A Brilliant, Indecent Proposal to the Broker and Placement Programs

We've asserted on many occasions that the horses being sold by the broker and placement programs are unlikely candidates for the slaughterhouse and that the brokers are buying resale horses to supplement both their income and their partner's incomes.

The broker's partners have all screamed foul.  Of course these horses are slaughter bound, they say.

Well, finally, someone stood up and asked the right question.  She posted a comment to one of the "program" pages.  It, of course, went unanswered.

The paperwork that must accompany these horses to slaughter, do each of these horses that are for sale here, have that paperwork. Perhaps for those of us with some doubt, you could get a photograph of that paperwork when you are there photographing the horses. I for one know that I'd be more apt to take a horse from one of these programs if I knew for sure they were really shipping tomorrow.....and so would many others who doubt the reality that these actually horses are getting shipped. At least they are not all lame, grey, pregnant, blind. etc.....

What a fantastic idea!  If these horses really are going to slaughter, they need to have an accompanying form from the owner, confirming they are the owner, asking if the horse has had any drugs or vaccines in the past 180 days, been diagnosed with any illnesses, and if the horse has been given any substances prohibited from use in food processing.

For Canada bound horses there is the owner declaration: "As the owner of the animal identified on this document I hereby certify that the information in this EID is accurate and complete.  I understand that, effective July 31, 2010 at least six months of documented acceptable history is required for an equine presented for processing in an establishemnt inspected by CFIA."  The Mexican form is similar - same questions - and ends with a statement "I declare as the owner or the owner's agent the information provided in this form and the attached documents to be correct and given in good faith."

Both forms require name, signature, and date.  (included below are links to all the forms).

So, Programs and Placements, Show Us The Paperwork!  You've got time to travel to your broker partners place of business, video tape and photograph, it shouldn't take but a moment more to photograph the EID so that your donators and supporters know that these horses really do have paperwork that permit them to be sent to slaughter.  We won't mention at this moment that two veterinarians still have to sign off on the horse before it can be shipped, we just want to see the paperwork and know it really, really exists.  And of course you can redact the owner's name so they don't receive any nastygrams.  (redact: to obscure or remove (text) from a document prior to publication or release.)

Show Us The Paperwork!


EID forms:

This one must be filled out for a horse going to slaughter in Canada:


This one must be filled out for a horse going to slaughter in Mexico:


Here are detailed instructions on filling out the forms.  Must be in BLUE ink!


Further confirmation for the doubting Thomases of the world:



Adulterated Meat and Inadequate Horse Care Results in a Slap on The Wrist

For many, this letter from July 12, 2012 to  Ron Andio will be old news:


If you don't feel like clicking, here is the meat of the letter (sadly, pun intended):

Dear Mr. Andio: 

On April 03, 05, and 30, 2012, the U.S. Food and Drug Administration (FDA) conducted an investigation of your livestock operation located at 4445 South Turner Road, Canfield, Ohio 44406. This letter notifies you of the violations of the Federal Food, Drug, and Cosmetic Act (the FD&C Act) that we found during our investigation of your operation. You can find the FD&C Act and its associated regulations on the Internet through links on FDA’s web page at www.fda.gov

We found that you offered for sale an animal for slaughter as food that was adulterated. Under section 402(a)(2)(C)(ii) of the FD&C Act, 21 U.S.C. 342(a)(2)(C)(ii), a food is deemed to be adulterated if it bears or contains a new animal drug that is unsafe under section 512 of the FD&C Act, 21 U.S.C. 360b. Further, under section 402(a)(4) of the FD&C Act, 21 U.S.C. 342(a)(4), a food is deemed to be adulterated if it has been held under insanitary conditions whereby it may have been rendered injurious to health.

Specifically, our investigation revealed that on or about August 20, 2011, you sold a bay thoroughbred gelding horse, identified with back tag (b)(4) (USDA Tag (b)(4)) for slaughter as food. On or about August 23, 2011, (b)(4) slaughtered this animal. The Canadian Food Inspection Agency (CFIA) analysis of tissue samples collected from this animal identified the presence of phenylbutazone at 0.0025 parts per million (ppm) in the muscle tissue and 0.026 ppm in the kidney tissue and clenbuterol at 0.0039 ppm in the eye (target tissue). FDA has not established a tolerance for residues of phenylbutazone and clenbuterol in the edible tissues of horses. The presence of these drugs in edible tissues from this animal in these amounts causes the food to be adulterated within the meaning of section 402(a)(2)(C)(ii) of the Act, 21 U.S.C. § 342(a)(2)(C)(ii).

Our investigation also found that you hold animals under conditions that are so inadequate that medicated animals bearing potentially harmful drug residues are likely to enter the food supply. For example, you failed to inquire about the medication status of animals purchased for slaughter. Food from animals held under such conditions is adulterated within the meaning of section 402(a)(4) of the FD&C Act, 21 U.S.C. 342(a)(4).

