Letter to Senate Committee on Human Rights

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The Standing Senate Committee on Human Rights
Senate, Ottawa, Ontario, Canada, K1A 0A4
June 30, 2021

Dear Senators,

On behalf of members of the advocacy group Evolve Our Prison Farms and the prison population at Joyceville Institution (Minimum), we thank you for your long-anticipated Report on The Human Rights of Federally-Sentenced Persons (June 2021). We appreciate the importance of this report and we wish to address inaccuracies of concern in the section pertaining to the reopening of penitentiary farms.

Your report states that “the committee is encouraged” by the reopening of the penitentiary farms at Joyceville and Collins Bay Institutions in Kingston, Ontario, and recommends the expansion of the program to other institutions (Recommendation 42). Your report fails to acknowledge the problematic realities of the new prison farms, which bear no resemblance to the former farms that were praised by Committee Chair Senator Jim Munson in his opening remarks: “From my perspective, there’s not much to look at. Just get on with, get back to it, because I think it’s an incredible tool to enhance a prisoner’s life and human right to work.”[i]

As we present evidence obtained through investigative research and direct experience, we hope that the Committee will realize that there is nothing about the new prison farms to be encouraged by, and there is, indeed, much to look at.

The price of prison farms

The new prison farms will no longer feed prisoners, as the former farms did. Instead, they will be commercial, competing in the open market. The major enterprise will be an intensive livestock operation with 2200 goats kept in confinement and mechanically milked on automated carousels.[ii] This will take place in a 100,000 square foot facility[iii] alongside a manure lagoon that will be 14 feet deep and 120 feet wide.[iv] The harmful impacts on prisoners, prison staff, and surrounding communities has been thoroughly analyzed and documented.[v] Furthermore, the commercial nature of the operation – associating underpaid prison labour with the private sector – sets a worrying precedent in Canada and constitutes a violation of human rights under the United Nations International Labour Organization’s standards for the use of prison labour.[vi]

According to your citations, only two witnesses spoke about the prison farms. One was Anne Kelly,[vii] Commissioner of the Correctional Service of Canada, whose statements cast a vague and favourable light on their multi-million-dollar investment. We will address her comments in a separate section below (CSC provided false and misleading information to the Committee). The other witness is a former lawyer with the Queen’s Prison Law Clinic, Sean Ellacott,[viii] who prefaced his statements with the disclaimer that he is “not an expert on the farm issue,” yet his comments are treated as authoritative despite being speculative in nature.

This witness claimed that the farm at Collins Bay, as he understood it, was “probably the most financially rewarding farm.” At best, the farm at Collins Bay could be described as the least financially draining. Each of the two prison farms in Kingston operated at a financial loss. In the last full year of operations (2009-2010), the farm at Collins Bay had a net loss of $319,000 and the farm at Joyceville had a net loss of $473,000.[ix] The public perception that the farms were financially successful is based on nostalgic narrative and hearsay, rather than fact.

It is also worth noting that the majority of revenues from the Joyceville farm were derived from the abattoir ($521,000 in the last fiscal year).[x] Without the abattoir revenues, the farm’s annual net loss would have been significantly greater, to the tune of $1 million.

Your report correctly states that the February 2018 federal budget allocated $4.3 million to reopen prison farms in Kingston, to be spent over a five year period. Internal documents show that CSC will invest an additional $9.75 million towards infrastructure costs for the milking facility.[xi] According to CSC spokesperson Kyle Lawlor,[xii] within three years of project implementation CSC has invested $6.6 million despite no new barn construction, no acquisition of goats, and no acquisition of dairy equipment except for two bulk coolers capable of storing a daily production of 9000 litres of goat milk (this volume would require over 3000 goats in active milking) and 1800 litres of cow milk (60 cows).[xiii]

The goat milk will be for commercial sale. Although CSC has not yet signed any contracts, it is widely reported that the milk is destined for the new Chinese state-controlled infant formula factory in Kingston for processing and export to China. This has been confirmed by CSC’s farm manager,[xiv] the chair of CSC’s Prison Farm Advisory Panel,[xv] Kingston MP Mark Gerretsen,[xvi] the President of Ontario Goat,[xvii] and more than 20 media reports since 2018.[xviii]

