Animal rights without controversy

Law and Contemporary Problems

Volumn 70, Issue 1, 2007, Pages 117-137

  Leslie, Jeff ^a   Sunstein, Cass R ^b  

^a UNIVERSITY OF CHICAGO LAW SCHOOL   (United States)

^b UNIVERSITY OF CHICAGO   (United States)

Author keywords

[No Author keywords available]

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EID: 34548459286     PISSN: 00239186     EISSN: None     Source Type: Journal    
DOI: None     Document Type: Article

References (124)

1. Richard A. Posner, Animal Rights: Legal, Philosophical, and Pragmatic, Perspectives, in ANIMAL RIGHTS: CURRENT DEBATES AND NEW DIRECTIONS 51, 74 (Cass R. Sunstein & Martha C. Nussbaum eds., 2004).
2. Richard A. Epstein, Animals as Objects, or Subjects, of Rights, in ANIMAL RIGHTS: CURRENT DEBATES AND NEW DIRECTIONS, supra note 1, at 157.
3. Gary L. Francione, Animals - Property or Persons?, in ANIMAL RIGHTS: CURRENT DEBATES AND NEW DIRECTIONS, supra note 1, at 108.
4. David Foster, Animal Rights Gain Support, Poll Shows, THE SEATTLE TIMES, Dec. 3, 1995, at A4.
5. Studies have consistently shown this to be true. For instance, ninety-one percent of Americans believe that the U.S. Department of Agriculture should be involved in safeguarding humane treatment of animals. Amanda Tolles & Steve Dyott, Consumers Seek to Curb Farm Animal Suffering, 96 BUS. & SOC'Y REV. 19 (1996).
6. A more recent study on New Jerseyans' opinions on animal treatment found that the vast majority of consumers were opposed to several treatment practices common among producers: Eighty-three percent of those polled felt that confining pregnant pigs and veal calves to stalls too small for them to turn around or stretch out should not be allowed; eighty-two percent were against cutting off the tails of cows or pigs without use of pain killers; eighty-one percent were against withholding food from chickens for up to fourteen days to increase egg production; seventy-eighty percent were against transporting livestock that are emaciated or unable to stand up; and seventy-four percent were against feeding calves liquid diets with no fiber or iron. EAGLETON INSTITUTE OF POLITICS CENTER FOR PUBLIC INTEREST POLLING, NEW JERSEYANS' OPINIONS ON HUMANE STANDARDS FOR TREATMENT OF LIVESTOCK 4 (2003) (performed on behalf of Farm Sanctuary), http://www.njfarms.org/NJ_opinons.pdf. The study also asked how important it was to respondents that farm animals and livestock in New Jersey be treated humanely; sixty-five percent replied that it was very important and twenty-four percent somewhat important.
7. Id at 16. Similarly, surveys conducted in the European Union in 2005 found that over eighty-five percent of respondents believed that animals should be treated much better in production systems.
8. FARM ANIMAL WELFARE COUNCIL, REPORT ON WELFARE LABELING 16 (2006), available at http://www.fawc.org.uk/reports/ welfarelabel-0606.pdf.
9. For a summary of studies of public opinion on animal welfare through 2001, see Harold Herzog, Andrew Rowan, & Daniel Kossow, Social Attitudes and Animals, in THE STATE OF ANIMALS: 2001 55, 65-66 (Deborah J. Salem & Andrew Rowan eds., 2001), available at http://www.hsus.org/press_and_publications/humane_bookshelf/ the_state_of_the_animals_2001.html (last visited July 25, 2006).
10. See JEREMY BENTHAM, THE PRINCIPLES OF MORALS AND LEGISLATION 310-11 n.1 (Prometheus Books 1988) (1789).
11. See generally Pamela D. Frasch et al., State Anti-Animal Cruelty Statutes: An Overview, 5 ANIMAL L. 69 (1999) (reviewing anti-cruelty statutes and penalties in all fifty states and the District of Columbia);
12. see also Stephan K. Otto, State Animal Protection Laws - The Next Generation, 11 ANIMAL L. 131 (2005) (detailing the modern trend towards strengthening anticruelty laws still further).
13. See JOHN RAWLS, A THEORY OF JUSTICE 505 (1971) (suggesting that animals deserve consideration but not justice).
14. For a critique, see MARTHA C. NUSSBAUM, FRONTIERS OF JUSTICE: DISABILITY. NATIONALITY, SPECIES MEMBERSHIP ch. 6 (2006).
