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Full Title Name: Detailed Discussion of Concentrated Animal Feeding Operations: Concerns and Current Legislation Affecting Animal Welfare
Elizabeth Overcash Place of Publication: Michigan State University College of Law Publish Year: 2011 Primary Citation: Animal Legal & Historical Center 1 Country of Origin: United States
This discussion of CAFOs and animal welfare measures introduces CAFOs and the agricultural industry. It then examines the animal welfare, environmental, and human health concerns that have arisen with CAFOs. Finally, the article notes the legislation and ballot initiatives that have been enacted to address these concerns.
American agriculture has changed dramatically over the past century. Agriculture traditionally consisted of many small farms, with twenty-four percent of Americans employed in agriculture before World War II. [ 1 ] Now, however, farming is handled by only a handful of companies, with only 1.5 percent of Americans currently employed in agriculture. [ 2 ] "Four companies now produce 81 percent of cows brought to market, 73 percent of sheep, half our chickens, and some 60 percent of hogs." [ 3 ] This change in the manner of farming has brought about many animal welfare, as well as environmental and human health, concerns. In turn, these concerns have created a push for new legislation to address these issues.
This Paper addresses the animal welfare issues and legislation associated with the current agricultural industry and its use of Concentrated Animal Feeding Operations, or CAFOs. This Paper proceeds in three parts. Part I provides a detailed explanation of CAFOs, discussing the definition of CAFO, the conditions present on CAFOs, and the locations of CAFOs. Part II delves into some of the common concerns arising out of CAFOs, focusing on animal welfare, but also taking a moment to note the environmental degradation and human health issues associated with CAFOs. Finally, Part III describes current and pending legislature concerning animal welfare on CAFOs.
II. What Is a CAFO?
Commonly referred to as "factory farms," [ 4 ] Concentrated Animal Feeding Operations, or CAFOs, are animal producing operations that have become a common part of today's agricultural industry, providing most of the food animals that Americans eat. [ 5 ] Although particularly popular in the United States, CAFOs are present worldwide, [ 6 ] providing a more automated form of agricultural production that allows for an increased meat yield. [ 7 ]
A. Definition of CAFO
According to the United States Environmental Protection Agency, or EPA, a CAFO is a form of AFO, or Animal Feeding Operation, defined as an: " agricultural operation[] where animals are kept and raised in confined situations. AFOs congregate animals, feed, manure and urine, dead animals, and production operations on a small land area. Feed is brought to the animals rather than the animals grazing or otherwise seeking feed in pastures, fields, or on rangeland." [ 8 ] More specifically, an agricultural operation qualifies as an AFO if the animals included in the operation are confined for at least forty-five days in a twelve-month period, and if there is " no grass or other vegetation in the confinement area during the normal growing season." [ 9 ]
Approximately fifteen percent of AFOs are CAFOs for EPA regulatory purposes. [ 10 ] To meet the definition of a CAFO, an AFO must meet one of EPA's definitions of Large CAFOs, Medium CAFOs, or Small CAFOs. [ 11 ] First, a Large CAFO must contain a certain number of animals, as seen in the table below.
Next, an AFO may be designated as a Medium CAFO in two ways. First, the AFO must contain a designated amount of animals, as seen in the table below. In addition to containing one of these quantities of animals, for an AFO to be a Medium CAFO, it must also either have "a manmade ditch or pipe that carries manure or wastewater to surface water," or have "the animals come into contact with surface water that passes through the area where they're confined." [ 12 ] Second, an AFO may be designated a CAFO if it is found to be a significant contributor of pollutants. [ 13 ]
Finally, an AFO may be designated as a Small CAFO if the operation contains fewer animals than a Medium CAFO, and if the operation is found to be a significant contributor of pollutants. [ 14 ] Small CAFOs are designated on a case-by-case basis. [ 15 ]
Regulatory Definitions of Large CAFOs, Medium CAFO, and Small CAFOs [ 16 ]
Animal Sector
Size Thresholds (number of animals)
Large CAFOs
Medium CAFOs [ 17 ]
Small CAFOs [ 18 ]
cattle or cow/calf pairs
1,000 or more
mature dairy cattle
veal calves
swine (weighing over 55 pounds)
750 – 2,499
swine (weighing less than 55 pounds)
10,000 or more
less than 3,000
sheep or lambs
16,500 – 54,999
laying hens or broilers (liquid manure handling systems)
chickens other than laying hens (other than a liquid manure handling systems)
125,000 or more
37,500 – 124,999
laying hens (other than a liquid manure handling systems)
ducks (other than a liquid manure handling systems)
ducks (liquid manure handling systems)
B. Conditions on CAFOs
CAFOs reflect an American trend toward greater confinement of livestock. [ 19 ] In contrast to the traditional, pre-World War II farm, where animals would typically graze in pastures, CAFOs confine animals to pens and cages, feeding them in masses in feedlots. [ 20 ] The main attributes of CAFOs, in terms of animal living conditions, are confinement and crowdedness.
Battery chickens, or egg-laying chickens, spend their entire lives in a "battery cage," which is a wire cage generally twelve inches by eighteen inches, holding up to six chickens. [ 21 ] "The cages are stacked on top of each other in a layer house that may hold over 80,000 birds." [ 22 ] Broiler chickens, or chickens raised for meat, are raised and live with as many as 40,000 other birds in litter on the floor of a warehouse. [ 23 ] The warehouse has no windows and no cooling, and the air is heavily filled with ammonia. [ 24 ]
Hogs live in similarly crowded conditions. [ 25 ] Sows, used for reproduction, are kept either loose or chained at the neck in individual pens that may be too small for the sow to turn around or walk. [ 26 ] Sows are put in "farrowing" (or "birthing") pens when ready to give birth, which provides room for "almost zero movement." [ 27 ] Sows are generally confined ten months of each year, or, if artificial insemination is used, they are continuously so confined throughout their lives. [ 28 ]
Cattle raised for dairy, similarly, often live indoors in individual pens, having "only enough room to stand up and lie down." [ 29 ] Cattle raised for beef are either raised in crowded, outdoor feedlots or indoor pens. [ 30 ] Calves raised for veal are chained down as newborns in narrow stalls in which they may not be able to stand up, turn around, or lie flatly. [ 31 ] In order to achieve a certain tenderness of the flesh, veal calves are fed a liquid diet of milk powder and vitamins, receiving no water or straw for bedding in order to preserve their tenderness. [ 32 ] Veal calves are often kept in the dark twenty-two hours or more each day. [ 33 ]
While there are other animals raised on CAFOs, chickens, pigs, and cattle are the most common. In 2009, there were 8.6 billion chickens, 113 million pigs, and over 34 million cattle, including 944,000 calves, killed for agricultural purposes. [ 34 ]
C. Locations of CAFOs
CAFOs are present in abundance throughout the United States. [ 35 ] The states with some of the greatest quantities of CAFO-derived animals are Iowa, California, Georgia, North Carolina, Minnesota, Illinois, Wisconsin, Pennsylvania, and New York. [ 36 ] Iowa produces the most CAFO hogs as compared to any other state, followed by North Carolina, Minnesota, and Illinois. [ 37 ] Iowa also has the most egg-laying hens, beating out California in fourth, Pennsylvania in fifth, and Minnesota in ninth, as well as the fourth most cattle feedlots, ahead of California with the sixth most. [ 38 ] California has the most dairy production of any state, while Wisconsin has the fifth most and New York has the sixth most. [ 39 ] Georgia has the most broiler chickens, ahead of North Carolina with the sixth most broiler chickens, and California with the seventh most. [ 40 ]
It is worth noting that in some states, such as North Carolina and Mississippi, CAFOs tend to be located in poor and African American communities. [ 41 ] For example, in North Carolina, there are 7.2 times as many swine CAFOs located within the areas of highest poverty as compared with the areas of lowest poverty, as well as around five times as many swine CAFOs in areas with the highest percentage of nonwhite population as compared to areas with the lowest percentage of nonwhite population. [ 42 ] The proximity of these CAFOs to already disadvantaged communities can lead to "inequitable health and socioeconomic burdens" for the populations in these communities. [ 43 ]
III. Concerns Arising out of CAFOs
A. Animal Concerns
Animal welfare concerns often arise from the treatment of animals housed on CAFOs. As farming has become more of a large-scale, indoor operation, agricultural animals have become closely-confined commodities given little to no individual attention. As one writer put it: "Genetically designed by machines, inseminated by machines, fed by machines, monitored, herded, electrocuted, stabbed, cleaned, cut, and packed by machines—themselves treated like machines 'from birth to bacon'—these creatures, when eaten, have hardly ever been touched by human hands." [ 44 ]
The close confinement and crowded conditions create at least two main problems. First, the conditions create both physical and mental ills for the animals. Chickens, pigs, and cattle all suffer from boredom. [ 45 ] Pigs are especially sensitive to the situation, and many die from the stress-related "porcine stress syndrome," while others develop neurotic behaviors, such as self-mutilation. [ 46 ] Cows are also particularly affected by the stress of the confinement, manifesting psychological and physiological disturbances. [ 47 ]
Stress is not the only illness that the animals suffer, however. For example, due to the heavily ammonia-filled litter in which chickens live, they suffer "ulcerated feet, breast blisters, and hock burns," [ 48 ] as well as feather-loss, blisters, tumors, foot and leg deformities, and osteoporosis. [ 49 ] Chickens also suffer crippling leg disorders, lung and heart disease, and sudden death syndrome as a result of their unnaturally quick growth. [ 50 ] Pigs similarly suffer from their ammonia-filled living quarters, and they additionally endure foot and leg damage from the slated or concrete floors on which they live. [ 51 ] Additionally, about half of all dairy cows develop a bacterial infection, mastitis, and veal calves, being anemic, develop digestive disorders such as stomach ulcers and chronic diarrhea. [ 52 ]
The second main problem is that the confinement prevents the animals from performing their natural behaviors, causing stress and even aggressive behavior by the animals. [ 53 ] This aggressive behavior, in turn, has led to CAFO workers now conducting painful procedures on the animals. Chickens are de-beaked to prevent pecking, which involves a hot blade cutting through a bird's beak, bone, and a "highly sensitive soft tissue, resembling the 'quick' of the human nail." [ 54 ] To discourage fighting, chickens may also have their toes removed. [ 55 ] Similarly painful, pigs and cows generally have their tails docked to prevent tail biting. [ 56 ]
These conditions, just to name a few, tend to raise concerns about the confinement and treatment of animals raised on CAFOs. As seen in Part III of this Paper, legislation concerning CAFOs addresses several of these issues of treatment, showing a public concern with some of these issues.
B. Environmental and Human Health Concerns
While this Paper addresses only the legislation affecting animal welfare on CAFOs, it will take a brief moment to note the environmental and human health concerns associated with CAFOs. The issue of environmental degradation that CAFOs present is due to the extreme amount of waste that CAFOs generate. According to the EPA, agriculture is "the leading contributor to water quality impairments in the Nation's rivers and lakes, and the fifth leading contributor to water quality impairments in the Nation's estuaries." [ 57 ] Twenty-two states reported on the impacts of agriculture on water quality, reporting that intensive animal operations account for twenty percent of the agricultural damage to rivers and streams. [ 58 ]
The primary source of pollution from CAFOs is animal manure. [ 59 ] Although a natural fertilizer, manure from CAFOs is generated in such quantities that surrounding fields cannot absorb it all, creating soil, water, and even air pollution. [ 60 ] The manure, when introduced into water, can result in fish kills, reduced biodiversity, and contaminated drinking water, among many other effects. [ 61 ] Nitrate from manure, if it enters drinking water, can be potentially fatal to infants. [ 62 ] "EPA found that nitrate is the most widespread agricultural contaminant in drinking water wells, and estimates that 4.5 million people are exposed to elevated nitrate levels from drinking water wells." [ 63 ] Additionally, when introduced into soil, manure can be toxic to plants. [ 64 ]
Odors from CAFOs can cause both environmental and human health concerns. Methane emissions from waste lagoons pollute the environment by contributing to global warming. [ 65 ] The United Nation's Food and Agriculture Organization's 2006 report estimated that eighteen percent of all greenhouse gas emissions are from livestock. [ 66 ] "The United States estimates that all of U.S. agriculture accounts for approximately 7% of total national emissions." [ 67 ]
The odors can cause both physical and mental health impacts in humans. [ 68 ] "[R]espiratory problems prevalent among CAFO works—bronchitis, hyper-reactive airway disease, occupational asthma, and hydrogen sulfide intoxication—are more likely found in populations living within two miles of large CAFOs than populations not located near CAFOs." [ 69 ]
Antibiotic resistance is also a human health concern. "The Center for Disease Control and Prevention (CDC) estimates that 60,000 Americans die each year from antibiotic resistant disease." [ 70 ] Inappropriate use and overuse of antibiotics is thought to be a main cause of antibiotic resistance, and much of this use results from agriculture. Nearly eighty percent of antibiotics used in America are estimated to be used for non-therapeutic purposes in livestock production, such as giving animals low levels of antibiotics to prevent disease, in an effort to compensate for the overcrowded and unsanitary CAFO conditions. [ 71 ]
