Dear Virginia Board of Agriculture and Consumer Services,

On behalf of Animal Equality, we submit the following comment in support of the Petition for Rulemaking Pursuant to Virginia Code §2.2-4007(A): Minimum Welfare Standards for the Transport of Live Poultry for Slaughter submitted by Animal Partisan (hereinafter “Animal Partisan’s Petition”). 

Animal Equality is a 501(c)(3) non-profit organization whose mission is to create a world where animals used in agriculture are respected and protected. Our organization works toward this mission by engaging with public officials, private companies, and members of the public through investigations, campaigns, and legal advocacy. Animal Equality has supporters throughout the United States, including Virginia, and regularly engages in litigation in jurisdictions across the country. 

I.) Adopting the Regulations Laid Out in Animal Partisan’s Petition Would Help Reduce Unnecessary Suffering of Poultry During All Stages of Transport Process  

We, as an organization, strongly support Animal Partisan’s Petition, as it would create safeguards and regulations that would undoubtedly reduce the number of pre-slaughter deaths and the amount of intense suffering experienced by poultry throughout each stage of the transport process.   

As noted in Animal Partisan’s Petition, poultry are the most processed animals in the United States, yet they are the least protected. Poultry often endure unspeakable suffering during the handling process, prior to transport. Animal Partisan’s Petition notes these birds can sustain serious injuries and endure immense stress from improper handling. This improper handling has also contributed to increased dead-on-arrival rates. Additionally, Animal Partisan outlines a 2022 investigation done by Animal Outlook, where birds were abused by workers during the handling process, with one worker even ripping the head off a bird. Unfortunately, this type of brutality during handling is all too common in the industry, and guidelines and safeguards are needed to ensure they are handled with the utmost care and respect. Animal Partisan’s Proposed Rule, as laid out in its Petition, would bolster protections for poultry and reduce suffering on a vast scale during the handling stage. 

While poultry are vulnerable to pain and suffering during the handling stage, they are even more at risk during the transport stage. As Animal Partisan’s Petition notes, extreme temperatures play a key role in stress, injury, and death during the transport stage. In fact, it is estimated that more than 20 million chickens die every year while being transported in the United States, with researchers at Michigan State University noting that “these deaths are caused by a number of factors, including poor ventilation, long journeys and high temperatures . . .” Animal Partisan’s Proposed Rule, as laid out in its Petition, would effectively reduce poultry suffering and mortality rates, as the Rule would ensure that the temperature is appropriately  regulated through proper ventilation, strict temperature monitoring, and sufficient space for each bird. These Regulations are absolutely necessary to ensure that birds are not left to suffer and die from extreme temperatures during transport. 

After the birds are transported to the slaughterhouse, they are often left, sometimes for many hours, to suffer and die from extreme temperatures in the lairage stage. Animal Partisan’s Proposed Rule would effectively reduce, if not eliminate, poultry deaths in the lairage period by implementing safeguards, including proper ventilation, temperature control, and strict limits on lairage time. Again, this Proposed Rule is absolutely critical to ensure the safety and well-being of poultry. 

II.) Adopting the Regulations Laid Out in Animal Partisan’s Petition Adds Additional Safeguards to Protect Virginia Consumers from Unsafe Food Products 

Not only does Animal Partisan’s Proposed Rule create safeguards for birds, but it also protects Virginia consumers from potentially dangerous food products. As Animal Partisan notes in its Petition, physiological responses to stress in animals, as well as physical impacts that cause bruising, can completely alter meat products in unsafe ways. Current poultry transport practices significantly increase the likelihood of stress and physical impact in birds, thus putting consumers at risk of consuming unsafe meat products. Stronger regulations, like the ones suggested by Animal Partisan, could greatly reduce stress and physical impact during the transport process, thus reducing the risk of unsafe meat products reaching Virginia consumers. For their safety, Animal Partisan’s Proposed Rule should be adopted. 

III.) Conclusion 

To conclude, Animal Equality strongly supports Animal Partisan’s Petition and asks that the Board adopt the regulations set forth in the Petition. These regulations are critical to ensure that poultry are protected from unnecessary suffering and that Virginia’s consumers are safeguarded from potentially dangerous food products. We thank you for your time and consideration.  

Best Regards, 

Animal Equality