15. See RENE DESCARTES, DISCOURSE ON THE METHOD AND MEDITATIONS ON FIRST PHILOSOPHY 34-36 (David Weissman ed., Elizabeth S. Haldane & G. R. T. Ross trans., Yale Univ. Press 1996) (1637).
16. See supra note 7.
17. See N.Y. AGRIC. & MKTS. LAW § 359(1) (McKinney 1991).
18. See id. § 359(2).
19. See id. § 356.
20. See id. § 355.
21. See id. § 353.
22. See id. §§ 353, 356.
23. See id. § 353.
24. See CAL. PENAL CODE §§ 597(b), 599b (West 1999 ).
25. Id. § 599b.
26. David J. Wolfson & Mariann Sullivan, Foxes in the Hen House: Animals, Agribusiness and the Law: A Modern American Fable, in ANIMAL RIGHTS: CURRENT DEBATES AND NEW DIRECTIONS, supra note 1, at 206.
27. By contrast, hunters and trappers, animal shelters, biomedical research, product testing, dissection, and fur farms combined are responsible for 218 million animal deaths per year. Id.
28. Id.
29. Id. at 217-18.
30. See id. at 218 for a description of customary pig-farming practices.
31. Id. at 219.
32. See id. at 218 for a description of customary chicken-farming practices.
33. For a more detailed overview, see PETER SINGER, ANIMAL LIBERATION 95-157 (rev. ed., Ecco 2002) (1975).
34. See, eg., Francione, supra note 3, at 108. However one may view the argument on the merits, the contention that animal should receive equal consideration with humans, and should not be viewed in any way as property or as resources for human use, has not made much headway in practical, political terms. The disclosure proposal set forth in this article is much more modest, and could lead to real improvements animal welfare of a kind that could be supported by people with a range of beliefs about the moral status of animals.
35. Wolfson & Sullivan, supra note 20, at 222.
36. Id.
37. Id.
38. Id.
39. For an overview, see PETER STEVENSON, EUROPEAN UNION LAW ON THE WELFARE OF FARM ANIMALS (2004), http://www.ciwf.org.uk/publications/ reports/EU_Law_2004.pdf.
40. For an overview, see MARY GRAHAM, DEMOCRACY BY DISCLOSURE: THE RISE OF TECHNOPOPULISM (The Brookings Institution 2002);
41. CASS R. SUNSTEIN, RISK AND REASON: SAFETY, LAW, AND THE ENVIRONMENT 191-228 (2002).
42. See 42 U.S.C. § 11023 (2000).
43. For a discussion of the success of the Toxic Release Inventory, see Archon Fung & Dara O'Rourke, Reinventing Environmental Regulation from the Grassroots Up: Explaining and Expanding the Success of the Toxics Release Inventory, 25 ENVTL. MGMT. 115 (2000).
44. See 42 U.S.C §§ 4321-70 (2000).
45. See Comprehensive Smoking Education Act, 15 U.S.C. §§ 1331-40 (1994) (requiring inclusion of one of four warnings on cigarette advertising and packaging: (1) Smoking Causes Lung Cancer, Heart Disease and May Complicate Pregnancy; (2) Quitting Smoking Now Greatly Reduces Serious Risks to Your Health; (3) Smoking by Pregnant Women May Result in Fetal Injury, Premature Birth, and Low Birth Weight; and (4) Cigarette Smoke Contains Carbon Monoxide).
46. See Federal Food, Drug, and Cosmetic Act, 21 U.S.C.S. § 343(i) (requiring ingredient list to avoid misbranding), § 343(q) (requiring nutritional information to avoid misbranding) (2001).
