, and an indication of the relative importance

of, various variables to an outcome.

In our analysis, we estimated the impact of the cessation on horse prices,

while considering other relevant variables, on horse sale price for five

price quantiles (20th, 40th, 50th, 60th, and 80th percentiles). As discussed,

the other variables in our analysis included a horse’s physical characteristics, such as breed/type, age, and gender. Regarding breed, the

data contained a total of 27 horse breeds, but for purposes of our analysis, we categorized horses into one of seven variables—Quarter horses, Paint

horses, Appaloosas, ponies and miniature horses, Thoroughbreds,

combined “other,” and “grade.” Grade horses are sold without breed

designation, are often sold in groups, and are usually the lowest-priced

horses available at an auction. Regarding age, horses in our data ranged

from 1 to 32 years old, and we included age as a continuous variable in our

analysis. We also used a related variable, the square of a horse’s age, to account for changes in a buyer’s willingness to purchase a horse as its age

increases. Regarding gender, we used “indicator” variables for mare,

stallion, and gelding (a neutered male horse).7 In addition, we used two

interactive variables to explain how the gender and age of a horse could

interact to affect its sale price—(1) interacting mare with age and (2)

interacting gelding with age. For example, the price of a mare may

increase early in her life as she is able to produce foals but may decline

when she becomes too old to breed consistently.

To capture information that was auction-specific, we included several

additional variables in our analysis. First, we measured the percentage of “no-sale” horses at each auction. In general, these horses were not sold by

their owners because they did not receive high enough final bids for these

horses at auction. We also included a variable denoting whether an

auction was in the western, southern, or eastern region of the United

States. In addition, we included variables to delineate whether an auction

was held in the spring or fall seasons. Industry experts we contacted said

spring auctions generally are larger and bring higher prices than fall

auctions, when owners may be more anxious to sell their horses rather

than have to feed them through the winter.

 

7An indicator variable takes the value of 1 or 0, depending on whether an event is true or present (i.e., 1), or not (i.e., 0).

 

Appendix I: Objectives, Scope, and

Methodology

Page 52 GAO-11-228 Horse Welfare

We included the cessation of slaughter as an indicator variable in our

analysis, with “0” indicating the period prior to the cessation of domestic

slaughter in 2007, and “1” for the period after. For purposes of our

analysis, the period prior to cessation included spring 2004 through 2006,

and the period after cessation included 2007 through spring 2010 (because most domestic slaughtering facilities were closed by early 2007).

To measure the effect of the economic downturn, we used a variable

based on average monthly unemployment rates from the Bureau of Labor

Statistics for the 12-month period prior to the date of each auction. These

data are compiled by Census Divisions or by geographic region; we used

the data for those Census Divisions or regions that correspond to the

locations of the three auctions.8 More specifically, we averaged the

unemployment rate data for the 12-month period prior to the date of each auction because we assumed that buyers and sellers would make

transaction decisions based on economic conditions for a period before

the date of the auction, not just on conditions at the time of the auction.

In order to review the soundness of our methodology and results, we

asked five academic experts in agricultural economics to review a draft of our model specifications and discussion of results for fatal flaws. We

chose these experts because they have published articles related to the

horse industry and livestock slaughter issues. These experts generally

found the model specifications and results credible. Several offered

specific technical comments related to the presentation of the model

results, which we incorporated, as appropriate. Additional information

about the results of our analysis is in appendix II.

To further examine the impact, if any, of horse market changes on horse welfare and states, local governments, tribes, and animal welfare

organizations, we used semi-structured interviews to systematically collect

the views of the State Veterinarian (an appointed position) in 17 states.9

8For the eastern auction, we used unemployment data for the “Mid-Atlantic” and “South

Atlantic” regions, consisting of Delaware, District of Columbia, Florida, Georgia, Maryland,

New Jersey, New York, North Carolina, Pennsylvania, South Carolina, Virginia, and West

Virginia. For the southern auction, we used data for the “West South Central” region,

consisting of Arkansas, Louisiana, Oklahoma, and Texas. For the western auction we used

data for the “Mountain” region, consisting of Arizona, Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming.