Finally, the meat produced on CAFOs may itself be a human health concern. "Diets high in red and processed meat have been found to be associated with greater mortality from cardiovascular disease and cancer," as well as with higher rates of Type 2 Diabetes. [ 72 ] Animals, such as those in CAFOs, which are fed a grain diet, rather than a natural grass diet, may have higher levels of total fat, cholesterol, calories, and saturated fat, which may increase cholesterol levels and risk of heart disease or stroke. [ 73 ]
The confinement conditions at these CAFOs not only give rise to environmental and human health concerns, but also raise inherent animal welfare issues. While the response to these concerns has not kept pace with the increase in CAFOs, legislation concerning CAFOs has provided some slight advancements in animal welfare.
IV. Legislation Regarding CAFOs
I n a response to the animal welfare concerns presented by CAFOs, new legislation has been appearing within most states to address these concerns. CAFOs are generally an issue of state law. The United States Department of Agriculture (USDA) does not have authority to regulate animal treatment in state CAFOs. [ 74 ] Further, only two federal laws even touch on agricultural animal welfare at all: the Humane Slaughter Act [ 75 ] and the Twenty-Eight Hour Law . [ 76 ] Neither law provides legitimate protection to animals on CAFOs. As a result, states, through both ballot initiatives and legislation, have begun to enact measures directed at the welfare of confined farm animals.
A. Federal Laws
The Humane Slaughter Act provides that "no method of slaughtering or handling in connection with slaughtering shall be deemed to comply with the public policy of the United States unless it is humane," [ 77 ] which means that "before being shackled, hoisted, thrown, cast, or cut," all "cattle, calves, horses, mules, sheep, swine, and other livestock . . . [must be] rendered insensible to pain by a single blow or gunshot or an electrical, chemical or other means that is rapid and effective." [ 78 ] However, the Act only applies to livestock, not poultry, [ 79 ] thus exempting ninety-two percent of animals killed on CAFOs. [ 80 ]
The Twenty-Eight Hour Law provides that animals may not be held without food or water for more than twenty-eight hours. [ 81 ] However, an extension to thirty-six hours is granted upon a simple request, sheep may be confined for forty-eight hours, [ 82 ] and the Law only applies to transportation by railcar, [ 83 ] thus exempting the majority of animals, as most animals are transported by truck. [ 84 ] The European Union, based upon research by the European Commission, states that fourteen hours is the maximum amount of time that may be considered "humane." [ 85 ]
With the lack of federal protection, states, as well as individuals, have taken CAFO regulation into their own hands through state legislation and ballot initiatives.
B. State Animal Welfare Measures
Both ballot initiatives and legislation have been enacted within many states to focus on the area of animal welfare on CAFOs. The greatest animal welfare concern, which is reflected in legislation and ballot initiatives concerning CAFOs, is the confinement of the animals. Other concerns include the treatment of nonambulatory animals, humane slaughter methods, the force-feeding of birds, and tail docking. These issues are thus the subject of state legislation within several of the states.
Although states began passing humane slaughter laws as early as 1956, even by 2006 only twenty-one states had enacted such laws. [ 86 ] Real change in animal welfare on CAFOs did not come until 2002, when Florida passed a ballot proposal, the Animal Cruelty Amendment: Limiting Cruel and Inhumane Confinement of Pigs during Pregnancy , requiring that pregnant sows be able to turn around freely in their enclosures. [ 87 ] Animal activist groups led the initial push for this ballot proposal, [ 88 ] and, after this success, more ballot proposals were raised in other states, countered by relatively conservative animal welfare legislation supported by the agricultural industry. [ 89 ]
New animal welfare legislation, in contrast to ballot proposals, has not always provided true advancements for animals on CAFOs. For example, in 1996, the New Jersey legislature passed Senate Bill 713: An Act Concerning Domestic Livestock and Animal Cruelty and Welfare Laws. [ 90 ] This bill enacted a new section of the state's existing statute regulating animal cruelty, [ 91 ] amending the New Jersey Statutes sections 4:22-16 and 4:22-16.1. [ 92 ] Until the enactment of Senate Bill 713, animal welfare and the protection of animals had been left to the discretion of the New Jersey Society for the Prevention of Cruelty to Animals (NJSPCA) and its related county organizations. [ 93 ] The bill directed the New Jersey Department of Agriculture (NJDA) to "create and promulgate regulations that would set standards governing the raising, keeping, and marketing of domestic livestock," or farm animals. [ 94 ] The "guiding principle to be utilized in establishing those standards was to be whether the treatment of these animals was 'humane.'" [ 95 ]
The NJDA regulations were ultimately challenged by NJSPCA and other interest organizations in N.J. Society for the Prevention of Cruelty to Animals v. N.J. Department of Agriculture . The issue in the case was whether the regulations promulgated by the NJDA pursuant to this authority were invalid for failing to comply with the "humane" standards requirement. [ 96 ] Although the court held that the regulations in their entirety were not invalid, [ 97 ] the court found that NJDA acted arbitrarily and capriciously in enacting its regulations by allowing all "routine husbandry practices," as there was no evidence that those practices were "humane." [ 98 ] The court further rejected NJDA regulations allowing cattle tail docking, finding no evidence to support that the practices were "humane." [ 99 ] Finally, the court rejected the assertion of NJDA that certain controversial farm practices, such as castration, de-beaking, and toe-trimming, are "humane" if they are performed by a "knowledgeable individual" "in a way to minimize pain." [ 100 ] Thus, this piece of legislation, which upon a prima facie look appeared to provide "humane" regulations for animals on CAFOs, was in fact implemented in such a way as to allow the agricultural industry to set the standards for regulations themselves.
To understand CAFO legislation, one must have a fair understanding of ballot initiatives. Ballot initiatives are the most effective way in which CAFO regulation is achieved. Ballot initiatives are proposals for new law that are placed directly on the voter ballot by a process of petition, or, in other words, by collecting a certain number of citizens' signatures. [ 101 ] Only twenty-four states allow the ballot initiative process. [ 102 ] This process can be helpful in achieving animal welfare legislation because, rather than going through the state legislature, the proposed laws are put on the ballot by the people and directly voted on by the people, [ 103 ] thus bypassing political constraints that might otherwise hinder legislative progress on these issues. Further, these initiatives have tended to spur legislation because agribusiness leaders attempt to preempt the more progressive ballot initiatives by encouraging legislatures to enact more conservative animal legislation before the ballot initiatives ever come to vote. [ 104 ]
To better understand ballot initiatives, one may compare them to similar issues being addressed through legislation. For example, recently, Washington citizens were attempting to get a ballot initiative, Initiative 1130 , on the November 2011 ballot, which would have prevented the stacking of egg-laying hen cages and would have required that egg-laying hens be confined in ways that allow them to lie down, stand up, fully extend their wings, and turn around freely. [ 105 ] This initiative was dropped, however, after the Humane Society of the United States (HSUS) entered a national agreement with the egg industry on July 7, 2011. [ 106 ]
Comparing Washington proposed Initiative 1130 with a similar Washington piece of legislation, Senate Bill 5487 , [ 107 ] provides a solid foundation for understanding how ballot initiatives differ from legislation. Senate Bill 5487 does not require full compliance with the new standards for egg-laying hen confinement until 2026, whereas Initiative 1130 requires its conditions be met by 2018. [ 108 ] Further, Initiative 1130 requires enough space to where each hen may fully extend her wings, where as Senate Bill 5487 does not require that a hen be able to spread her wings. [ 109 ] The supporters of each are also worth noting. Senate Bill 5487 was supported by the state and national agribusiness industry, including by battery cage egg producers, whereas the supporters of Initiative 1130 were almost all of the Washington state animal welfare organizations, as well as many major national animal welfare organizations, such as the HSUS and Farm Sanctuary. [ 110 ]
Thus, at least in this instance, the ballot initiative appears to be a good bit more progressive in terms of animal welfare than does the senate bill, which is reflected in the organizations that support each proposal. As most ballot initiatives concerning CAFOs focus on confinement standards for animals, ballot initiatives will be better addressed in the next section.
C. Subject Matter of CAFO Measures
Legislation concerning the animal welfare aspects of CAFOs may be divided into several different categories that tend to appear across the states. These categories are: confinement standards for CAFO animals, treatment standards for nonambulatory animals, humane slaughter laws, and miscellaneous protection laws concerning topics such as force-feeding and tail docking.
1. Confinement
Legislation concerning confinement is one of the most common types of CAFO legislation. Considering the issue of crowdedness on CAFOs, this is not surprising. What might be surprising, however, is that confinement legislation tends to legislate for specific animals on CAFOs, not for every animal on a CAFO. These laws generally focus on two groups of animals: one, pigs during pregnancy and calves raised for veal, and two, egg-laying hens. Of the several states that have adopted these measures, the statutes are almost entirely the same, generally granting veal calves and gestating sows the freedom of movement to lie down, stand up, and turn around without touching their enclosures.
Ballot initiatives are crucial to understanding confinement legislation. In 2002, Florida passed a ballot proposal, the Animal Cruelty Amendment: Limiting Cruel and Inhumane Confinement of Pigs during Pregnancy , which requires that pregnant sows be able to turn around freely in their enclosures. [ 111 ] This was the first time in American history that a farming practice was banned solely on account of its inherent cruelty, and 2.5 million Floridians voted for this change. [ 112 ] "Before the vote, Florida's legislature had ignored proposed legislation to ban the gestation crate, one of factory farming's worst forms of intensive confinement;" thus, the onus fell on animal advocates to act. [ 113 ] The Animal Rights Foundation of Florida led the campaign for the ballot initiative along with HSUS, The Fund for Animals, and Farm Sanctuary. [ 114 ]
After this success, HSUS, Arizona Humane Society, Animal Defense League of Arizona, and Farm Sanctuary led another effort to pass Proposition 204 in Arizona. [ 115 ] Proposition 204 : Relating to Cruel and Inhumane Confinement of Animals passed in 2006. [ 116 ] This proposition, which added section 13-2910.07 of title 13, chapter 29, of the Arizona Revised Statutes, provides that:
[A] person shall not tether or confine any pig during pregnancy or any calf raised for veal, on a farm, for all or the majority of any day, in any manner that prevents such animal from:
1. lying down and fully extending his or her limbs; or
2. turning around freely. [ 117 ]
Opponents of Proposition 204, including the Arizona Farm Bureau and the Center for Consumer Freedom, put $2.5 million into an unsuccessful campaign against the initiative. [ 118 ]
In 2008, Proposition 2 , a ballot initiative in California, was successfully passed by the people, and now requires that calves raised for veal, egg-laying hens, and pregnant sows only be confined in enclosures that allow them to lie down, stand up, fully extend their limbs, and turn around freely. [ 119 ] Proposition 2 obtained many supporters:
The Humane Society of the United States, the California Veterinary Medical Association, the Center for Food Safety, the ASPCA, the Consumer Federation of America, the Center for Science in the Public Interest, the United Farm Workers, Farm Sanctuary, the Sierra Club, Cesar Chavez Foundation, the State Humane Association of California, Republican and Democratic elected officials, hundreds of California veterinarians, family farmers, religious leaders, and an overwhelming majority of California voters. [ 120 ]
Specifically, Proposition 2 passed with 63.5 percent of the vote. [ 121 ] Opponents included Foster Farms, the United States Poultry and Egg Association, and Land-o-Lakes. [ 122 ]
After Proposition 2's success, agribusiness leaders seemed afraid of the ballot initiative. Michigan Governor Jennifer Granholm helped avoid a costly ballot measure battle by signing legislation requiring basic movement to be allowed for egg-laying hens, breeding pigs, and veal calves. [ 123 ] HSUS described the law as "the result of good-faith negotiations between humane groups, environmental groups, and the state's agricultural industry." [ 124 ]