The cow milk will be for research quota, not for market sale and not for consumption.[xix] This is due to Canada’s supply management controls for cow dairy. The former prison farms were exempted from quota on the condition that the products be used for internal purposes only and never sold.[xx] After the former farms were phased out, CSC phased in its Food Service Modernization, the centralized “cook-chill” model that is heavily criticized in your report. You correctly connect the prison farm closures with the shift towards industrial food service and you decry how the elimination of prison farms denied prisoners access to fresh food, yet you express no concern that the new prison farms in no way restore access to fresh food.

The former prison farms operated at a financial loss yet they had value in producing fresh food for prisons. The new prison farms are costlier by multiple magnitudes and have eliminated the essential value. We respectfully ask if this is something to be encouraged by.

Prison farms do not necessarily improve employment potential

Mr. Ellacott vaguely cites the “intrinsic benefits” of the former farms including “job training benefits,” yet research finds no measurable employability benefits associated with the former dairy and beef operations.[xxi] CSC never tracked the impact of farm work on employment or recidivism,[xxii] and in fact argued against it: “For those people who leave our facilities to seek employment, the agricultural sector is not a viable, realistic market.”[xxiii] According to CSC media lines, the farms were closed because they did not “reflect the labour market demands of today and of the future” or the “realities offenders are facing in today’s urban labour market.”[xxiv]

CSC’s report on the feasibility forums explicitly states that public perceptions on the benefits of the former prison farms “were opinions, based on personal observation and heartfelt beliefs and not upon any rigorous analysis of the actual impact of penitentiary farm programs on either rehabilitation or employability post release.”[xxv] Simply put, there is no empirical evidence showing the employment potential or rehabilitative value of prison farms.

That said, we affirm the testimonies of individuals whose personal experiences on the former farms were transformative. Some have said that it saved their life and taught them empathy, particularly through bonding with the cows. The former farm staff were also held in high regard as mentors who established relationships of mutual trust and collaboration between incarcerated farm workers and community partners. When the former farms were closed, we know from anecdote and personal experience that many tears were shed as farm workers loaded the cows onto trucks.

Prison farm experiences were not universally positive

Mr. Ellacott summarily states: “I never heard anything [about the prison farms] that wasn’t glowing.” The accounts of former prison farm workers and former correctional staff are not exclusively positive. We have heard the glowing stories as well as the darker ones documented in books, research, and interviews. For example:

Former prison farm worker 1: “When I had to go in and take a baby calf away from her mother, I was putting my life at risk, because them cows were wanting to kill me when I would go in and try to take the calf. They knew what we were doing, and they were going to do whatever was in their power to stop that. So I mean that affected me. Of course it affected me. It was like, whoa man, what am I doing here? They would cry, the mother and the baby would be talking to each other, and it’s – oh my God. And you know that hurt, that affected me.”[xxvi]

Former prison farm worker 2: “It wasn’t easy to adjust to being around cows. I’d been on milking duty a couple of weeks when one of the cows stepped on my foot. I began to hit it with punches like a professional boxer. The next day, another cow crushed me against a railing and I rolled a series of punches on its side and on its head. After a few days of this, the cows would moo and prance around nervously when I came into the barn, making it harder to milk them. One day, a cow coughed when I was behind it. Green shit flew out of her ass and all over my face. I tore into that cow with my fists. My immediate job, however, was preparing cows for slaughter. It was my job to decide which seven cows would end up on death row on any given day.”[xxvii]

Retired correctional officer: “I personally know of a case where a farm worker at Frontenac was caught by his peers having sex with a cow. He was placed in segregation at CBI – since no minimum-security institutions have their own Segregation Unit – and other offenders were either amused or disgusted, and were bellowing ‘mooooooo…’ at him for days. Just awful all the way around.”[xxviii]