47. See COUNCIL ON ENVTL. QUALITY, THE NATIONAL ENVIRONMENTAL POLICY ACT: A STUDY OF ITS EFFECTIVENESS AFTER TWENTY-FIVE YEARS 29 (1997) - (noting that prior to NEPA, agency decisions were made without reference to environmental information);
48. Fung & O'Rourke, supra note 33 (detailing the success of the TRI and recommending application of TRI structure to other contexts);
49. Madhu Khanna et al., Toxics Release Information: A Policy Tool for Environmental Protection, 36 J. ENVTL. ECON. & MGMT. 243, 243-45 (1998) (discussing the regulatory effect of the Toxic Release Inventory on industry behavior);
50. Sunstein, supra note 32, at 191-228 (discussing the effects of various informational regimes).
51. Clearly, those who believe that society should prohibit the use of animals for food will not be satisfied with a disclosure regime. They might even conclude that it is counterproductive to their cause if the disclosure regime led consumers to conclude that buying humanely produced meat satisfied all their moral obligations to animals. On the other hand, animal-use abolitionists might embrace a disclosure regime for instrumental reasons if they thought it would cause society to confront the harms suffered by animals and move society closer to an abolitionist perspective.
52. The RSPCA guidelines program began in 1994. See Freedom Food - About Us, http://www.rspca.org.uk/servlet/Satellite?pagename=RSPCA/ RSPCARedirect&pg=About_the_rspca (last visited Feb. 8, 2006).
53. For the RSPCA's substantive guidelines on Chickens, Beef Cattle, Dairy Cattle, Ducks, Laying Hens, Pullets, Pigs, Farmed Atlantic Salmon, Sheep (including Dairy Sheep), and Turkeys, see http://www.rspca.org.uk/ servlet/Satellite?pagename=RSPCA/RSPCARedirect&pg=welfarestandards (last visited Feb. 8, 2006).
54. Humane Farm Animal Care: Animal Care Standards, http://www.certifiedhumane.com/documentation.asp (last visited Jan. 31, 2006) (listing guidelines for Beef Cattle; Broiler Chickens; Egg Laying Hens; Dairy Cows; Dairy, Fiber, and Meat Goats; Pigs; Sheep, including Dairy Sheep; Turkeys; and Young Dairy Beef). All guidelines are available with registration.
55. American Humane Association, Free Farmed Certification Program, http://www.americanhumane.org/freefarmed (last visited Jan. 31, 2006). Animal welfare standards are not available online, but can be requested by calling (303) 792-9900 or by writing American Humane; 63 Inverness Drive East, Englewood, CO 80112.
56. Animal Welfare Institute, http://www.awionline.org/farm/standards.htm (last visited Jan. 31, 2006) (listing Humane Husbandry Criteria for Pigs, Beef Cattle and Calves, Rabbits, Ducks, and Sheep).
57. British Columbia Society for the Prevention of Cruelty to Animals, http://www.spca.bc.ca/farm/standards.asp (last visited Jan. 31, 2006) (listing SPCA Certified Standards for the Raising & Handling of Laying Hens, Broiler Chickens, Beef Cattle, Pigs, and Dairy Cattle).
58. The Royal Society for the Prevention of Cruelty to Animals, supra note 39.
59. For more details on the "Certified Raised and Handled" logo, see Humane Farm Animal Care, http://www.certifiedhumane.com (last visited Jan. 31, 2006).
60. American Humane Association, supra note 41.
61. AMERICAN MEAT INSTITUTE, RECOMMENDED ANIMAL HANDLING GUIDELINES AND AUDIT GUIDE (2005), http://www.animalhandling.org/guidelines/ 2005RecAnimalHandlingGuidelines.pdf.
62. NATIONAL CHICKEN COUNCIL, ANIMAL WELFARE GUIDELINES AND AUDIT CHECKLIST (2005), http://www.nationalchickencouncil.com/files/ AnimalWelfare2005.pdf.
63. NATIONAL PORK BOARD, SWINE WELFARE ASSURANCE PROGRAM MANUAL (2003), http://www.pork.org/Producers/SWAP/swapManual.aspx.
64. UNITED EGG PRODUCERS CERTIFIED, ANIMAL HUSBANDRY GUIDELINES FOR U.S. EGG LAYING FLOCKS (2006), http://www.uepcertified.com/ abouttheprogram.html.
65. Food Marketing Institute, http://www.fmi.org/animal_welfare (last visited Dec. 6, 2006). Guidelines can be requested from Karen Brown at FMI by calling (202) 452-8444.
66. Whole Foods, Animal Compassionate Program, http://www.wholefoodsmarket.com/products/meat-poultry/ qualitystandards.html (last visited Dec. 6, 2006);
67. see also Andrew Martin, Meat Labels Hope to Lure the Sensitive Carnivore, N.Y. TIMES, Oct. 24, 2006, at A1 (describing the Whole Foods program).