HSUS then "had its eye on Ohio to pass legislation to ban the use of poultry cages, veal crates and gestation stalls." [ 125 ] Big agriculture in Ohio feared an initiative like Proposition 2 would come to their state, so, in anticipation of this initiative, the Ohio Farm Bureau and other agribusiness leaders tried to preempt HSUS by talking with state legislators. [ 126 ] As a result, the House and Senate proposed Issue 2 , a voter referendum to create an Ohio Livestock Care Standards Board, which would establish a state board to set state standards for the care and well-being of livestock. [ 127 ] Since agribusiness lobbied for Issue 2 , and since the governor and legislature, led by the state agriculture director, would appoint members to the board, the board would be industry dominated. [ 128 ] Representative Michael J. Skindell, D-Lakewood, has said, "[I]t's really about agribusiness interests working with the legislature to block regulations requiring more humane treatment of animals—allowing a chicken to spread its wings in a cage, for example, or a dairy cow to lie down in the barn." [ 129 ]
Issue 2 was approved. [ 130 ] However, on January 27, 2010, the Ohio Livestock Care Initiative, a 2010 proposed constitutional amendment, was filled with the Ohio Attorney General as a countermeasure to Issue 2. [ 131 ] The initiative was supported by HSUS. [ 132 ] On June 30, HSUS agreed to drop ballot efforts in accordance with an agreement with Governor Ted Strickland and Ohio agricultural leaders that required the state to adopt several livestock regulations, including "phasing out gestation crates used by the pork industry over the next 15 years . . . ." [ 133 ]
More legislation has sprung up. In 2007, Oregon enacted Senate Bill 694 : An Act Relating to Confinement of Animals, which provides that neither a calf raised for veal nor a pig may be confined unless they can lie down, fully extend their limbs, and turn around freely. [ 134 ] The Oregon law thus differs slightly from the others in that it does not require a pig to be a pregnant sow in order to receive protection. Providing protection only to pregnant pigs, rather than all pigs, tends to be the norm, as seen in the successfully passed 2008 Colorado Senate Bill 08-201: Confinement of Calves Raised for Veal and Pregnant Calves, which provides that calves raised for veal and gestating sows must be able to stand up, lie down, and turn around without touching the sides of their enclosure. [ 135 ]
In 2009, Maine enacted Legislation Document 1021 : An Act to Prohibit Cruel Confinement of Calves Raised for Veal and Sows During Gestation, which provides that calves raised for veal and pregnant sows must be able to lie down, stand up, fully extend their limbs, and turn around freely. [ 136 ]
Also in 2009, Michigan passed House Bill 5127: Animal Industry Act, which covers not only calves raised for veal and gestating sows, but also egg-laying hens, and provides that these covered animals must be able to lie down, stand up, fully extend their limbs, and turn around freely when confined. [ 137 ] Michigan thus addresses all three of the major confinement issues in a single statute.
Finally, this most recent 2011 bill, Oregon Senate Bill 805 : Relating to Egg-Laying Hens, established standards for the confinement of egg-laying hens in Oregon, providing that:
A person commits the offense of unlawfully confining an egg-laying hen if the person is a farm owner or operator who, for the majority of any 24-hour period, confines an egg-laying hen in an enclosure, located on a farm, that:
(a) Prevents the egg-laying hen from:
(A) Lying down;
(B) Standing up;
(C) Turning around freely; or
(D) Fully extending and flapping her wings; or
(b) Is stacked or otherwise placed above or below another enclosure. [ 138 ]
2. Nonambulatory Animals
Several states have also passed legislation concerning nonambulatory animals, meaning animals that are unable to walk or stand without assistance. These laws generally prohibit buying or selling nonambulatory animals, or establish minimum care standards for nonambulatory animals, or both. For example, in 2003, Oregon passed House Bill 3339 : An Act Relating to Livestock, which prohibits the trading of nonambulatory livestock. [ 139 ] Washington also, in 2009, passed Senate Bill 5974 : An Act Relating Transporting or Accepting Delivery of Live Nonambulatory Livestock, which prohibits transporting or accepting delivery of live nonambulatory livestock. [ 140 ]
Several states, however, did not enact laws concerning downed animals until abuses concerning these animals were discovered. [ 141 ] California is a good example. On February 17, 2008, after the USDA's Food Safety and Inspection Services (FSIS) learned that a meat packing company was not always notifying FSIS about cattle that became nonambulatory after being inspected but before being slaughtered for food, the USDA announced the largest meat recall in United States' history. [ 142 ] "The matter came to light when the Humane Society of the United States (HSUS) released videotapes of what it described as employees inhumanely handling downer cattle before slaughter." [ 143 ] The meat packing company, Hallmark/Westland Meat Packing Company, recalled 143 million pounds of beef products dating as far back as February 1, 2006, about fifty million pounds of which had been distributed to the school lunch program and other federal nutrition programs in at least 45 states. [ 144 ] The USDA deemed the meat unfit for human food because nonambulatory cattle are more likely to have bovine spongiform encephalopathy (BSE). [ 145 ] "In early May 2008, HSUS notified the Secretary of Agriculture that it had collected new evidence of abuse of nonambulatory cows and pigs at livestock auction markets in Maryland, Pennsylvania, New Mexico, and Texas." [ 146 ]
To help rebuild market confidence, the American meat Institute, the National Meat Association, and the National Milk Producers Federation petitioned FSIS to entirely ban nonambulatory cattle from the meat supply. [ 147 ] This rule became effective in 2009. [ 148 ] Similarly, California Assembly Bill 2098 , enacted in 2008, prohibits the sale of meat or meat products of nonambulatory animals for consumption, and requires the entity in charge of the nonambulatory animal to "either take immediate action to humanely euthanize the animal or humanely remove the animal for veterinary treatment." [ 149 ]
3. Humane Slaughter
While states began passing humane slaughter laws as early as 1956, [ 150 ] only twenty-one states had enacted such laws by 2006. [ 151 ] These humane slaughter laws provide some regulation of the methods of animal slaughter in CAFOs. The 2006 Mississippi House Bill 1109 is one such statute, providing:
For purposes of this chapter, the following methods of slaughtering and handling are declared to be humane:
(a) In the case of cattle, calves, horses, mules, sheep, swine, ratites, nontraditional livestock, rabbits and other livestock, all animals are to be rendered insensible to pain by a single blow or gunshot or by an electrical, chemical or other means which is rapid and effective before being shackled, hoisted, thrown, cast or cut; or
(b) By slaughtering and handling in connection with such slaughtering in accordance with the ritual requirements of the Jewish faith or any other religious faith that prescribes a method of slaughter whereby the animal suffers loss of consciousness by anemia of the brain caused by the simultaneous and instantaneous severance of the carotid arteries with a sharp instrument. [ 152 ]
This statute also provides for the Commissioner of Agriculture and Commerce to examine and inspect for humane methods of slaughter within CAFOs. [ 153 ]
New Hampshire, similarly, enacted a humane slaughter law in 1960. [ 154 ] In 2010, however, New Hampshire enacted House Bill 1359 : An Act Relative to the Enforcement of Humane Slaughter Laws, which changed the wording of the statute to allow, rather than require, the Commissioner of the Department of Agriculture, Markets, and Food to authorize any agent to enforce the state's Humane Slaughter Provisions. [ 155 ] Thus, with this recent bill, New Hampshire effectively destroyed the power of its humane slaughter law, allowing the law's enforcement to be only permissive rather than mandatory.
4. Miscellaneous Protection Statutes
While many of the animal protection statutes fall into categories, there are also statutes seen in fewer numbers, with just a few states enacting them. Two such types of statutes, which in fact are becoming more commonplace in pending legislation and deserving of their own categories, are statutes prohibiting tail docking and statutes prohibiting force-feeding of birds. For an example of a force feeding statute, Michigan, in 2007, enacted House Bill 4871 , which prohibits the force-feeding of birds, meaning "deliver[ing] food by placing a tube or other device into the esophagus of a bird and includes any other feeding method designed to cause the ingestion of an amount of food by the bird that exceeds the amount that would be ingested voluntarily by a bird of that species." [ 156 ] Legislation concerning force-feeding of birds, generally to produce the food foie gras, [ 157 ] has arisen out of much controversy. Not only have there been protests against foie gras during the last decade, [ 158 ] but even lawsuits challenging the practice; one such suit, Lovenheim v. Iroquois Brands , dates as far back as 1985. [ 159 ]
For an example of a tail docking statute, in 2009, California passed Senate Bill 135 , which prohibited the tail docking of horses and cattle. [ 160 ] This bill was supported by the American Society for the Prevention of Cruelty to Animals (ASPCA), HSUS, California Veterinary Medical Association, California Cattlemen's Association, and California Farm Bureau. [ 161 ] While there are other miscellaneous anti-cruelty statutes, these are two of the more common types, as is seen in the currently pending legislation.
V. Pending Legislation Concerning CAFOs
Pending animal welfare legislation may also be divided into categories. Issues of animal confinement continue to be the foremost topic in new CAFO legislation, followed by legislation concerning tail docking, force-feeding of birds, treatment of nonambulatory animals, and miscellaneous animal protection concerns.
Pending legislation among the states still focuses hugely on the confinement standards for animals on CAFOs. Florida currently has pending Senate Bill 1636 : An Act Relating to the Protection of Farm Animals, which would provide that no calves raised for veal or egg-laying hens may be confined in such a way that the animals cannot lie down, stand up, fully extend their limbs, and turn around freely. [ 162 ] Similarly, Massachusetts, North Carolina, and Rhode Island have pending House Bill 458 , House Bill 610 , and House Bill 7769 , respectively, which have the same requirements for egg-laying hens, sows during pregnancy, and calves raised for veal. [ 163 ]
New York currently has two bills addressing this issue. The first is Assembly Bill 1928 : An Act to Amend the Agriculture and Markets Law, in Relation to the Confinement of Animals for Food Producing Purposes, which would provide that pigs during pregnancy, egg-laying hens, and calves raised for veal shall not be confined in a way that prevents them from lying down, standing up, fully extending their limbs, and turning around freely. [ 164 ] The second is Assembly Bill 2118 : An Act to Amend the Agriculture and Markets Law, in Relation to Enacting the Prevention of Farm Animal Cruelty Act, which would not only provide the same requirements of being able to lie down, stand up, extend their limbs, and turn around freely, but would also extend protection to any adult or juvenile bovine, porcine, poultry, or fowl species, thus substantially broadening the typical scope of these sorts of bills. [ 165 ] The bill would also prohibit excessive breeding of these animals; force-feeding; excessively crowded, unsanitary or unsafe conditions; failure to provide nutritious food and potable water; and failure to obtain appropriate medical care for the animals. [ 166 ] This bill thus goes further than many of the currently pending bills in terms of animal welfare reform.
2. Tail Docking
Tail docking legislation continues to grow among the states. Illinois currently has House Bill 1697 : An Act Concerning Animals pending, which would prohibit the tail docking of bovine animals unless necessary to the health of the animal. [ 167 ] Similarly, New York currently has pending Assembly Bill 1893 : An Act to Amend the Agriculture and Markets Law, in Relation to Prohibiting Tail Docking of Cattle, which would prohibit the tail docking of horses and cattle, [ 168 ] and Rhode Island has pending Senate Bill 458 : An Act Relating to Animals and Animal Husbandry, which would prohibit the tail docking of cattle. [ 169 ]
3. Force-feeding of Birds
Public concern with the force-feeding of birds also appears to be growing, as state legislation continues to address this issue. Hawaii currently has pending House Bill 77 : An Act Relating to Foie Gras. [ 170 ] This Act would prohibit the possession, sale, offer for sale, trade, or distribution of foie gras, the fatty liver of a bird that is obtained through force-feeding. [ 171 ] This proposed law appears to have a broader scope than current force-feeding laws in that it not only prohibits the act of force-feeding the birds, but also prohibits the partaking in any part of the result of force-feeding the bird, the foie gras. Not even possession of foie gras is allowed.
Treatment of nonambulatory animals further continues to be a point of interest in CAFO legislation. New York currently has pending two bills, Assembly Bill 1725 : An Act to Amend the Agriculture and Markets Law, in Relation to Downed Animals, [ 172 ] and Assembly Bill 4615 : An Act to Amend the Agriculture and Markets Law, in Relation to Nonambulatory Animals. [ 173 ] Assembly Bill 1725 would provide that a downed animal, referring to a cow that cannot walk and stand without assistance, shall not be bought, sold, or received for human consumption, nor shall a downed animal be pushed or dragged, but may only be moved with a sling or stoneboat. [ 174 ] The proposed law would also provide that the downed animal be immediately either humanely euthanized or removed for veterinary treatment. [ 175 ] Assembly Bill 4615 would provide that no person shall transport, hold, buy, sell, give, receive, or market a nonambulatory animal. [ 176 ] Thus, there remains a concern with the CAFO animals that are nonambulatory, or downed.
As always, there are several miscellaneous animal welfare laws pending among the states. New York has pending Assembly Bill 5912 : An Act to Amend the Agriculture and Markets Law, in Relation to Vaccination of Egg-laying Hens Against Salmonella, which would prohibit the transportation, sale, or offer or exposure for sale of eggs from chickens not vaccinated against salmonella enteritidis. [ 177 ] Although helpful to animals, this bill appears to be more for human health concerns than animal welfare concerns. Vermont currently has pending House Bill 553 , which would prohibit the transportation for slaughter or slaughter of calves less than ten days old. [ 178 ] While there are several other miscellaneous animal welfare bills pending, these two are among the more beneficial to the animals.