One former prison farm worker has warned the media and the Correctional Service of Canada that animal abuse occurred in the past and will occur again, particularly given the size and number of goats.[xxix] He explains: “A cow is an intimidating animal because of its size and its nature. It’s an intimidating animal. A little goat, cute little cuddly goat, is not a very intimidating animal. So right there you’re opening the door for guys that are having a bad day and they’re going to lash out at these animals. If you lash out at a cow you’re taking your life into your own hands. If you lash out at a goat, there’s no fear factor to keep you from smashing a goat, where there was with a cow.”[xxx]

CSC provided false and misleading information to the Committee

In 2019, following the publication of the Senate Committee’s Interim Report, Evolve Our Prison Farms met with Senator Yvonne Boyer and Senator Kim Pate to alert the Committee to the issues and concerns outlined in this letter. Specifically, we discussed the human rights violations associated with the new commercial-industrial farming model, and the ethical violations associated with the exploitation of prisoners in the Joyceville abattoir performing work that is documented as being traumatic[xxxi] and criminogenic.[xxxii]

Senator Boyer was alarmed to learn that CSC exposes prisoners to work that is known to increase risk of substance abuse, PTSD, emotional desensitization, unemployment, violent crime, and domestic violence.[xxxiii]

Following these meetings, the Committee issued follow-up questions to CSC, including: “Are federally-sentenced persons involved in the slaughtering of animals?”

Our concerns and evidence did not enter into your report but CSC’s response did: “CSC does not slaughter animals. The abattoir located at Joyceville Institution is leased to a private business which operates this facility. A small number of inmates are involved in an industry training program working at the location. They are registered with the Ontario Ministry of Trades and are earning hours toward a retail meat cutter apprenticeship.”

The statement “CSC does not slaughter animals” is false. The Joyceville abattoir is owned by CSC, managed by CORCAN, and leased to private company Wallace Beef since 1995.[xxxiv] The profit-sharing relationship sees CSC provide a labour force of prisoners to work in the abattoir, earning $3 per hour.[xxxv] Wallace Beef staff use a bolt gun to stun the animals and inmates use knives to bleed out and butcher the animals.[xxxvi] If CSC does not slaughter animals, then who does? The facts are plain: CSC owns an abattoir where prisoners slaughter and butcher animals.

It is worth noting that although CORCAN pays inmates $3.00 per hour for the abattoir work, CSC invoices Wallace Beef at minimum wage ($12.88) plus a training fee ($4.52) per offender hour worked, in addition to an annual leasing fee of $61,245.00 and $70,962.00 in annual utilities and property taxes, and CSC also receives $8.00 per animal processed.[xxxvii]

CSC justifies this by labelling it an “industry training program.” Our research, including some 1000 documents obtained through Access to Information covering two decades of abattoir records, in addition to multiple inquiries with CSC’s media department and interviews with inmates at Joyceville, finds no evidence to support the Commissioner’s claim that inmates at the abattoir are registered with the Ontario Ministry of Trades earning hours toward a retail meat cutter apprenticeship.

When pressed for comment on what vocational certification or other accreditation has been received by inmates in the abattoir, CSC’s media department issued the statement: “As with all programs that develop and improve essential workplace skills, offenders assigned to the abattoir acquire on-the-job training and orientation to the required technical skills. If the offenders do not already possess the necessary vocational certifications, they are provided with Workplace Hazardous Materials Information System (WHMIS), Safety with Power Tools and Workplace Safety Orientation. Since 2017-18, there have been 78 vocational certifications of this nature issued during actual employment assignment at the abattoir.”[xxxviii]

According to inmates, the WHMIS and Safety certifications are required for all work placements.

When pressed on the claim about apprenticeships with the Ontario Ministry of Trades (note that there is no “Ontario Ministry of Trades” – we presume that CSC is referring to the Ontario College of Trades or the Ministry of Training, Colleges and Universities), CSC vaguely states that “Participation in apprenticeships through the abattoir is available for eligible offenders.”[xxxix]

According to inmates at Joyceville, no one has any knowledge of any abattoir worker earning an apprenticeship or receiving any form of vocational certification beyond the above-named certifications required for any work placement within CSC.