9These states are California, Colorado, Florida, Indiana, Kentucky, Louisiana, Maryland, Missouri, Montana, New Mexico, New York, North Carolina, Ohio, Oklahoma,

 

Pennsylvania, Texas, and Wyoming.

 

Appendix I: Objectives, Scope, and

Methodology

Page 53 GAO-11-228 Horse Welfare

These states included the 10 with the largest horse populations, and the 10

with the largest horse economies—a total of 14 states. In addition, we

added Montana, New Mexico, and Wyoming at the suggestion of

representatives of the horse industry and animal welfare organizations,

who indicated that these states had unique perspectives on border or tribal

issues related to horses. In some cases, the State Veterinarian was joined

by other state officials, such as members of the state livestock board, for

these interviews. The results of the interviews are not generalizable to all

State Veterinarians but provide information about the situations faced by these 17 states.

Semi-structured interviews follow a standard structure to systematically

gather information from the target audience. In our case, we wanted to

systematically collect information from these 17 states on (1) horse sales

and prices; (2) export, trade, and transport of horses; (3) abandoned and adopted horses; (4) horse abuse and neglect cases; (5) legislation related

to horse slaughter and welfare; and (6) other factors generally affecting

horse welfare. Using software called NVivo, we then performed a

qualitative content analysis of the results of these interviews to identify

common themes and the frequency with which certain issues were raised.

Content analysis is a methodology for structuring and analyzing written

material. Specifically, we developed a coding and analysis scheme to

capture information on factors that may explain changes in the horse

industry in these states. Such factors included the cessation of domestic

slaughter; economic conditions; restrictions on the use of certain drugs in

horses slaughtered for human consumption; and changes in horse

breeding, disposal, care and maintenance, prices, sales, and such inputs as

the cost of feed. We also developed a coding and analysis scheme to

capture information on factors related to horse owners’ potential

responses to those changes, including abandoning, neglecting, abusing,

and hoarding horses, as well as factors related to horse welfare such as

being harmed by unfamiliar herds and traveling farther to slaughter. In

addition, we developed a coding and analysis scheme to identify state and local responses to changes in the horse industry, including impacts on

resources, costs, investigations, and legislation. The content analysis was

conducted by two GAO analysts with the assistance of a GAO

methodologist. Discrepancies in coding were generally discussed and

resolved between the analysts; on occasion, the methodologist weighed in

to resolve a discrepancy. To further examine challenges, if any, to USDA’s oversight of the transport

 

and welfare of U.S. horses exported for slaughter, we identified and

 

Appendix I: Objectives, Scope, and

Methodology

Page 54 GAO-11-228 Horse Welfare

analyzed a generalizable sample of about 400 horse shipping forms, known

as owner/shipper certificates, for the period 2005 through 2009, to

determine whether (1) the certificates were properly completed and (2)

horses were traveling farther to slaughter since the cessation of domestic

slaughter in 2007 than they were traveling prior to the cessation. Each

owner/shipper certificate represents one load or shipment of horses.

APHIS maintains these forms at its headquarters offices in Riverdale,

Maryland, in hardcopy, sorted by year and shipper.

As there were no electronic records of the sample frame (i.e., the universe

of certificates) from which we could randomly sample and we initially did not know the total number of certificates on file, we selected a stratified,

systematic random sample from the hardcopy certificates for the period. We chose to stratify the sample frame into three strata (i.e., time periods)

so we would be able to compare estimates of certificate completeness and

the distances horses traveled before and after 2007. Specifically, we

systematically selected 396 certificates, including 192 for 2005 through

2006, the 2 years prior to the cessation of domestic slaughter; 84 for 2007;

and 120 for 2008 through 2009, the 2 years after the cessation. In the

course of selecting this sample, we determined that there were nearly

16,000 certificates on file for these years, including 7,671 certificates for

2005 through 2006, 3,378 certificates for 2007, and 4,787 certificates for

2008 through 2009.

