OFA provided comments and recommendations regarding the regulatory registry consultation posting for the proposed regulations related to service, appeal and animal forfeiture time periods and contact information under the Provincial Animal Welfare Services (PAWS) Act, 2019. Our topline feedback is summarized below:
- Additional Methods of Service and When Service Is Effective: OFA has concerns with certain listed methods of service; Service by regular mail may cause delayed delivery of important documents in rural Ontario. Alternative methods of delivery should be prioritized. If using regular mail, then registered or tracking mail should be utilized. Farm businesses should be exempt from documents being served to those managing a location. Service of documents to household members should be limited to those verified to be 18 years or older.
- Additional Time to Initiate an Appeal of an Order, a Removal, a Decision to Keep an Animal in Care, or a Statement of Account and Changes to Corresponding Time Period for Animal Forfeitures: OFA strongly supports extending the appeal time from five to ten business days, and extending the time period for forfeiture of an animal from ten to fifteen business days. OFA recommends owners/custodians of these animals be informed of timelines when documents are being served.
- Contact Information to be Collected When Animal Ownership or Ongoing Custodianship Changes While the Animal is the Subject of an Order: OFA believes an exemption from this requirement should exist for commercial livestock owners, as it is an unrealistic due to the normal production cycle of commercial livestock.
- Additional Considerations: OFA has additional recommendations to ensure that the PAWS Act and its regulations are appropriate aligned with livestock agriculture practices and appropriate welfare standards, and functioning as intended.
Previous related OFA submissions:
OFA submission regarding the proposed changes to the Provincial Animal Welfare Services Act
Joint letter to Michael Kerzner regarding the Provincial Animal Welfare Services Act, 2019