68. Swine Welfare Assurance Program, Why a Welfare Assurance Program?, http://www.porkboard.org/SWAPHome (last visited Feb. 1, 2006).
69. AMERICAN MEAT INSTITUTE, supra note 46.
70. See Humane Farm Animal Care: Animal Care Standards, Pigs, supra note 40.
71. See Animal Welfare Institute, supra note 42;
72. NATIONAL PORK BOARD, supra note 48.
73. NATIONAL PORK BOARD, supra note 48.
74. See Animal Welfare Institute, Humane Husbandry Criteria for Pigs, supra note 42.
75. See; e.g., Humane Farm Animal Care: Animal Care Standards, Pigs, supra note 40, at 9 (requiring that farrowing pens be a minimum of 5 ft. × 7 ft., but recommending pens of 10 ft. × 10 ft., with a piglet protection zone of at least 8 sq. ft.).
76. See, e.g., id. at 4 (requiring a minimum flow rate of .75-quarts per minute for drinkers used by lactating sows).
77. For example, the American Meat Institute voted in 2002 to make animal welfare a non-competitive issue in the industry on the theory that this would promote open sharing of ideas, information, and expertise to enhance animal handling and welfare. American Meat Institute, AMI Board Votes to Make Animal Welfare a Non-Competitive Issue: Vote Signifies Industry's Ongoing Commitment to Optimal Animal Handling in Plants (Oct. 24, 2002), http://www.meatami.com/Template.cfm?Section= Archived&template=PressReleaseDisplay.cfm&PressReleaseID=1317.
78. Humane Farm Animal Care, supra note 40.
79. American Humane Association, supra note 41.
80. Certified Humane Certification Program Frequently Asked Questions, http://www.certifiedhumane.org/faq.html (last visited Feb. 1, 2006) (describing the Certified Humane certification process); The Free Farmed Certification Process, http://www.americanhumane.org/site/ PageServer?pagename=pa_farm_animals_ff_cert_process (last visited Feb. 1, 2006) (describing the Free Farmed certification process).
81. See UNITED EGG PRODUCERS CERTIFIED, supra note 49.
82. Requirements of a United Egg Producers Certified Company, http.//www.uepcertified.com/abouttheprogram.html (last visited Feb. 1, 2006). Of 204 applicants for certification, only eleven have failed the first audit. Failed applicants are given sixty days to improve conditions; only one producer has failed a second time. Telephone interview with Gene Gregory, Senior Vice President, United Egg Producers (Oct. 7, 2004).
83. See AMERICAN MEAT INSTITUTE, supra note 46, at 4.
84. Swine Welfare Assurance Program, supra note 52.
85. See Swine Welfare Assurance Program, How do I participate in SWAP as a Producer?, http://www.pork.org/Producers/SWAP/SWAP.aspx (last visited Feb. 1, 2006).
86. See Food Marketing Institute, supra note 50.
87. Food Marketng Institute & The National Council of Chain Restaurants, Food Marketing Institute, The National Council of Chain Restaurants (NCCR) and the Food Marketing Institute (FMI) Announce Certification of First Auditors; Slaughter Plants Can Request Animal Welfare Audits, Apr. 17, 2003, http://www.fmi.org/media/mediatext.cfm?id=522.
88. Telephone interview with Karen Brown, Senior Vice President, Food Marketing Inst. (Noy. 30, 2006).
89. Id.
90. In fact, the Better Business Bureau (BBB) recently recommended that United Egg Producers discontinue its "Animal Care Certified" label on the grounds that it misleads consumers. See Associated Press, Business Group Shells Egg-industry Ads: Better Business Bureau Disputes Humane Claim, May 11, 2004, available at http://www.msnbc.msn.com/id/4951194/ [hereinafter Egg-industry Adsc].
91. The BBB found that the UEP standards actually improved animal treatment, but that industry standards for the treatment of egg-laying hens - which allow for artificially inducing molting through food withdrawal and for trimming or burning off birds' beaks - would not be considered "Humane" by most consumers. See Id.
92. In October 2005, with encouragement from the Federal Trade Commission, the United Egg Producer, agreed to stop using the Animal Care Certified label, and instead agreed to label eggs as "United Egg Producers Certified." See Alexei Barrionuevo, Egg Producers Relent on Industry Seal, N.Y. TIMES, Oct, 4, 2005, at C18.
