Some calves are isolated and housed in cramped areas unnecessarily.
3.1 A requirement should be added that each calf have, at a minimum, 1.8 m squared space allowance based on the scientific report.
3.1.1 All calves should be group housed upon arrival, unless otherwise indicated by a veterinarian. Recommended practice A should be a requirement.
Some calves walk on flooring that cause pain and discomfort.
3.4 15% of animals with bursitis is a high prevalence of pain. Change language of second requirement to say “exceeds 10%” in accordance with report from Briscic (2011). For third requirement, it should state “A dry bedded area must be continuously available to calves.” A minimum space requirement for the bedded area should be specified. Recommended practices A, B, C, F, G, J should all be requirements.
Some calves are weak from inadequate food and unable to exhibit behaviours that promote well-being.
4.1 Missing in this section is a requirement that addresses how calves need for sucking will be accommodated. As noted in the Scientific Report they are highly motivated to suck and it provides health and behavioural benefits.
4.2 Change requirement 4 to state at least 5 times a day in accordance with the findings in the Scientific Report. Recommended practice C should be a requirement, with a firm minimum of 8L/day for the first 8 weeks of life. Given the overwhelming evidence in the scientific report of the benefit of using a teat, a requirement should be added that all milk and milk replacer is fed through a teat a modification of recommended practice E. There can be a bucket phaseout time period of no more than 15 years. Add a requirement that there should be at least one teat per calf.
4.2.2 The Scientific Report found that abrupt weaning before 8 weeks of age harms welfare. The first requirement should be modified to say 8 weeks of age. The second requirement should be modified to say 10 days at minimum (recommended practice B should be the requirement, and the recommended practice should be 22 days).
Some calves are handled roughly.
5.1 Recommended practice A should be a requirement. Calves are typically in a state of fear when around humans and yelling/hitting management practices only increase that fear. Recommended practices C and D should be requirements.
5.2 The second requirement should include lifting cattle by the tail. Recommended practice C, D, E and F should be requirements. Any other way to handle cattle is unacceptable.