The concerns brought to the attention of Senators Boyer and Pate in 2019 were sufficient to warrant a follow-up with CSC on these matters, yet you excluded the evidence of psychological harm in slaughter work from your report and included CSC’s statement that fosters the illusion that inmates (and CSC) do not slaughter animals. It is discouraging to think that had we not brought this matter to the attention of our Senators, CSC would not have been given an opportunity to set this false claim on the record.

On the matter of the abattoir, the Committee should be aware that the records obtained through Access to Information reveal a long history of legal, institutional, and regulatory violations. Over the years, these violations include (to name a few): improper slaughter; improper meat handling; improper blood disposal; disrepair; money laundering; contraband smuggling; drug use; prisoners working unsupervised; prisoners being unable to quit; CSC rushing psychological assessments (then discontinuing them) to meet financial targets; CSC breaking protocol to allow inmates convicted of knife offences; CSC breaking protocol to allow inmates to work unsupervised and outside of approved hours to avoid hiring outside contract work; a period of license suspension due to investigations by federal and provincial authorities including OMAFRA, the Ontario Provincial Police, and CSC’s Joint Forces Investigative Unit (Pen Squad); a period in which the abattoir was operating without a contract; and a period in which Wallace Beef paid inmates in meat in lieu of incentive pay.

Staff at Joyceville have attempted to terminate the contract with Wallace Beef multiple times since 1997: “The issues present are insurmountable [and] vary between those of institutional security, statutory and legal, business and ethical.” However, the abattoir has been protected due to “political implications” by the Ministry of Public Safety under pressure from beef and dairy industry lobbies.[xl]

Given the seriousness of the issues, we question why your report casts a fictional and favourable light on this abattoir. We also question why the abattoir was mentioned at all if the purpose was not to expose the human rights violations.

This month (June 2021), inmates at Joyceville informed us that they will collectively refuse to work at the abattoir. If they face consequences for this refusal, we hope that our Senators will come to their defense.

What do prisoners have to say?

In 2017-2018, Evolve Our Prison Farms surveyed the prison population at Joyceville to determine their interest in dairy operations versus plant-based agriculture. Over 150 responses were received, 75% of which expressed preference for plant-based agriculture. Multiple respondents added a handwritten comment expressing that they do not want slaughter to be a component of prison farms.

In 2021, equipped with more detailed knowledge of the new prison farm model, Evolve Our Prison Farms issued a second feedback form to Inmate Committees at all federal institutions in Canada. To date, we have received 35 responses from 11 different institutions, including three Inmate Committees responding on behalf of the population. 94% of respondents indicate that they do not believe the new prison farm model has the best interests of prisoners in mind.

Evolve Our Prison Farms has corresponded with hundreds of prisoners, conducted in-person visits and interviews at multiple institutions, and collaborated with several formerly incarcerated men and women, including a former prison farm worker. Their voices are of paramount importance.

The Senate Committee’s follow-up with CSC questioned whether prisoners had been consulted on the redesigned prison farms. CSC responded: “The Inmate Committees at Joyceville Institution and Collins Bay Institution were kept apprised of the consultations… In addition, a former offender from the farming program was consulted and continues to be a resource that CSC can access as implementation planning is ongoing.”

What CSC’s statement omits is the fact that the Inmate Committees at Joyceville and Collins Bay do not support the new prison farm model and they are upset that they have not been included in the planning process.

Further, as we informed Senators Boyer and Pate in 2019, the “former offender” that CSC referenced is Shaun Shannon, once a spokesperson for the movement to restore prison farms. Mr. Shannon stated in a recorded interview that CSC consulted him on multiple occasions and each time he told them in no uncertain terms that “the goat plan will never work” but he “might as well have been speaking to a wall.”[xli]

All things considered, you can imagine our distress at the pattern of false information and misleading statements issued by CSC that so far have been successful at controlling public perceptions towards the prison farms, keeping prisoners’ voices silent, and even manipulating the Senate Committee on Human Rights to overlook the egregious violation of human rights associated with the new prison farms and the Joyceville abattoir.