Because we followed a probability procedure based on random selections

of our starting points (e.g., first select the 25th certificate in the 2005

through 2006 strata and every 40th certificate thereafter), our sample is

only one of a large number of samples that we might have drawn. Since

each sample could have provided different estimates, we expressed our

confidence in the precision of our particular sample’s results as a 95

percent confidence interval. This is the interval that would contain the

actual population value for 95 percent of the samples we could have

drawn.

To estimate the degree to which owner/shipper certificates were properly

completed by the shipper and by Canadian and Mexican officials, we

extracted information from the certificates that APHIS uses to help

determine compliance with the Commercial Transportation of Equines to

Slaughter regulation, such as the loading date, time, and location;

certification that the horses were fit for transport; the identity of the

receiving slaughtering facility; and the date and time the shipment arrived.

Using our sample of certificates, we calculated estimates of the degree of

 

completeness of all certificates returned to APHIS from slaughtering

 

Appendix I: Objectives, Scope, and

Methodology

Page 55 GAO-11-228 Horse Welfare

facilities or border crossings from 2005 through 2009 and tested the

change over time for statistical significance.

In order to estimate the distance that horses traveled, on average, we

extracted information on each shipment’s origination (i.e., loading) point and destination (i.e., off-loading) point from the certificates. Regarding

shipments that went to former U.S. slaughtering facilities, we used the

Transportation Routing Analysis Geographic Information System

(TRAGIS) model developed by the Department of Energy to estimate

driving miles between the origination point, such as an auction, farm,

feedlot, or stockyard, and the slaughtering facility. Because TRAGIS

includes only U.S. roads, we used a different approach for calculating

distances beyond the U.S. border to foreign slaughtering facilities. First,

based on USDA information on the border crossings most often used to

export shipments of horses intended for slaughter, we used TRAGIS to

calculate the distance from an origination point to several border

crossings. Then, for each border crossing, we used commercial software

available on the Web to estimate the distance from these crossings to a

foreign slaughtering facility. We then combined the results and selected

the combination that resulted in the shortest potential distance traveled

from the origination point to the slaughtering facility. As a result, our

estimates of the total distance traveled to foreign slaughtering facilities are

likely to be underestimates.

We conducted this performance audit from April 2010 through June 2011,

in accordance with generally accepted government auditing standards.

Those standards require that we plan and perform the audit to obtain

sufficient, appropriate evidence to provide a reasonable basis for our

findings and conclusions based on our audit objectives. We believe that

the evidence obtained provides a reasonable basis for our findings and

 

conclusions based on our audit objectives.

 

Appendix II: Results of the Econometric

Analysis of Horse Sale Prices

Page 56 GAO-11-228 Horse Welfare

For our econometric analysis of horse sale prices from three large

geographically-dispersed horses auctions, we conducted a hedonic

quantile regression to estimate the impact of a number of explanatory

variables, including the cessation of domestic horse slaughter; the

economic downturn (i.e., recession); horse attributes such as breed, age,

and gender; and the location and timing of horse auctions, on the full

range of values of the outcome variable—horse sale prices. We were

particularly interested in the impact of the cessation and economic

downturn, as these factors have been cited as reasons for recent changes

in the horse industry. Appendix I includes a detailed explanation of our

methodology for this analysis.

A discussion of the results for the separate variables in the model follows:

• Age of horse. The results show that age is an important variable in

explaining horse prices in these auctions. The positive sign for a

horse’s age and negative sign for the age squared, indicate that young

horses will increase in price as they age, but older horses will start to

decline in price as they age. Moreover, the positive effect of age

becomes zero for mares and geldings between 11 and 12 years of age,

while stallions continue to increase in price for approximately 5 more

years.