VI. Conclusion
The conditions currently present on CAFOs are undoubtedly subjects of animal welfare, environmental degradation, and human health concern. As is apparent, animal welfare reform on CAFOs continues both in state legislation and ballot initiatives. The proposed and enacted laws reflect the concerns with animal welfare that are present on CAFOs, focusing primarily on the close confinement of animals, but also addressing some of the painful procedures conducted on the animals, such as tail docking and force-feeding, among others, as well as the treatment of nonambulatory animals and the slaughter of animals. There appears to be a general trend toward legislation giving animals on CAFOs slightly more space in their confinements, generally not major advancements, but providing enough room to lie down, stand up, fully extend their limbs, and turn around freely.
These legislative efforts, however, are clearly motivated by similar, and more progressive, ballot initiatives. The ballot initiatives are the work of animal welfare and animal rights advocates, such as HSUS, Farm Sanctuary, and state animal interest organizations, such as the Animal Rights Foundation of Florida, the Arizona Humane Society, and the Animal Defense League of Arizona. Without ballot initiatives and the fear that the possibility of ballot initiatives puts in the agribusiness leaders, state legislatures would likely enact less animal welfare reform legislation, as there would be significantly less pressure to do so. Ballot initiatives are thus the fuel behind current changes in laws concerning CAFOs.
While the law certainly has a good distance to travel before it alleviates all of the concerns of animal welfare on CAFOs, it appears to be moving in a forward direction, although at a slow pace, each year bringing more legislation, more ballot initiatives, and more, although minor, change. The question, however, might not be whether change will come for animals on CAFOs, but rather whether legal changes arriving at such slow speeds can keep up with the growing agribusiness industry. If the laws cannot keep up, which is a real possibility, then legal aid may come too late to help many of the agricultural animals confined within this industry.
[1] Matthew Scully, Dominion 29 (2002).
[2] Id. ; see also Danielle Nierenberg, Happier Meals: Rethinking the Global Meat Industry 6 (2005) ("The industrialization of meat production has been accompanied by consolidation in the meat industry, so that today a handful of multinational corporations controls most meat production.").
[3] Scully, supra note 1, at 29.
[4] Heather Dowding, Concentrated Animal Feeding Operation (CAFO) , Encyclopedia Earth ( Feb. 8, 2011, 11:22 PM), http://www.eoearth.org/article/Concentrated_Animal_Feeding_Operation_%28CAFO%29#ref_6 .
[5] See Scully, supra note 1, at 29.
[6] Dowding, supra note 4.
[8] Region 7, U.S. Envtl. Prot. Agency, Concentrated Animal Feeding Operations , http://www.epa.gov/region7/water/cafo/index.htm (last updated Apr. 15, 2011).
[9] Id.
[10] Id.
[17] "Must also meet one of two 'method of discharge' criteria to be defined as a CAFO or may be designated." Id.
[18] "Never a CAFO by regulatory definition, but may be designated as a CAFO on a case-by-case basis." Id.
[19] See Kate Celender, The Impact of Feedlot Waste on Water Pollution under the National Pollutant Discharge Elimination System (NPDES) , 33 Wm. & Mary Envtl. L. & Pol'y Rev. 947, 950 (2009).
[20] Id. at 952.
[21] David S. Favre , A nimal Law : W elfare, Interests, and Rights 293 (2008) .
[24] Peter Singer, Animal Liberation 103 (2002 ed. 2002).
[25] Id. at 120–21.
[26] Favre, supra note 21, at 290; Singer, supra note 24, at 126.
[27] Favre, supra note 21, at 291; see also Singer, supra note 24, at 126.
[28] Singer, supra note 24, at 128.
[30] I d. at 140.
[32] Id. at 130, 134.
[34] North Carolina Agricultural Statistics , Nat'l Agric. Statistics Servs., U.S. Dep't of Agric., 38–42, available at http://www.ncagr.gov/stats/2010AgStat/Page037_056.pdf (last visited Jan. 6, 2011) (giving statistics on all livestock and poultry production in North Carolina).
[35] Factory Farm Map , Food & Water Watch , http://www.factoryfarmmap.org/#animal:all;location:US;year:2007 (last visited Aug. 16, 2011) (providing a map of factory farm locations throughout the United States).
[36] Factory Farms—State Fact Sheets , Food & Water Watch , http://www.foodandwaterwatch.org/food/factoryfarms/factory-farms-state-fact-sheets/ (last visited Aug. 16, 2011).
[41] Carol J. Hodne, Concentrating on Clean Water: The Challenge of Concentrated Animal Feeding Operations, IA Policy Project ( Apr. 2005), at 28, available at http://www.iowapolicyproject.org/2005docs/050406-cafo-fullx.pdf .
[42] Id .
[44] Scully , supra note 1, at 29.
[45] Singer, supra note 24, at 100, 122, 140.
[46] Melanie Joy, Why We Love Dogs, Eat Pigs, and Wear Cows: An Introduction to Carnism 26 (2010); Singer, supra note 24, at 122.
[49] Factory Egg Farming Is Bad for the Hens . . . , Wesleyan Univ. , http://www.wesleyan.edu/wsa/warn/eon/batteryfarming/hens.html (last visited Jan. 8, 2011).
[50] Favre, supra note 21, at 294.
[51] Singer, supra note 24, at 123–24; Getting to Know the Pig Behind Your Bacon , Food Connect , http://brisbane.foodconnect.com.au/inspiration/agrarian-revolution/getting-to-know-the-pig-behind-your-bacon/ (last visited Jan. 8, 2011) ("60% of breeding sows and 93% of pigs reared for meat live their lives almost entirely indoors.").
[52] Singer, supra note 24, at 132–33; Factory Dairy Production , Farm Sanctuary , http://www.farmsanctuary.org/issues/factoryfarming/dairy/ (last visited Jan. 8, 2011).
[53] Favre, supra note 21, at 293; U.S. Meat Production , Physicians for Soc. Responsibility (2009) , http://www.psr.org/chapters/oregon/safe-food/industrial-meat-system.html#Topofpage .
[56] Singer, supra note 24, at 121; Animal Welfare , Sustainable Table , http://www.sustainabletable.org/issues/animalwelfare/ (last updated Sept. 2009).
[57] Office of Water & Office of Sci. & Tech., U.S. Envtl. Prot. Agency, Preliminary Data Summary: Feedlots Point Source Category Study app. iv, 3 (1998), available at http://www.epa.gov/waterscience/guide/feedlots/envimpct.pdf .
[59] Nicholas C. Cronauer, Note, Flushing Out the Illinois Livestock Management Facilities Act , 5 Val. U. L. Rev. 637, 641 (2011); Office of Water, supra note 57, at 1.
[60] Cronauer, supra note 59, at 641–42; Office of Water, supra note 57, at 1–2.
[61] Office of Water, supra note 57, at 1–2.
[62] Id. at 1.
[65] Id.; see also U.S. Meat Production , supra note 53.
[66] U.S. Meat Production , supra note 53.
[68] Cronauer, supra note 59, at 643–44; Office of Water, supra note 57, at 2.
[69] Cronauer, supra note 59, at 644.
[71] Id. For a detailed discussion on the issue of antibiotic-resistant bacterial strains in humans caused by industrial livestock practices, see Ariele Lessing, Note, Killing Us Softly: How Sub-Therapeutic Dosing of Livestock Causes Drug-Resistant Bacteria in Humans , 37 B.C. Envtl. Aff. L. Rev. 463 (2010).
[74] Anastasia S. Stathopoulos, Note, You Are What Your Food Eats: How Regulation of Factory Farm Conditions Could Improve Human Health and Animal Welfare Alike , 13 N.Y.U. J. Legis. & Pub. Pol'y 407, 434–35 (2010) .
[75] 7 U.S.C. § 1901 (2006) .
[76] 49 U.S.C. § 80502 (2006) .
[78] Id. at § 1902(a) .
[79] 9 C.F.R. § 301.2 (2005).
[80] Stephanie J. Engelsman, "World Leader"—At What Price? A Look at Lagging American Animal Protection Laws , 22 Pace Envtl. L. Rev. 329, 335 (2005) .
[82] Id. at § 80502(a)(2)(B) .
[83] Tuberculosis, Brucellosis, and Paratuberculosis in Cattle and Bison; Identification Requirements, 60 Fed. Reg. 48,362, 48,365 (Sept. 19, 1995) (to be codified at 9 C.F.R. pts. 50, 51, 77, 78, 80).
[84] Engelsman , supra note 80, at 338.
[85] European Comm'n: Scientific Veterinary Comm., Animal Welfare Section, Report on the Welfare of Intensely Kept Pigs (adopted Sept. 30, 1997), available at http://ec.europa.eu/food/fs/sc/oldcomm4/out17_en.pdf .
[86] Ariz. Rev. Stat. Ann. §§ 3-2001–3-2017 (2011); Rebecca F. Wisch, Table of State Humane Slaughter Laws , Animal Legal & Historical Ctr. (2006), available at http://www.animallaw.info/articles/ovusstatehumaneslaughtertable.htm .
[87] 2002 Florida Amendment Article X Section 19 (enacted as Section 21).
[88] Voters Protect Pigs in Florida, Ban Cockfighting in Oklahoma , Humane Soc'y U.S. (Nov. 6, 2002), http://www.humanesociety.org/news/news/2002/florida_gestation_crates_OK_cockfight_110602.html .
[89] See infra Part III.C.1.
[90] N.J. Soc'y for the Prevention of Cruelty to Animals v. N.J. Dep't of Agric ., 955 A.2d 886, 888–90 (2008).
[100] Id. at 909–13.
[101] What Are Ballot Propositions, Initiatives, and Referendums? , Initiative & Referendum Inst. U. S. Cal. Sch. L. , available at http://www.iandrinstitute.org/Quick%20Fact%20-%20What%20is%20I&R.htm#Initiatives (last visited Aug. 18, 2011).
[102] Id.
[103] See id.
[104] See Laura Schierhoff, Ohio's Issue 2 , Animal Blawg (Sep. 17, 2009), http://animalblawg.wordpress.com/2009/09/17/ohio%E2%80%99s-issue-2/ .
[105] Proposed Initiatives to the People—2011 , Wash. Secretary St. , http://www.sos.wa.gov/elections/initiatives/people.aspx (last visited Aug. 18, 2011); Washington Farm Animal Cruelty Prevention, Initiative 1130 (2011) , Ballotpedia , http://ballotpedia.org/wiki/index.php/Washington_Farm_Animal_Cruelty_Prevention,_Initiative_1130_%282011%29 (last modified July 18, 2011).
[106] Andrew Garber, Backers Cancel Initiative to Give Chickens Better Living Conditions , Seattle Times , July 7, 2011, 12:03 PM, http://seattletimes.nwsource.com/html/politicsnorthwest/2015535924_post_3.html ; Washington Farm Animal Cruelty Prevention , supra note 105.
[107] S.B. 5487 , 62d Leg., Reg. Sess. (Wa. 2011).
[108] The Act , Yes! on 1130 , http://yeson1130.com/act (last visited Aug. 18, 2011).
[110] Id. ; Washington Farm Animal Cruelty Prevention , supra note 105.
[111] 2002 Florida Amendment Article X Section 19 (enacted as Section 21).
[112] Florida's Historic Ban on Gestation Crates , Animal Rights Found. Fl. , http://www.animalrightsflorida.org/initiative.html (last visited Aug. 22, 2011).
[114] Voters Protect Pigs in Florida , supra note 88.
[115] Animals Win Big at Ballot Box: Voters in Arizona and Michigan Side with Humane Society on Statewide Ballot Measures , Humane Soc'y U.S. (Nov. 7, 2006), http://www.humanesociety.org/news/press_releases/2006/11/arizona_michigan_ballot_110706.html .
[116] 2006 Arizona Proposition 204 .
[118] Animals Win Big at Ballot Box , supra note 115.
[119] 2008 California Proposition 2 .
[120] Yes on Prop 2 , Ballot Measure Domains , http://www.ballotmeasuredomains.com/domains/yesonprop2com.aspx (last visited Aug. 22, 2011).
[122] Paul Shapiro, Making History for Animals: YES! on Prop 2 , About.com , http://animalrights.about.com/od/proposition2ca2008/a/YesOnProp2.htm .
[123] While Ohio Agriculture Groups Stonewall, HSUS and Michigan Agriculture Groups Compromise on Farm Animal Confinement Practices , Humane Soc'y U.S. (Oct. 5, 2009), http://www.humanesociety.org/news/press_releases/2009/10/michigan_farm_animal_confinement_compromise_100509.html .
[125] Schierhoff, supra note 104.
[130] Ohio Livestock Care Standards, Issue 2 (2009) , http://ballotpedia.org/wiki/index.php/Ohio_Livestock_Care_Standards,_Issue_2_(2009 ) (last modified Aug.19, 2011).
[134] S.B. 694 , 74th Leg. Assemb., Reg. Sess. (Or. 2007).
[135] S.B. 08-201, 66th Gen. Assemb., 2d Reg. Sess. (Co. 2008).
[136] L.D. 1021 , 124th Leg., 1st Reg. Sess. (Me. 2009).
[137] H.B. 5127 , 95th Leg., Reg. Sess. (Mi. 2009).
[139] H.B. 3339 , 72nd Leg. Assemb., Reg. Sess. (Or. 2003).
[140] S.B. 5974 , 61st Leg., Reg. Sess. (Wa. 2009).
[141] See Geoffrey S. Becker, Cong. Research Serv., RS 22819, Nonambulatory Livestock and the Humane Slaughter Methods of Slaughter Act 1 (2009) , available at http://www.nationalaglawcenter.org/assets/crs/RS22819.pdf .
[149] A.B. 2098 , 2007–08 Leg., Reg. Sess. (Ca. 2008).
[150] Ariz. Rev. Stat. Ann. §§ 3-2001–3-2017 (2011) ; Wisch, supra note 86.
[151] Wisch, supra note 86.
[152] H.B. 1109 , 2006 Leg., Reg. Sess. (Ms. 2006).
[154] N.H. Rev. Stat. Ann. §§ 427:33–37 (2011).
[155] H.B. 1359 , 2010 Gen. Court, Reg. Sess. (Nh. 2010).
[157] "[F]oie gras is made from the liver of geese. . . . [F]orce-feeding is frequently used in order to expand the liver and thereby produce a larger quantity of paté. . . . Force-feeding usually begins when the geese are four months old. On some farms where feeding is mechanized, the bird's body and wings are placed in a metal brace and its neck is stretched. Through a funnel inserted 10–12 inches down the throat of the goose, a machine pumps up to 400 grams of corn-based mash into its stomach. An elastic band around the goose's throat prevents regurgitation. When feeding is manual, a handler uses a funnel and stick to force the mash down." Lovenheim v. Iroquois Brands, 618 F. Supp. 554, 556 n.2 (D.C. 1985).
[158] Id. ; Marian Burros, Organizing for an Indelicate Fight , N.Y. Times , May 3, 2006, available at http://select.nytimes.com/gst/abstract.html?res=F00C15F63A5B0C708CDDAC0894DE404482 ; Marshall Sella, Does a Duck Have a Soul? How Foie Gras Became the New Fur , N.Y., June 18, 2005, available at http://nymag.com/nymetro/food/features/12071/ .
[159] Chuck Squatriglia, Foie Gras Farmer Sued by Animal Rights Groups , San Francisco Chron ., Oct. 23, 2003, at A21, available at http://www.sfgate.com/cgi-bin/article.cgi?file=/chronicle/archive/2003/10/23/BAG9T2H4LV14.DTL .
[160] S.B. 135 , 2009–10 Leg., Reg. Sess. (Ca. 2009).
[161] Victory for Farm Animals—California Bans Tail Docking of Cows , ASPCA (Oct. 23, 2009), http://www.aspca.org/Blog/victory-for-farm-animals-in-california.aspx .
[162] S.B. 1636 , 2011 Leg., Reg. Sess. (Fl. 2011).
[163] H. 458 , 187th Gen. Court, Reg. Sess. (Ma. 2011); H. 610 , 2011–12 Gen. Assemb., Reg. Sess. (NC. 2011); H.B. 7769 , 2010 Gen. Assemb., Reg. Sess. (Ma. 2010).
[164] A. 1928 , 2011–12 Assemb., Reg. Sess. (Ny. 2011).
[167] H.B. 1697 , 97th Gen. Assemb., Reg. Sess. (Il. 2011).
[169] S.B. 458 , 2011 Gen. Assemb., Reg. Sess. (Ri. 2011).
[170] H.B. 77 , 26th Leg., Reg. Sess. (Hi. 2011).
[178] H. 553 , 2009–10 Gen. Assemb., Reg. Sess. (Vt. 2010).