Conclusion and recommendations

Without critically assessing the prison farms and abattoir through a human rights lens, why did the Committee choose to comment at all on these matters in a report on human rights? It is our contention that the Committee should have refrained from including this section in its current form, which only serves to promote the exploitation of prisoners in slaughter work for a private company and to promote the expansion of prison labour for the private sector via the new commercial prison farm model.

We have been informed that the content of your report was limited to the witness testimonies. This procedural limitation does not excuse the absence of any experts called to testify on these matters. Notwithstanding, the Committee should have independently known that it is a violation of human rights under the United Nations for prison labour to be associated with the private sector unless it meets specific conditions including voluntariness (freedom from coercion or fear of penalty) and working conditions and wages equivalent to free workers. These conditions, as you are aware, are not met in Canada, yet your report acknowledges the commercial nature of the new prison farms and recommends their expansion. This report is endorsing a human rights violation.

Had the Committee consulted experts and Inmate Committees at the institutions where the new prison farms are being established, it is likely that a different approach would have been taken to Recommendation 42. Our suggestions for an amended Recommendation include:

  • Recommend an allowance within CSC’s Food Service Modernization for any restored prison farms to be permitted to supply food for internal use in prisons.
  • Recommend an immediate halt to the introduction of commercial prison farms selling to private companies and competing in the open market.
  • Recommend that prison farms adhere to a non-profit mandate and social justice purpose.
  • Recommend that CSC not renew its contract with Wallace Beef in September 2021.
  • Recommend the permanent closure of the Joyceville Institution abattoir.
  • Recommend that animals not be incorporated in prison programming except under a recognized model of animal-assisted therapy.
  • Recommend that prison farms produce healthful foods to feed prisoners and food-insecure communities, forming a network of food security across Canada.
  • Recommend the re-introduction of incentive pay for CORCAN jobs where goods are produced for internal use.
  • Recommend that any prison labour associated with the private sector adhere to standards set by the United Nations International Labour Organization, providing working conditions and pay equivalent to free workers.

Without having had an opportunity to provide witness testimony to the Committee, we are doing so here in the form of this written response. We ask that the problems identified in this letter be resolved by adjusting your recommendations in a revised or supplemental report. We also hope that you will share our conviction that these very serious issues merit full inquiry into the prison farms and the Joyceville abattoir, as well as the false and misleading statements made by the Correctional Service of Canada to our respected Senators.

Working together, we can bring about much-needed change for the better. We look forward to receiving your response to the issues, evidence, and recommendations presented in this letter.


Calvin Neufeld                                               Kevin Belanger
Founder                                                          Former Chairman (2018-2021)
Evolve Our Prison Farms                            Joyceville Institution (Min) Inmate Committee

Sent to:

Senator Salma Ataullahjan
Senator Wanda Thomas Bernard
Senator Nancy Hartling
Senator Yvonne Boyer
Senator Yonah Martin
Senator Marie-Françoise Mégie
Senator Thanh Hai Ngo
Senator Kim Pate
Senator Scott Tannas
Senator Marc Gold
Senator Donald Plett
CSC Commissioner Anne Kelly
Minister of Public Safety Bill Blair
Correctional Investigator Ivan Zinger