• Gender of horse. The results indicate that the value of horses varies

both by their gender and the interaction of their gender and age.

Specifically, the results show that the price of geldings is initially

higher than both stallions and mares. This premium holds until

approximately age 12, when the premium relative to stallions has gone

to zero. Mares do not sell at a premium relative to stallions at any point

in the age distribution.

• Location and timing of auction. The results indicate that a horse sold

at either the eastern or southern auctions would fetch a higher price

than an identical horse sold at the western auction. The premium for

horses sold at the eastern auction is greater than the premium for

horses sold at the southern auction. The timing of an auction—spring

versus fall—was also statistically significant and suggests that horses

sold in the fall tend to sell at a discount, although this effect diminishes

for the higher price categories. This may be because owners may be

more anxious to sell their horses in the fall rather than feed them

through the winter.

• Auction no-sales percentage. The results suggest that for every 1

percent increase in an auction’s “no-sales” percentage, price decreased

Appendix II: Results of the Econometric

 

Analysis of Horse Sale Prices

 

Appendix II: Results of the Econometric

Analysis of Horse Sale Prices

Page 57 GAO-11-228 Horse Welfare

by about 2 percent across quantiles. That result was highly statistically

significant and consistent across all horse price quantiles. This phenomenon may result from sellers having certain expectations of

acceptable bid prices, and, if those expectations are not met, they may

be willing to wait for a later auction date to try selling the horse again.

Horse buyers may have expectations, as well, that prices will be falling

even lower and wait until the next auction. This may be especially true

during a period of economic slowdown, according to experts.

• Horse breed/type. The results suggest that Quarter horses sold at a

premium, relative to grade horses, which do not have a declared breed

registry. Ponies also tend to sell at a premium relative to grade horses,

for those ponies sold in the higher categories (i.e., quantiles). An

unexpected result was that other breed types, Paint horses,

Appaloosas, and Thoroughbred horses sold at either a discount or did

not show statistically significant difference in price, relative to grade

horses. This could have been due to the small number of observations

compared to other breeds and that for certain breeds, such as

Appaloosas, there could be a lack of buyers for these types of horses.

• Economic downturn. The results show that the recession or downturn

in the general economy caused a consistently negative effect on horse

prices across the range of price categories. This effect was greater, in

dollar terms, for the higher price categories. Across the five price

categories, we estimate that for each percentage point increase in

average unemployment in the relevant regions, horse prices decreased

by 5.2, 5.2, 4.8, 4.7, and 4.8 percentage points, respectively.

• Cessation of domestic slaughter. The results show that the cessation

was related to declines in prices for lower- to middle-value horses but

diminished for higher-value horses (i.e., horses in the higher price

categories in the table). For example, in the first three price categories,

horse prices declined by 21, 10, and 8 percentage points, respectively.

Table 2 lists the results, expressed as semi-log coefficients, of the hedonic

quantile regression for five categories of horse sale prices—the 20th, 40th,

50th (median), 60th, and 80th percentiles.1

1A semi-log model specification is one in which the outcome variable (Y) is transformed

into logarithms and the explanatory variables (X) are unchanged. The model coefficients of

the explanatory variables from this type of specification are then in semi-log form. The

semi-log specification has been widely used in the economic literature to estimate horse

 

and other livestock prices in hedonic models.