The violations listed above are not intended to an all-inclusive list. It is your responsibility to assure that your operations are in compliance with the law. As a dealer of animals, you are frequently the individual who introduces or offers for introduction into interstate commerce, the adulterated animals.  As such, you share responsibility for violating the Federal Food, Drug and Cosmetic Act.  To avoid future illegal residue violations you should take precautions such as:

1. Implementing a system to determine from the source of the animals whether the animals has been medicated and with what drug(s); and

2. If the animal has been medicated, implementing a system to withhold the animal from slaughter for an appropriate period of time to deplete potentially hazardous residues of drugs from edible tissue.  If you do not want to hold the medicated animal then it should not be offered for human food, and it should be clearly identified and sold as a medicated animal.

You should take prompt action to correct the violations described in this letter and to establish procedures to ensure that these violations do not recur. Failure to do so may result in regulatory action without further notice such as seizure and/or injunction. 

We also note that the slaughterhouse has on file an Equine Information Document (EID) certificate (or guarantee) dated August 23, 2011 from the producer stating that this animal that you sold had not been administered any drugs or vaccines or treated with any substances not permitted for use in food processing equine in the last 180 days prior to your purchase of this animal. During our inspection of your firm, you admitted that you filled out and signed the producer’s name to this form and did not inquire of the producer the medication status of this animal. You provided this EID to the dealer who purchased this animal from you. Providing such a false guaranty is prohibited by section 301(h) of the FD&C Act, 21 U.S.C. 331(h). You should take appropriate actions to ensure that this violation does not recur. 

You should notify this office in writing of the steps you have taken to bring your firm into compliance with the law within fifteen (15) working days of receiving this letter. Your response should include each step that has been taken or will be taken to correct the violations and prevent their recurrence.  If corrective action cannot be completed within fifteen (15) working days of receiving this letter, state the reason for the delay and the time frame within which the corrections will be completed.  Please include copies of any available documentation demonstrating that corrections have been made.

In summary, on 3 different days in April of 2012, the FDA conducted inspections of Andio's farm and found violations.  The inspection was apparently a result of the CFIA (Canadian Food Inspection Agency) testing a horse Andio sent to slaughter in Canada in April of 2011 (yes, 2011) and finding Bute in its system.  Bute is an illegal drug to administer to any animal entering the human food chain.

The FDA went on to say "their investigation found that you hold animals under conditions that are so inadequate that medicated animals bearing potentially harmful drug residues are likely to enter the food supply."

And continued with:

"During our inspection of your firm, you admitted that you filled out and signed the producer’s name to this form and did not inquire of the producer the medication status of this animal. You provided this EID to the dealer who purchased this animal from you."

According to this letter, Mr. Andio not only supplied toxic horse meat to Canada, but admitted to falsifying documents to state otherwise, forging the signature of the individual or firm he got the horse from, and supplying these falsified documents to the dealer who bought the horses from him and took them to slaughter.

We don't know exactly what the statement about inadequate conditions means.  It certainly doesn't bode well for the animals in his possession.

What is perhaps most appalling is that the FDA slaps him on the wrist and asks for a letter stating how compliance will be done in the future.  Other questions abound.  Why did it take a year for the letter to be sent to Andio?  Why is he still allowed to ship horses when the CFIA has a zero tolerance policy for Bute?

The CFIA only randomly tests meat products.  ( http://www.inspection.gc.ca/food/information-for-consumers/fact-sheets/specific-products-and-risks/meat-and-poultry-products/horse-meat/eng/1331217628360/1331225704619 )  There is no way of knowing how much toxic meat is entering the system, but based on what we know about the percentage of American horses who have received Bute, it's easy to guess that it's a very, very significant amount.

Consumers in both the European Union and elsewhere should be scared, very, very scared to consume anything that may contain American horse meat.  The article below cites a number of terrifying side effects:


"Published in Food and Chemical Toxicology, the research study states that the health hazards associated with bute in horse meat aren’t dose related.

According to the study, bute causes bone-marrow depression like aplastic anemia, agranulocytosis, thrombocytopenia, leucopenia, pancytopenia, and hemolytic anemia, which are fatal in the vast majority of cases. The elderly are more susceptible than younger adults. The risks for developing bone-marrow depression and other serious effects are heightened because humans metabolize bute into oxyphenbutazone, which also causes bone-marrow depression.

The study also demonstrates that children are at increased risk of developing aplastic anemia from minute levels of bute and oxyphenbutazone in horse meat, presumably because their bones are still growing. But even very low levels of bute can result in a hypersensitivity reaction in susceptible adults that’s mostly fatal. All of these effects are considered to be idiosyncratic, meaning it is unknown who will be afflicted.

The National Toxicology Program showed that bute is a carcinogen. In fact, bute can cause chromosomal alterations that lead to cancers like leukemia in humans.

In amounts lower than those that cause bone-marrow depression, bute can also result in a serum sickness–like illness resulting in “fever, fatigue, malaise, and inflammation of the kidney, swollen glands and an enlarged spleen. A person can end up on dialysis for the rest of their life,” the authors of the peer-reviewed research study wrote in a follow-up letter to the editor.

Because bute was taken off the market for human use more than a decade ago due to its side effects, no long-term studies have been or will be conducted. No safe levels were set by food-safety regulators. Therefore, the drug was banned for all animals intended for human consumption, and there is no withdrawal time."