Erik Gardiner says life is starting to return to normal following the Humboldt Broncos bus crash a year ago April 6th.
The former Kelowna Rockets forward was born in Humboldt and saw many close friends and teammates die on that fateful day.
"I think I will deal with it for the rest of my life. It is a tragic event for those families to go through. It is tragic for everyone living in the community (Humboldt). It probably hit me harder because I played with them not to long ago."
Gardiner played 25 games with the Broncos during the 2016-2017 season and has tattoos on of the names of Jacob Leicht and Logan Schatz who died in the crash.
"I live my life differently. I think twice about what young kids make with their lives. I just try to live like every day is my last".
Gardiner says he has tried to move on, something his friends would want him to do.
Gardiner has retired from competitive hockey, but has four years of tuition and books if he wishes to use his WHL scholarship.


Living in Los Angeles, I meet more than my share of actors. Not just the more famous ones, but the ones trying to make it. And there are many of them at the "undiscovered" stage of their careers who are pure artists. By that I mean they love acting. They are passionate about the process of creating a character and performing. And some of them are extremely talented. They consider themselves as pure artists, but they are starving, because they have not adjusted to the idea that successful actors know that they are not just artists, but are working in an industry trying to make a profit, not just art.
Tom Cruise, on the other hand, knows that he is in a business. He loves acting, and works as hard or harder than almost anyone in the industry at his performances. He has been the lead in 29 films, has won three Golden Globes and been nominated for three Oscars. But, he is also ranked #3 in all-time box office revenue ($6.5 billion so far), because he understands the business of acting, perhaps better than almost anyone.
Tom Cruise has a PR team, an acting coach, a manager, an agent, a financial advisor and business partners in his production company. Why? Because to succeed in acting you need all of those things, as well as talent.
The successful dentists I know all have their team as well. They use a practice consultant to coach them, work with a financial advisor, use outside marketing resources, and have a deeply-engaged relationship with their distributor representative. And they make sure that their office manager is constantly updating her skills (through organizations like AADOM).
But all that is expensive, you might say. In response, I say, you know what's expensive? Houses. Cars. Kids' educations. Travel. Retirement. That's why you need to be successful as a dentist, not just clinically excellent. That takes investment. Tom Cruise pays his manager 10% of his income because he earns it! His acting coach isn't expensive–he's an investment in growth. His financial advisor doesn't cost him money–he makes him money. And all of these people do these things so that Tom can focus on his performance.
Successful dentists–dentists who are thriving and enjoying their work–focus on the clinical and the business side of their practices. Clients of mine use 1-800-DENTIST because they know their ROI is 4-1 on their marketing investment. They have us build their websites because they know they couldn't possibly keep up with SEO on their own. Fortune Management clients keep using their coaches even as they get more successful, because they know they can always get better (or slip back into old, unproductive habits.) Patterson clients know that their rep isn't just keeping their cabinets full of sundries, but are also steering them in the right direction on new technology, office design and clinical training.
Those are just examples of the many good resources that are available to you. I list my favorites on this blog on the right-hand side, from Gary Takacs to Spear Education to the Madow brothers, and in the resources section of this blog as well.
Long-term success in dentistry is not an impossible mission, but a noble one. You're helping people, and the only way you can keep doing it in the next 20 years is by running your business extremely well. And that takes a team.
This entry was posted in Advertising, Dental Marketing, dental technology, Dentistry, Online Reviews, Practice Management, Team Building, Websites and tagged advertising, dental marketing, dental practice management, dental practice marketing, Dental team training, dental technology, dentistry, Online Reviews, websites, Yelp by Fred Joyal. Bookmark the permalink.
Thanks for a great article Fred ! It's a good one to ponder as goals are set for next year. I am sharing this with my dental colleagues… Especially the ones with mortgages tuitions vacations and new technology investments! Hope you have a wonderful holiday season and healthy prosperous new year!!
Spot On, Fred! Well written (as usual), and right on target! Thanks for sharing!
Fred, you tell it exactly like it is.
Sadly, there are a lot of dentist artists not reading your blog, and missing this great advice.
Well done, you've hit the nail on the head!
What a great analogy! Nailed it. Thanks for this article!
I am aware that there are a few male office managers, but the limitations of English make it difficult to not favor one gender over another in any particular sentence. I think that there should be more male office managers, especially now that there are so many more female dentists!
Fred, I'm just in the process of editing my book and my PC editor has gone through and put "he/she" everywhere which takes the content away from being totally conversational….I know what you mean when using the written word. I had to change them all to "they" or "them" for better readability. BTW Fred, in your video you perform admirably as an Office Manager. LOL!