[i] RIDR, Evidence, 15 May 2017.
[ii] Correctional Service of Canada (2019). Nutrient Management Strategy. Prepared by Eastern Crop Doctor Inc. Retrieved by Evolve Our Prison Farms through Access to Information request.
[iii] Impact Assessment Agency of Canada (2021). Joyceville Institution Cattle and Goat Barn Construction.
[iv] Correctional Service of Canada (2019).
[v] Fitzgerald, A. J., Wilson, A., Bruce, J., Wurdemann-Stam, A., & Neufeld, C. (2021, January 31). Canada’s proposed prison farm program: Why it won’t work and what would work better. Evolve Our Prison Farms.
[vi] Queen’s Business Law Clinic (2020). Legal Issues Arising from the Export of Prison-Sourced Infant Formula. Prepared for Evolve Our Prison Farms.
[vii] RIDR, Evidence, 27 February 2019.
[viii] RIDR, Evidence, 15 May 2017.
[ix] Correctional Service of Canada (2017, February 15). Briefing Note to the Minister of Public Safety and Emergency Preparedness. Retrieved by Evolve Our Prison Farms through Access to Information request.
[x] Ibid
[xi] Inquiry of Ministry, Q-1781, by MP Scott Reid (Lanark-Frontenac-Kingston) (2018, May 23). Retrieved by Evolve Our Prison Farms through Access to Information request.
[xii] Email dated 22 January 2021.
[xiii] Public Works and Government Services Canada (2018, December 17). Solicitation Amendment.
[xiv] Atkinson, S. (2019, March 26). New prison farm structure taking shape. Ontario Farmer.
[xv] MacAlpine, I. (2018, June 21). Prison farms to include dairy, goat operations. Kingston Whig-Standard.
[xvi] Allan, M. (2019, June 11). Vigils for ethical prison farms to be held outside Collins Bay Institution. Kingstonist.
[xvii] Green, J. (2021, March 3). Former inmate, President of Ontario Goat, question ‘Prison Farm’ logic. Frontenac News.
[xviii] Prison Farms & Feihe Connection. Evolve Our Prison Farms.
[xix] Prison Farm Advisory Panel Meeting Minutes (2018, July). Retrieved by Evolve Our Prison Farms through Access to Information request.
[xx] Briefing note to the Commissioner (2016, December 16). Retrieved by Evolve Our Prison Farms through Access to Information request.
[xxi] Struthers Montford, K. (2019). Land, Agriculture, and the Carceral: The Territorializing Function of Penitentiary Farms. Radical Philosophy Review.
[xxii] Correctional Service of Canada (2008, June). Employment Strategy: Institutional Component.
[xxiii] Ross Toller, Regional Deputy Commissioner of Ontario, Correctional Service Canada (2010, March 25). Statement to the Standing Committee on Public Safety and National Security.
[xxiv] Correctional Service of Canada Media Lines (2011, July 19). Retrieved by Evolve Our Prison Farms through Access to Information request.
[xxv] Correctional Service of Canada (2016, September 19). Report on the Town Hall Meeting on the feasibility of re-establishing penitentiary farms at the Joyceville and Collins Bay Institutions. Prepared by Monachus Consulting.
[xxvi] Evolve Our Prison Farms (2020, February 6). Prison Farm (R)evolution Videoconference.
[xxvii] Atkinson, Richard. The Life Crimes and Hard Times of Ricky Atkinson: Leader of the Dirty Tricks Gang. Exile Editions (2017).
[xxviii] Email to Evolve Our Prison Farms, 2018.
[xxix] Cumming, I. (2020, August 11). Former prisoner has reservations about current project: Shaun Shannon was formerly in charge of the Kingston prison farm’s dairy herd. Ontario Farmer.
[xxx] Evolve Our Prison Farms (2019, July 26). Ex-Prison Farm Worker Interview.
[xxxi] Lebwohl, M. (2016, January 25). A Call to Action: Psychological Harm in Slaughterhouse Workers. Yale Global Health Review.
[xxxii] Fitzgerald, A. (2012). Doing time in slaughterhouses: A green criminological commentary on slaughterhouse work programs for prison inmates. Journal of Critical Animal Studies.
[xxxiii] Fitzgerald, A., Kalof, L., & Dietz, T. (2009, June). Slaughterhouses and Increased Crime Rates: An Empirical Analysis of the Spillover from “The Jungle” into the Surrounding Community. Organization and Environment.
[xxxiv] CSC statement to Evolve Our Prison Farms, 21 May 2021.
[xxxv] Records retrieved by Evolve Our Prison Farms through Access to Information request.
[xxxvi] Statements from multiple sources including former chairman of the Joyceville Inmate Committee.
[xxxvii] Records retrieved by Evolve Our Prison Farms through Access to Information request.
[xxxviii] CSC statement to Evolve Our Prison Farms, 25 May 2021.
[xxxix] Ibid
[xl] Records retrieved by Evolve Our Prison Farms through Access to Information request.
[xli] Evolve Our Prison Farms (2019, July 26). Ex-Prison Farm Worker Interview.