 

Appendix II: Results of the Econometric

Analysis of Horse Sale Prices

Page 58 GAO-11-228 Horse Welfare

Table 2: Semi-log Coefficients for Hedonic Quantile Regression of Horse Prices

Estimated coefficients by quantile (percentile) of horse price distributiona

Explanatory variableb 20th 40th50th (median) 60th80th

Age of horse 0.218***0.233*** 0.241*** 0.243***0.221***

Age of horse squared -0.007***-0.007***-0.007*** -0.007***-0.006***

Gender mare (female) 0.220***0.180** 0.086 0.103 0.129

Gender gelding (neutered male) 0.879***0.882***0.780*** 0.767***0.568***

Interaction of mare with age -0.061*** -0.071***-0.068*** -0.073***-0.075***

Interaction of gelding with age -0.059***-0.081***-0.086*** -0.094***-0.094***

Southern auction 0.488***0.532*** 0.477*** 0.504***0.535***

Eastern auction 0.860***0.924*** 0.878*** 0.813***0.809***

Fall auction -0.274***-0.204***-0.201*** -0.173***-0.126***

Auction no-sale percentage -0.020*** -0.020***-0.016*** -0.016***-0.012***

Breed Quarter horse 0.216*** 0.291*** 0.321*** 0.323***0.381***

Breed Paint horse -0.138** -0.134***-0.092* -0.068 -0.094*

Breed Appaloosa horse -0.111 -0.156 -0.272* -0.348* -0.392**

Breed ponies & miniature horse 0.075 0.117 0.132 0.217** 0.201**

Breed Thoroughbred horse -0.437*** -0.667**-0.385 -0.430 -0.407**

Breed other (misc.) horse -0.082 0.017 0.023 -0.054 -0.011

Economic downturn -0.053***-0.054***-0.049*** -0.048***-0.049***

Cessation of domestic slaughter -0.235***-0.110***-0.082*** -0.028 0.034

Constant 5.817***6.136*** 6.276*** 6.450***6.963***

Source: GAO analysis of horse sale price, horse characteristic, and auction-specific data from three horse auctions, and unemployment

rate data from the Department of Labor for regions where these auctions are located. Notes: The estimates in the table that are statistically significant at the 0.05, 0.01, and 0.001 percent

levels are noted by one, two, or three asterisks, respectively.

Although the sales data included 27 breeds, the primary breed types were Quarter horses, 73.9

percent of the horses; grades (low-valued horses without breed designation), 12.1 percent; and Paint

horses, 11.9 percent; with a small number of observations for breeds such as ponies, 0.57 percent;

Appaloosas, 0.45 percent; and Thoroughbreds, 0.25 percent.

aThe upper bounds for the quantiles correspond to horses priced at $600 (20th), $1,000 (40th),

$1,400 (50th or median), $1,750 (60th), and $3,000 (80th).

bIn creating categorical variables, one category must be omitted from the analysis to prevent

dependencies (where one variable is highly related to another). For instance, to create the seasonal

categorical variable, we omitted the spring auction variable from the analysis. However, the effect of

the spring auction season is represented in the regression, because the coefficient for the variable fall

auction is interpreted as relative to the reference variable (the one left out of the analysis—spring

auction). Other categorical variables in the model include horse gender, region, and breed/type.

From the table, we see that most of the regression estimates for the model

have the expected directional signs and are statistically significant. The

retransformed results, from the semi-log form back to dollar and percentage

changes, are presented for our two variables of interest—cessation of

 

domestic slaughter and economic downturn—in table 1 of this report.

 

DEPARTMENT OF AGRICULTURE LETTER TO GAO IS NOT POSTED HERE. IT CAN BE FOUND ON THE ORIGINAL GAO DOCUMENT.

 

Appendix IV: GAO Contact and Staff

Acknowledgments

Page 61 GAO-11-228 Horse Welfare

Lisa Shames (202) 512-3841 or shamesl@gao.gov

In addition to the contact named above, James R. Jones, Jr., Assistant

Director; Jim Ashley; Mark Braza; Antoinette Capaccio; Barbara El Osta;

Emily Gunn; Terrance N. Horner, Jr.; Armetha Liles; Kimberly Lloyd; Jeff

Malcolm; John Mingus; Kim Raheb; and Carol Herrnstadt Shulman made

key contributions to this report.

Appendix IV: GAO Contact and Staff

Acknowledgments

GAO Contact

Staff

 

Acknowledgments

 

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