Love can be full of surprises, but smashing both your cars into each other in a possible love-fueled argument is particularly unexpected. According to police in Springfield, Oregon, a couple smashed their respective cars into one another while traveling westbound on on Highway 126 at approximately 10:15 p.m. on Thursday night, according to KVAL 13.
41-year-old Gevevieve Daley and 45-year-old William Grace crashed into one another when Daley lost control of her 2003 Pontiac Grand Am. If you look at the image above closely, you can see that that Grace was driving a 1973 Chevrolet Camaro when the incident occurred.
According to police, Daley lost control of her Grand Am, crashed into the median and spun around. During her crash, she was struck by Grace, and both vehicles sustained heavy damage. Fortunately, neither party was seriously injured, but they were still transported to Riverbend Hospital.
Initially, both parties told police they were arguing prior to the crash, but they later retracted their statements. No evidence shows an argument or act of aggression took place prior to the incident, but this sure seems to be one hell of a coincidence. Both parties have been charged with DUI and reckless driving.
Two is always better than one when it comes to pony cars.


It's not clear that this is really helpful; it's more or less notes I took while researching NIS (Yellow Pages). Note that Sun originally called it Yellow Pages, but British Telecom already had this name for something else. While a lot of interface-level prefixes were left yp, NIS was chosen instead.
Most of the contents of this document were plagierized from http://www.tldp.org/HOWTO/NIS-HOWTO/ , dated 1 July 2003.
One machine acting as server, but read-only copies of database on 0+ slave servers.
Slaves notified of modifications via yppush.
NIS+ side note: NIS+ is newer version, not universally used, easy for clients, but nightmare for server administrator, supports data encryption and authentication over secure remote procedure call (RPC).
Database manager (DBM) format, fixed-size buckets and hashing techniques enabling retrieval by key. Derived from ASCII databases (/etc/passwd and /etc/group), the master NIS server should retain both (ASCII and binary).
Older ypbind versions do a broadcast to find a running server, but this is insecure (anyone could answer). Newer versions keep a host configuration file, /var/yp/binding/... (if set up; mine isn't).
NIS uses remote procedure calls (RPS). The server is portmap and converts RPC program numbers into TCP (UDP)/IP port numbers. It must be running to make RPC calls, what the NIS client does, to NIS servers on their respective hosts. When an RPC server is launched, it tells portmap what port number it is listening on and what RPC program numbers it is prepared to serve. When a client makes a call to a given program number, it first contacts portmap on the server to determine the port number where the RPC packets should be sent.
portmap should be started before inetd since that dæmon can start (and stop) it. A separate, omnipresent instance is needed.
NIS+ side note: for secure RPC, a time service is needed and must be enabled in /etc/inetd.conf on all participating hosts.
In particular, using yppassword, which often just maps to passwd, sends the old password in clear text over the network to the NIS master server. If the change to a new password is successful, no problem. However, upon failure, the old password remains in effect until it can be changed and, meanwhile, anyone having sniffed it, can attack using that password. Worse, if the system administrator changes the NIS password for a user, its root password is sent in clear text over the wire.
Without going to NIS+, one solution to this makes use of rpasswd which goes over a secure SSL connection.
Where does this stuff live?
On Linux, one generally installs the ypbind dæmon in /usr/sbin and the other binaries, ypwhich, ypcat, yppasswd, yppoll and ypmatch, in /usr/bin.
This configuration file determines the order of look-ups when information is requested just as /etc/hosts is consulted when performing host look-ups.
tells NIS that the password look-up functions should first consult /etc/passwd (in the local "file" system) or look to a NIS server for it and, those approaches failing, ask Vintela Authentication Services (VAS) for it (in the case of a VAS user that is not also a local Unix user).
New maps are created using ypinit -m (when setting up the NIS server for the first time). Maintaining the maps in use is a matter of updating /var/yp/Makefile and rebuilding (make -C /var/yp) each time. This holds for after making changes to one or more maps too.
Map entries are limited to 1024 characters, governed by YPMAXRECORD, which cannot be simply modified. The glibc implementation removes this limit, but all servers and clients on the network must participate.
One way around this for group names is to break them out onto multiple lines, each with a slightly different name and keeping the same GID of course. The first entry should contain the "real" group name (and the GID); to save space, don't put any users on that line. The cleverness happens because looking for a username, you get the right GID while looking by groupname you also get the right GID (and ignore the bogus groupnames).
To survive reboot, there needs to be a ypbind (server) or ypclient (client) script in the init script directory (/etc/init.d, etc.).
Nothing to do with Halloween themes, these two commands list the maps and the master offering them and reveal the contents thereof. Think of ypwhich sort of as ls for the NIS maps and ypcat as cat to see their contents.