Part of the takeaway message here is that horse dealers can easily pass horses with drug histories into the food chain, and that the "system" in place to protect consumers is lax at best.  The dealers don't care what they are shipping; they just want their cash.  And the government agencies appear to be largely asleep at the wheel.


Explaining Just How "The Truck is Coming!"

First we need to thank the individuals employed by the USDA who took the time to walk us through the process and answer our questions. We will talk with them again and they remain concerned, as do other federal agencies, about the potential for abuse of the shipping system by all individuals contributing to it.

This information was readily found on the USDA-APHIS website concerning shipping of horses to slaughter by Brian Moore in 2010:

Almost without change it is 30 head of horses being shipped.  Only on 4/22 were 21 horses shipped.

No grays or ponies shipped to slaughter according to these federal forms.  Few horses over the age of 18 are documented.

The data is from 1/11/2010 through 8/2/2010.  38 loads are documented.

Of the 1131 horses documented, 31 were stallions.  That equates to 3%.

On 3/8, of the 30 horses nearly all of them were listed as bays, and most were mares (22).  There were also 7 geldings and one stallion.  Race horses, perhaps?

According to the USDA, the way the process works is the kill buyer acquires horses for meat and creates a load.  Then a USDA Accredited Veterinarian examines the load and signs off on the VS 17 140 form.  The vet must go through an accreditation process which is renewed every three years and involves continuing education credits.  The USDA Accredited Vet is not compensated by the USDA.  One would logically assume however, that a veterinarian would not go through this process unless he/she was getting paid, so we’ll figure the kill buyer is charged for this inspection.

After the VS 17 140 is issued and signed by the accredited vet – in this case Dr. James Holt for all 38 loads – the original form must be inspected by a USDA compensated AVIC veterinarian.  Again, according to one of our contacts at the USDA there is an AVIC area office in nearly every state.  There is one located in the capital city of Harrisburg, Pennsylvania which is approximately 45 minutes from New Holland or Jonestown, where Moore’s farm is located.  Note the original form must be stamped and signed, so it cannot be faxed or emailed.

There are field vets for the USDA, as was explained to us, that often sign off on and stamp the VS 17 140 form in order for the kill buyer to have their documentation in place to ship the load of horses to slaughter without visiting an AVIC office.  The kill buyers have 30 days from the endorsement date to ship the horses.

We were also told by the USDA that a “contract” between a slaughter house and kill buyer can be as simple as a handshake or may actually exist as a formal contract.  One individual told us he spent years at the Cavel plant in Illinois supervising the off loading of slaughter horses.  He inspected 800-1500 horses per week, and only ever saw one mini come through.  The mini was rejected and not slaughtered. 

In every example shown Dr. Holt issues the 17 140 one day and the USDA Vet stamps and signs the form the following day.  This belies the story that horses loaded Monday night at New Holland are shipped overnight to Canada, at least during the time period that these documents were issued.

Keep in mind the kill buyer fills out the form VS 10-13 which includes the USFA hip tag number.  You often see horses in the broker programs with these tags on them.  This is not a sure indication that the horse is going to ship to slaughter.  The horse may have been tagged but rejected by one of the veterinarians and the tag simply wasn’t removed.  Additionally, if horses are bought at auction in NY or another state, tagged and brought back to PA as meat horses, the buyer eludes having to get a negative coggins test on those horses, saving him a significant amount of money.  Lastly, those USDA hip tags might just be used as a marketing ploy.

We are fortunate to have the Freedom Of Information Act to request information like this.  If the same information is requested by more than one individual it is required to be placed on the federal agency’s website: “The FOIA also requires that agencies automatically disclose certain information, including frequently requested records.”  Clearly that is what occurred with this request, since it was found on the APHIS website. 

We are also thankful that the FBI, USDA and PSP (Pennsylvania State Police) are monitoring this ongoing situation with brokers and broker programs.  Government cannot legislate a moral compass, but they can regulate and enforce laws being broken by those dancing too close too the edge.

We will leave you with the faces of those that were lost; the ones that could not be saved.  Most of these pictures come from Washington State and Montana.  Heartwrenching, as you note how fat and healthy they are.  Rest in Peace, Dear Ones.  May you not have died in vain.


More Horses That Were Very Likely Not Going to Ship To Slaughter

Stallions are an issue.  According to APHIS they need to be treated differently:

  • Separate stallions and other aggressive horses from the rest of the shipment.
http://www.aphis.usda.gov/animal_health/animal_dis_spec/horses/horse_transport.shtml )

Factor in the fact that he's only 15 hands and quite thin as well, and you've got a prime candidate for a broker program.  Grimly, if butchered this horse would not yield a lot of meat.  Sorry, but that's the painful, brutal reality.

Then there's this tiny, skinny mini.  Pulled from the kill pen, not.  But the dealer was smart enough to buy her knowing someone would buy the story.

We're happy these horses are out of the auction pipeline (at least for now) but come on, rescue horses that are really in danger of shipping, please!