93. See supra notes 32-37.
94. Labeling food sold in grocery stores is a familiar practice. Applying a labeling system to other food outlets - deli counters, restaurants, hot dog stands, and the like - is imaginable, but considerably more challenging. Should a restaurant have to trace and disclose the practices of each supplier of every kind of meat and other animal product on the menu? How available must the disclosure be? Must it be made part of the menu, or, as is the case with nutritional claims, is it enough to require restaurants to have the information available upon request? See 21 C.F.R. § 101.9(j)(2)(i) (2006). Although the practical difficulties are perhaps greater with non-grocery store food outlets, there are many possibilities for displaying a label or labels that could be effective, including menus, food packaging, and prominently displayed signs.
95. See supra notes 46-52.
96. See supra note 5.
97. See, e.g., Agriculture Online, Survey Shows Consumers Value Humane Treatment of Poultry, Mar. 1, 2004, http://www.agriculture.com/ag/story.jhtml?storyid=/templatedata/ag/ story/data/agNews_51370.xml (finding fifty-four percent of consumers would be willing to spend five to ten percent more for products certified as protective of animal care, and an additional ten percent would be receptive to paying fifteen to twenty percent more);
98. David Dickinson & DeeVon Bailey, Willingness-to-Pay for Information: Experiential Evidence on Product Traceability from the USA, Canada, the U.K., and Japan 12-13 (Utah State Univ. Econ. Research Inst., Working Paper No. 12, 2003), available at http://www.econ.usu.edu/Research/03/ERI2003-12.pdf (showing that consumers are willing to pay four to nine percent more for pork and nine to twenty-eight percent more for beef that carries additional guarantees of humane animal treatment and meat safety);
99. Richard M. Bennett & Ralph J.P. Blaney, Estimating the Benefits of Farm Animal Welfare Legislation Using the Contingent Valuation Method, 29 AGRIC. ECON. 85, 85-98 (2003) (surveying U.K. citizens' willingness to pay to support legislation to phase out the use of battery cages for egg production in the European Union and concluding that the estimated benefits of the legislation outweigh the costs);
100. R.M. Bennett, J. Anderson, & R.J.P. Blaney, Moral Intensity and Willingness to Pay Concerning Farm Animal Welfare Issues and the Implications for Agricultural Policy, 15 J. AGRIC. & ENVTL. ETHICS 187, 193 (2002) (showing that survey participants in the U.K. were willing to pay approximately $1.68 per week more for eggs from chickens raised outside of cages).
101. See Rod Smith, Consumer Views on Animal Production Pushing Toward More Ethical Husbandry, FEEDSTUFFS, Jan. 1. 2001, available at http://www.upc-online.org/010101feedstuffs.html (discussing the industry impact of consumers' preferences for humane treatment of food animals);
102. Swine Welfare Assurance Program, supra note 52 (explaining that increased consumer awareness of animal welfare necessitates proactive industry action).
103. See Consumers Union, The Consumers Union Guide to Environmental Labels, http://www.eco-labels.org/home.cfm (last visited Feb. 1, 2006). Consumers Union provides ratings for some labels but not others.
104. See id. "Certified Humane Raised and Handled" and "Free Farmed" labels are both rated "highly meaningful";
105. the United Egg Producer's logo is not rated at all. See id.
106. See Egg-industry Ads, supra note 73.
107. See supra Part V.
108. The National Chicken Council Guidelines require ammonia levels to be below twenty-five parts per million. NATIONAL CHICKEN COUNCIL, supra note 47.
109. The Humane Farm Animal Care guidelines require that ammonia levels not exceed ten parts per million on average and never exceed twenty-five parts per million. Humane Farm Animal Care: Animal Care Standards, Broiler Chickens, supra note 40, at 7.
110. Litter saturated with urine and excrement leads to high ammonia concentrations, and chickens exposed to unsanitary litter for long periods can suffer blisters and burns on their feet, legs, and breasts, For a summary of research on the health effects of unsanitary litter, see REPORT OF THE SCIENTIFIC COMM. ON ANIMAL HEALTH AND ANIMAL WELFARE, THE WELFARE OF CHICKENS KEPT FOR MEAT PRODUCTION (BROILERS) 39-40 (2000), available at http://europa.eu.int/comm/food/fs/sc/ scah/out39_en.pdf (produced for the European Commission Health & Consumer Protection Directorate-General).