Post written by Sauid Ishaq, FRCP, from Birmingham City University, Birmingham, United Kingdom.
Our video case report demonstrates the application and effectiveness of hemospray as a rescue therapy in acute bleeding from portal hypertensive gastropathy.
PHG is a common and potentially fatal adverse event of cirrhosis, with severity correlating with the degree of portal hypertension. There is limited evidence supporting the role of nonselective b-blockers (NSBB) and terlipressin for bleeding PHG failing that transjugular intrahepatic portosystemic shunt (TIPS) is considered. Acute bleeding really poses a challenge.
Our video case report demonstrates the ease of application and effectiveness of hemospray in this situation, potentially revolutionizing the endoscopic management of bleeding PHG.
Congratulations to the authors of this very informative video.
Hemostatic powder was probably a temporary solution ? Did the patient received TIPS for a permanent hemostasis control ?
thanks Alex – patient responded to betablocker and abstinenve, if reucurrancr TIPS will be considered.


text:
Link between rising tuition fees and depression amongst UK students?
Updated 18 October 2017
There's been a 28% rise in UK students seeking counselling whilst at university. Are tuition fees to blame? Image credit: amenclinics According to newly-released figures, around 43,000 students at top UK universities sought counselling for anxiety and depression in 2014/15, compared with 34,000 in 2011 – the year before tuition fees rose to £9,000.
In order to feel like the high tuition fees are really worth the hassle, today's students are under pressure to perform well and make themselves as employable as possible in an increasingly competitive job market.
There's a tendency now to think about your degree in terms of 'getting your money's worth' – but at the current rates, this is nearly impossible!
But are rising tuition fees the only problem?
We'd suggest that it's not just the rise in tuition fees that's putting pressure on students and causing mental health issues, but also a more general rise in UK living costs and frozen maintenance loans that have failed to reflect these changes.
As we found in our student money survey last year, student living costs currently average at around £745 per month, whereas the £480 maintenance loan only covers just over half of this. As a result, 2 out of 3 students told us they struggled to survive off the loan. Sounds pretty stressful to us!
Being a student no longer about "long lazy days"
Image credit: Timothy Brown - Flickr.com Dr Ruth Caleb, who is head of Counselling at Brunel University, has also spoken out saying that thanks to rising tuition fees there's a "cultural change in being a student."
She states that student life no longer lives up to the stereotype of having "long lazy days" but rather students are under a lot more pressure to perform and are evidently experiencing anxiety as a result.
Dr Caleb claims that student counselling services are seeing an annual rise in demand of around 10%.
Our student money survey 2015 also reflects Dr Caleb's claim, as results indicated that students are becoming increasingly conscious of how they spend their cash, forking out comparatively less on buying food, clothes and socialising and more on rent as rental prices continue to increase.
If you'd like to speak to someone about feeling down or anxious at uni, remember that every university has a counselling department, and they're there to support you.
If you'd prefer to speak to someone outside of your uni, there's also a range of support services available online specifically for students such as mental health charity, Student Minds - you can check out their support page here.
Train compensation shake-up – get cash now instead of vouchers!

redpajama_set_name: RedPajamaCommonCrawl


The Purple Mattress is sold on Amazon for $1,299.00. A lot of buyers feel that the purple mattress is rather pricey, especially compared to other mattresses sold on the market. The purchase price could be said to be reasonable and significant when measured against the elastic nature of the mattress. Remember that this mattress is a mattress that offers excellent pressure relief and edge support. The mattress is certain not for everybody, but it's perfect for people that adore the relaxation it have a budget that is flexible and provides.
The Purple Mattress Is Composed of elastic Polymer. The cover is made with Lycra, and a mix of Polyester as well as Viscose; they're produced to be soft to permit for the flow of air. The Lycra material is used for temperature regulation.
One characteristic of this purple mattress is its , to help with pressure relief and weight distribution. Gives some rebound, which makes it easy for you to turn without interference from one position to the other to the mattress.
Another feature of this mattress is that it is Constructed to offer firm support. Even when their over two users of the mattress at the exact same period assists in weight distribution and ensures that other users aren't bothered by any motion.
Purple Mattress can also be designed using a Major science-based Technology to create. Spine alignment is provided by this comfy bed. It also equalizes pressure from the body's weight so that nobody feels the motion of the others sleeping or wake up when others proceed.
1 great feature of the purple mattress is that it is an Mattress which doesn't have any artificial germicides and doesn't contain any toxic materials which can be bad for the user's health. It's built with Polymer substances that protects the mattress against dust mites and allergens and are safe to use. The Purple mattress is licensed by CertiPUR at the USA.
Also, this Exceptional mattress is made with a grid System that provides supports depending upon the pressure given to it. It features a sleep experience that is exceptional to each user.
The cover of the purple mattress may become cluttered after long Use, but the good news is that this cover is washable. Just use a high-efficiency washer with detergent along with cold water to wash. After wash dry with air dry that air cools on The mattress cover. It requires cycles for your cover to be dry; then you are able to replace in your mattress.
If you are currently looking for a mattress that offers pressure Relief, movement isolation, temperature regulation and is super comfy You should buy the purple mattress. The Purple Mattress is made Polymer that provides support and comfortable grid To this user.


Alaska Land Cruise: Sail the Inside Passageway with an Insider. Filled with icy creeks that tower over the Pacific Ocean while snowy peaks stretch towards the horizon. Alaska feels boundless. … Norwegian lets you explore all sides of Alaska the way locals see it, up close and personal on an Alaskan cruise.
Learn how to make travel enjoyable?


text:
BooksMay 23, 2011 issue
Vincent D. RougeauMay 23, 2011
Creating Capabilitiesby By Martha NussbaumHarvard Univ. Press. 256p $22.95
When societal progress is viewed primarily in terms of the overall increase in economic wealth, the human need for membership and meaningful participation soon loses salience in public policy debates and, ultimately, is relegated to the realm of preference. The vehemence of the recent protests against union-busting legislation in Wisconsin was surprising, partly because many of us had assumed that strong unions had long ago been sacrificed to the gods of free market liberalism. Determining whether a society is truly flourishing, however, requires an assessment of a broad range of measures of human flourishing, including meaningful opportunities to engage in various forms of social interaction. Economic indicators alone tell only part of the story.
In Creating Capabilities: The Human Development Approach, Martha Nussbaum sets out to provide general readers with a comprehensive account of the increasingly influential "capabilities approach" to political and economic development, which seeks to consider the development of societies in terms that reflect a comprehensive account of human experience. Although the model is most often considered in the context of development in poorer nations, all nations confront issues that raise important questions about what it means to provide the highest possible quality of life for all members of the community.
Students of Catholic social teaching will find the capabilities approach very familiar in a number of ways. Nussbaum sees capabilities as a means for theorizing about basic social justice. The capabilities approach views each human person as an end and not only asks about overall well-being in a general sense, but also considers what opportunities are available to each person.
What then are the capabilities of which Nussbaum speaks? There are a number of views on what the list should include. Amartya Sen, the economist and Nobel laureate who along with Nussbaum has played a major role in the intellectual framing of the approach, does not believe that developing a list of capabilities is particularly important, and he has focused instead on a comparative use of capabilities. Nussbaum, however, commits to 10 specific capabilities as a basis for identifying fundamental political entitlements. They are: life; bodily health; bodily integrity; senses, imagination and thought; emotions; practical reason; affiliation; other species; play; and control over one's environment.
By specifying which capabilities are most important, Nussbaum seeks to give content to the ideas of human dignity and equality within a broader commitment to political liberalism. She is therefore particularly concerned with individual rights and choice in the conceptions of human dignity taken by the capability approach, but it is not an individualism without limits. By presenting a list of core capabilities, Nussbaum offers a helpful point of engagement for those who seek to bring Catholic social teaching into conversations about justice in settings defined by political liberalism and religious pluralism. Her willingness to commit to core capabilities helps make terms like "human dignity," "social justice" and "equality" more intelligible in public discourse.
Because it is based on the idea that all people have capabilities by virtue of their humanity, the capabilities approach is closely allied with the movement for international human rights. It makes explicit the notion that any rights or entitlements that arise from the approach must be linked to corresponding duties, but it also demands that governments play an active role in supporting peoples' entitlements. Nussbaum is explicit in rejecting an understanding of rights as purely barriers against the interference of the state, a direct challenge to the extraordinary currency this view has gained in the United States. She argues that rights mean little if the state cannot be called upon to support and enforce them.
Civil and political rights have economic and social preconditions that will often require the affirmative action of the state to empower people who have long been marginalized, or to create a level playing field between institutions that control huge amounts of capital and the workers they employ. All of these ideas have been sounded in Catholic social teaching for over a century, but as current events make plain, many Americans reject them as "socialist."
Nussbaum offers the capabilities approach not as dogma but as something to be considered, discussed and improved upon in an effort to allow the dignity of human beings to become a central part of how we think about development in a complex, global economy. It is an important corrective in a world where the quality of peoples' lives has been reduced almost completely to a concern for how much money they have, and for which commitments to social solidarity are expendable when it comes time to balance the books.
This article also appeared in print, under the headline "Quality of Life," in the May 23, 2011, issue.
Vincent D. Rougeau
Vincent D. Rougeauis a professor of law at the University of Notre Dame.


Patrick has been working in the field of medical communications since 2007. He has experience with a broad range of therapeutics in the areas of rare metabolic diseases, neurology, virology, and psychiatry. Within these areas, Patrick has developed content for a wide array of medical media, including abstracts, posters, manuscripts, monographs and journal supplements, websites, interactive training CDs, patient case libraries, and MOA videos.
He has contributed to the planning and execution of publication plans as well as the development of thought leader engagement strategies and speaker training content in preparation for product launches. He is also trained in meeting facilitation. Before entering the field of medical communications, Patrick obtained a PhD in behavioral and cellular neuroscience from the University of Pittsburgh. After post-docs at Johns Hopkins and NINDS, he spent 6 years doing basic neuroscience research with a small biotech company.


text:
Q: Linearly independent matrix proof Suppose that $S=\{u_1,u_2,…,u_n\}$ is a set of vector from $\mathbb{R}^m$. Show that $S$ is linearly independent if and only if the set $S'=\left\{u_1,\ \sum_{i=1}^2 u_i,\ \sum_{i=1}^3 u_i,\ \ldots,\ \sum_{i=1}^n u_i\right\}$ is linearly independent.

A: If S is a linear independent set, then $a_1u_1+a_2u_2+...+a_nu_n=0$ implies all $a_i=0$ by definition. Thus
$$b_1u_1+b_2\sum_i^2u_i+...+b_n\sum_i^nu_i=\sum_i^nb_iu_1+\sum_i^{n-1}b_iu_2+...+b_nu_n=0$$
implies $\sum_i^kb_i=0$ for all $k$, namely $b_i=0$ for all $i$. That is, S' is also a linear independent set.
The reverse direction is similar and easy now.

A: Define
$$s_k := \sum_{i=1}^k u_i, \quad k=1:n.$$
Then $S' = \{ s_1, s_2, \dots, s_n \}$. Note that
$$u_1 = s_1, \quad u_k = s_k - s_{k-1}, \quad k > 1.$$
This should be enough to get you going. If you get stuck, write what you did and explain where is the problem.

redpajama_set_name: RedPajamaStackExchange


text:
Wolf: Return-to-Field is Better for Cats, Shelters, and Communities
by Peter J. Wolf Jul 16, 2019 Updated Dec 8, 2020 Why you can trust Voice of OC
Sharon Logan's recent opinion piece ("OC Animal Care Wrong to Return Sheltered Cats Back into Neighborhoods," July 12) only adds to the misinformation and scaremongering on the subject of unowned, free-roaming "community" cats, thereby undermining any chance for reasonable discussions and fact-based reporting.
Best Friends Animal Society operates more large-scale trap-neuter-return (TNR) and return-to-field (RTF) programs than any other organization in the country. As such, we are in a unique position to comment on the positive impact such programs have not only on the cats, but on animal shelters and the communities they serve. The TNR process is simple: cats are caught, evaluated by veterinarians, vaccinated, spayed or neutered, and returned to their original outdoor homes, unable to have kittens.TNR is typically employed at a community level; RTF is essentially TNR for healthy cats brought to a shelter as "strays." (According to OC Animal Care's mid-year report, more than 93 percent of the 4,609 cats and kittens brought to the shelter during the first half of 2019 were categorized as "strays.")
Historically, even the most social of these cats had little chance of making it out of overcrowded shelters alive. And by adding to the shelter's population, they increased the likelihood of stress-related disease transmission. In short, the consequences of "sheltering" these cats was almost entirely negative—for the "strays" themselves, the adoptable owner-surrendered cats, and, of course, the staff who were expected to kill one cat after another with no end in sight.
I agree with Logan that residents need to speak up about the kinds of programing they want to see implemented by their local animal shelter. It's important, however, that the public be well-informed. Contrary to Logan's claim that RTF "controversial at best," the practice is well-established across the country. As a result, there is a growing body of evidence demonstrating the benefits of these programs.
RTF programs have positive impacts in the shelter and the community
As RTF becomes more popular, shelters and non-profits are paying greater attention to the metrics that can be used to document its results. A study recently published in the peer-reviewed journal Frontiers in Veterinary Science, for example, reports the results of six large-scale RTF/TNR programs operated by Best Friends in partnership with municipal shelters. The results show median reductions of 32 percent in feline intake and 83 percent in shelter killing across the six partner shelters, as well as a median increase of 53 percent in live-release rate.
Perhaps the most impressive statistic, though, is the reduction in newborn kitten intake: 41 percent across the four shelters that tracked such data. This is compelling evidence that these programs are effective at reducing the overall population of community cats. I am unaware of any other approach that has produced comparable results.
RTF program cats are healthy
Obviously, community cats face a number of risks. However, a growing body of research tells us that the vast majority of these cats are healthy—even thriving. Indeed, the study mentioned previously put hard numbers behind what those of us familiar with these programs have known for some time. Of the nearly 73,000 cats involved in the six RTF/TNR programs, 83 percent were simply sterilized, vaccinated, and returned to where they were living in the community. Another 15 percent were adopted directly from the shelter or transferred to rescue groups for adoption. Just 0.5 percent were euthanized for serious health concerns. Such findings challenge the common misconception that these cats are unhealthy—and that RTF is, as Logan suggests, "cruel" and "abusive."
The fact that these cats are healthy is hardly surprising. Again, those of us familiar with these programs know firsthand that many residents care for and value community cats. This helps explain why so many of them are sociable, too. It's understandable that there can be some reluctance about returning "friendly" cats—but again, it's important to recognize that they're very likely doing well where they were found. What they need from the shelter isn't impoundment but sterilization, vaccination, and a ride back to where they were found.
RTF reduces shelter overcrowding
As Logan notes, OC Animal Care is already operating at capacity (a common scenario during "kitten season"), dramatically reducing the chances of a positive outcome for an incoming "stray" cat. By sterilizing, vaccinating, and returning healthy "strays," RTF programs reduce overcrowding and the risk of disease transmission.
These programs also free up resources for other lifesaving programs. This year, for example, OC Animal Care was able to host Emergency Bottle Baby Training for Kittens for the first time. This kind of community-focused training is virtually impossible without a robust RTF program in place to "buy" shelter staff the necessary bandwidth.
RTF is aligned with anti-cruelty laws
Logan isn't the first to suggest that RTF might be considered abandonment (an argument that strikes me as a red herring more than anything else). She fails to acknowledge, however, a key factor underpinning the legal concept: criminal intent.
Anti-cruelty laws are designed to prevent actions that will result in foreseeable harm. As mentioned previously, though, the vast majority of community cats are healthy; there's no reason to think that returning them—sterilized and vaccinated—to the location where they were found puts them at some increased risk. Criminal sanctions for returning a healthy cat to their outdoor home as part of a program deliberately designed to improve the cat's overall health and well-being conflicts with the legislative intent of anti-cruelty laws.
Remember, too: these programs are becoming increasingly common across the country, operated openly in communities large and small, urban and rural. It's difficult to imagine such a trend if Logan's interpretation of the relevant laws were correct.
What exactly is Logan proposing?
No doubt many readers will have noticed that Logan failed to provide any recommendations for OC Animal Care. She complains that the agency's policies and practices are "not what sheltering is supposed to be about" but has little to say about what should be done with the thousands of "stray" cats who are brought in each year.
Again, though, there is a growing body of evidence demonstrating the benefits of RTF compared to the "traditional" approach for managing feline intake. It's better for the cats (including adoption candidates and lost pets), for the shelter staff, and for the community as a whole.
Peter J. Wolf is a research and policy analyst for Best Friends Animal Society, one of the largest animal welfare organizations in the U.S. and a leader in the development and operation of community cat programs.
Opinions expressed in editorials belong to the authors and not Voice of OC.
Voice of OC is interested in hearing different perspectives and voices. If you want to weigh in on this issue or others please contact Voice of OC Involvement Editor Theresa Sears at TSears@voiceofoc.org
For a different view on this issue, consider:
Logan: OC Animal Care Wrong to Return Sheltered Cats Back Into Neighborhoods
Tagged: Best Friends Animal Society, Community Opinions on Animals, OC Animal Care, OC Animal Shelter


text:
/**
 *
 */
package com.darly.dlclent.widget.floorview;

import java.util.ArrayList;
import java.util.Iterator;
import java.util.List;

/**
 * @ClassName: SubComments
 * @Description:TODO
 * @author JohnnyShieh
 * @date Feb 20, 2014 10:03:22 AM
 */
public class SubComments {

	private List<Comment> list;

	public SubComments(List<Comment> cmts) {
		if (cmts != null) {
			list = new ArrayList<Comment>(cmts);
		} else {
			list = null;
		}
	}

	public int size() {
		return list == null ? 0 : list.size();
	}

	public int getFloorNum() {
		return list.get(list.size() - 1).getFloorNum();
	}

	public Comment get(int index) {
		return list.get(index);
	}

	public Iterator<Comment> iterator() {
		return list == null ? null : list.iterator();
	}
}

redpajama_set_name: RedPajamaGithub


Thought using the iron was boring? Think again, my friend!
Before you cut out your fabric, give it a press to smooth it out – this will help you get more accurately shaped pieces. If your pattern is creased, give that a press too on a low, dry setting (check the ink doesn't run first!).
If you're folding over the edge of the fabric to stitch it as a hem, for example, give it a press before stitching to flatten and neaten it.
Press each seam after stitching it and before stitching across it. You don't literally have to get up after sewing every seam and go over to the ironing board – you can "save up" a few bits that need pressing and do them in one go, as long as the iron gets to them before you stitch over that part of the garment.
Press seams either open or towards the back of the garment.
Press darts towards one side (horizontal darts usually go downwards).
Avoid pressing gathers, for example on the head of a set-in sleeve, as it may ruin the lovely fullness you've created with your stitching.
If you're pressing a small tricky part such as a collar, you can hang the rest of the garment off the end of your ironing board so it doesn't get under the iron.
First, test your iron setting on a small swatch of your fabric. Different fabrics can tolerate different amounts of heat and steam – too high and they may become marked or even melt!
You can help avoid damaging your fabric by laying a pressing cloth over it to protect it from the direct heat of the iron. A piece of muslin, cotton or even a tea towel will do just fine.
When ironing your pre-made clothes, you usually move the iron back and forth to smooth out the creases. When pressing, on the other hand, you're placing the iron onto the fabric, holding it static for a few seconds, then lifting it up and placing it on another part of the fabric.
Don't be afraid of a bit of steam. As long as your fabric can take it, steam will soften your fabric and help you mould and manipulate it into the shape you want it to be. For instance, it can help you roll a facing to the inside of the garment, or it can make a pointy bust dart look a little more curved and a lot less rude.
Press on both wrong and right sides of the fabric to get a neat finish.
If you're really fancy, you can use a tailor's ham and seam roll (aka sausage). These are specially shaped dedicated pressing devices which look like cushions but are deceptively firm. A tailor's ham will help you press curved parts of a garment such as darts or collars; a seam roll is a cylindrical shape which lets you press just the middle of a seam without creating a ridge on the seam edges. If you don't want to buy them, you can make your own or roll up a towel tightly as a make-shift alternative.
And finally, at the risk of sounding like your mother, turn the iron off when you're not using it, won't you? Not only will conserving the energy help save the planet (sort of), but if you knock it over and burn yourself you'll probably be so absorbed in your sewing that you don't notice until the next day, by which time you have a massive scar. Or that's what I do, in any case!
Still awake?! Do you have any pressing tips of your own to share?


Home Hair care How to take care of scalp problems?
It could be that the person is experiencing flaky dry scalp and dandruff. He/she may have tried out various types of hair care products, but still is not able to treat it effectively and only is finding it to increase and feel embarrassing about the whole thing. But it is possible to take care of these problems and to help the hair to be lush and in good health.
According to health experts, every person is likely to have some type of dandruff, which is an organic procedure. It takes place when the skin cells in the scalp region dies and starts to shed off. The old skin is replaced by the new skin cells. The procedure tends to go at unique rates among different people. Again, bad dandruff is termed to be where the skin cell shedding is noticed at faster rate and is visible to the eyes, thus making it to appear embarrassing for the person experiencing it. Dandruff can be generally noticed to be accumulated on the shirt's collar region. It can also be noticed in the beard or eye brows and all over the head. It becomes essential to control this dandruff issue and to do away with it. Using ketomac shampoo hair fall is sure to rescue the hair and ensure dandruff is removed from the hair effectively.
What exactly impacts rate of dandruff shedding procedure?
There are several factors that are considered to determine the rate of shedding of cells on the scalp.
Sebum deficiency (natural oil): Sebum is regarded to be essential natural oil that safeguards and moisturizes the skin and the hair. Different types of people tend to produce this specific oil at different rates, depending upon their hormones. The person releasing natural oil in smaller amounts will experience dry skin, which is prone to get perished and replaced quickly. Again, dry skin can be caused due to constant cleaning. Therefore, such people are advised to wash their hair less regularly and to use weaker anti-dandruff shampoo. The best anti-dandruff shampoo is one that protects the hair and can offer remedy to the dry scalp and also beat bad dandruff. Sensitive scalp will lead to dry skin. Sensitive skin will mean the unpleasant conditioners and shampoos will inflame the crown, causing it to dry up and weaken the skin. The hair is prone to get damaged if sebum is not generated in ample amount.
Excessive sebum amount: If natural oil is developed in the scalp in huge amounts, then it can cause bad dandruff. Greasy skin and hair will only generate bad dandruff, faced mainly by youngsters. This can also cause them to develop pimples. Hence using the best ketomac dandruff treatment shampoo will be the right solution availed.
Chosen lifestyle: There are many who are addicted to junk food due to lack of time. They may develop itchy scalp and dandruff. The hair and the scalp region like other body parts do require good nutrients for growth.
Therefore, finding out the cause and knowing the right treatment can help do away with dandruff.
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