111. For more details on the health and cost effects of poor litter quality management, see CASEY W. RITZ ET AL., LITTER QUALITY AND BROILER PERFORMANCE 1267 (2005), available at http://pubs.caes.uga.edu/caespubs/pubs/PDF/B1267.pdf.
112. The National Chicken Council guidelines provide, among other things, that "[w]henever birds are handled for any reason, including vaccinations, treatments, and movement to new facilities or to processing, handling should be accomplished in such a manner as to avoid injuries. Abuse of the animals should not be tolerated under any circumstances.... The number of birds in the catcher's hand depends on the size of the bird and should not cause injury to the birds. For birds weighing more than four pounds, the maximum number of birds per hand is five." See NATIONAL CHICKEN COUNCIL, supra note 47, at 8.
113. See Christine Jolls & Cass R. Sunstein, Debiasing Through Law, 35 LEGAL STUD. 199 (2006).
114. See, eg., H.L.I. Bornett, J.H. Guy, & P.J. Cain, Impact of Animal Welfare on Costs and Viability of Pig Production in the UK, 16 J. AGRIC. ENTL. ETHICS 163-86 (2003) (comparing profitability of different pig-rearing systems and concluding that pig welfare can be improved significantly with a modest increase in cost, but that the current higher cost for pigs raised in high welfare systems must be maintained if high welfare producers are to continue to be profitable);
115. cf. Dermot J. Hayes & Helen H. Jensen, Lessons from the Danish Ban on Feed-Grade Antibiotics, CTR. FOR AGRIC. AND RURAL DEV., Briefing Paper 03-BP 41 (2003), available at http://www.card.iastate.edu/publications/DBS/PDFFiles/03bp41.pdf. (presenting an economic analysis of the consequences of a ban on antibiotic use in food animals in the United States).
116. E.g., P.H. Hemsworth, G.J. Coleman, J.L. Barnett & S. Borg, Relationships between Human-Animal Interactions and Productivity of Commercial Dairy Cows, 78 J. ANIMAL SCI. 2821, 2821-31 (2000);
117. P.H. Hemsworth, G.J. Coleman, J.L. Barnett, S. Borg & S. Dowling, The Effects of Cognitive Behavioral Intervention on the Attitude and Behavior of Stockpersons and the Behavior and Productivity of Commercial Dairy Cows, 80 J. ANIMAL SCI. 68, 68-78 (2002);
118. P.H. Hemsworth, G.J. Coleman, & J.L. Barnett, Improving the Attitude and Behavior of Stockpersons toward Pigs and the Consequences on the Behavior and Reproductive Performance of Commercial Pigs, 39 APPLIED ANIMAL BEHAV. SCI. 349, 349-62 (1994);
119. B. D. Voisinet, T. Grandin, J.D. Tatum, S.F. O'Connor & J.J. Struthers, Feedlot Cattle with Calm Temperaments Have Higher Average Daily Gains than Cattle with Excitable Temperaments, 75 J. ANIMAL SCI. 892, 892-96 (1997).
120. E.S. Jolly, J.B. Gaughan, & A.K. King, Environmental Enrichment for Neonatal Pigs and its Influence on Post Weaning Aggression, 80 J. ANIMAL SCI. 25, 25-26 (Supp. 1 2002).
121. A. Sevi, M. Albenzio, G. Annicchiarico, M. Caroprese, R. Marino & L Taibi, Effects of Ventilation Regimen on the Welfare and Performance of Lactating Ewes in Summer, 80 J. ANIMMAL SCI. 2349, 2349-61 (2002).
122. L.A. Werth, S.M. Azzam, M.K. Nielsen, & J.E. Kinder, Use of a Simulation Model to Evaluate the Influence of Reproductive Performance and Management Decisions on Net Income in Beef Production, 69 J. ANIMAL SCI. 4710, 4719-21 (1991).
123. C.A. Lunam, A.M. de Passille, & J. Rushen, Neuroma Formation following Tail Docking of Dairy Calves, 80 J. ANIMAL SCI. Supp. 1/85 J. DAIRY SCI. Supp. 1 (2002);
124. C.B. Tucker & D.M. Weary, Tail Docking in Dairy Cattle, 11 ANIMAL WELFARE INFO. CTR. BULLETIN 3-4 (Winter 2001-Spring (2002).