Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1480 Tip Top Poultry, lnc, JBAO521114 49NOV2020 Open On November 17, 2020 at approximately 2125 hours as |
519G was conducting “Poultry Good Commercial Practices”

task, |G) observed multiple birds on the
production kill ine that appeared to have a very small nick
on the neck area of the birds and was not bleeding
properly as well as eyes still open and looking around and
very much conscious. After observing multiple birds of this
nature within three minutes, | notified the [if
at approximately 2128 hours.
(vel arrived, | askeclMWto stand and watch
the conditions of the birds prior to the scalding tank.
witnessed birds with very small nicks and have not
bled out entering the scalder tank. | then asked, “What was
the cause of this issue?" | proceeded to inquire if this was
a mechanical or a human issue that could be adjusted. The
maintenance department then came to see what the issue
could have been and while all four of us (1 USDA.
Inspector, 1 Live dock Supervisor, and 2 Maintenance
men) was standing in the picking room we observed more
birds that were not cut at all on the neck area as well as
birds that may have had a small nick that made it look as
thought the bird neck wasn’t cut at all, |,
and multiple plant membt total
of 12 birds that were removed from the kill line within 30
minutes. The kill ine was stopped, and birds were removed
from the line every time this was observed while both the
Live Dock department as well as the Maintenance
department tried to rectify this issue. 9 CFR 381.65(b)
states, “Poultry must be slaughtered in accordance with
good commercial practices in a manner that will result in
thorough bleeding of the carcasses and ensure that
breathing has stopped prior to scalding. Blood from the
killing operation must be confined to a relatively small
area.” FSIS Directive 6110.1 states, “If birds hung on the
slaughter line die before slaughter because of mishandling,
or if birds are being killed in a manner that does not
comply with GCP as defined in 9 CFR 381.65(b), the
resultant product is adulterated under the PPIA. This
includes the treatment of all birds brought onto the official
premises of a slaughter plant, not just those entering
production. IPP are to issue an NR for noncompliance with
9 CFR 381.65(b) (failure to handle the birds in accordance
with GCP) when an ongoing pattern or trend develops
where birds are not being slaughtered in a manner that
results in thorough bleeding of the carcasses, that results
in birds entering the scalder before their breathing has
stopped, or that otherwise involves their being handled ina

systematic way that results in their d ethan by
slaughter.” Ifithad not been for me [toy 1)
stopping the kill ine some of the birds would Have entered

the scalder tank, alive and stil breathing. No preventive
measure has been given from the establishment to prevent

20


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P51179+V51
179

Sanderson Farms, Inc.

RQE4420123
017G

17DEC2020,

04C05

Poultry Good
Commercial
Practices

Finalized

Est. P-51179 at Sanderson Farms, Palestine, Texas at
2100 hours in December 15, 2020 . In attendance are the

id
(b)(6)

At approximately 2025 hour Sth of December 2020, |,
Relief (bye) GL observed the following:
Picker Line for Evis Line 3 and 4 broke down and stopped
Tunning at approximately 2012 hours. [ndeyey_____]
nolified me at 2024 hours about the line break down.
immediately checked the scalder and found all 31 young
chicken dead, cyanotic and immobile. Their beak or head
are under water despite the establishment's claim that the
water trough of the stunner has been dropped. The young
chicken between the automatic kill machine and past the
stunner water are all alive. Regulatory Control Action is not
applied because the establishment decided to terminate the
operation of the aforementioned line. {n 30th of October
2020, (foy6) wrote an MOI on the same

i joung chicken to remain in the stunner
which has not been drained or lowered during line

stoppage for an extended period of time which resulted to
drowning. (reminded (BG)
that the PPIA and Agency regulations require that live
poultry be handled in a manner that is consistent with good
commercial practices and that they not die from causes
other than slaughter. | also recommende((B)(®)

to review Federal Register Notice Vol. 70, No.
187, published September 2005 [Docket No. 04-037N] for
FSIS recommendations concerning treatment of live
poultry before slaughter. | also told him that an MOI will
be forwarded to the District Office and the District
Veterinary Medical Specialist (DVMS) in case additional
follow-up is recommended. Respectfully, [da] [>\6)
USDA Relief SPHY at P-51179: Sanderson

Farms at Palestine, Texas.

PS17

Mar-Jac Poultry-MS

Q005402115
227G

27NOV2020

04c05

Poultry Good
Commercial
Practices

Finalized

|

NTS) Mar-Jac Poultry, MS
1301 James Street Hattiesburg, MS 30401 [afioy@) |. At
approximately 2130 hours on November 26, 2020, the
following less than Good Commercial Practices (GCP)
incident was observed at Mar-Jac Poultry in Hattiesburg,
MS. On two sequential dumps, [f5y(@)

observed a cage of birds emptieto aS ST WETE
already on the conveyor belt for the South picking line.
This resulted in multiple incidents of a pile of live birds at
Jeast two birds deep on the conveyor belt with many birds
completely covered.
(== Iwas verbally notified of the incident at
approximately 2135 hours. Respectfully, [da]
(eye) Hattiesburg, MS 39401
i —— I

41


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P510 House Of Raeford Farms RHB4811114 23NOV2020 | 04C05 | PoultryGood | Finalized | Ms. Nicole Reynolds, Plant Manager, P-510 House of
123G Commercial Raeford Rose Hill, NC 28458 Ms. Reynolds At
Practices approximately 1116 while performing the Good Commercial

Practices Verification task, | observed a live bird about to
enter the scalder. The bird at the time of my observation
had normal rhythmic breathing, eyes open and blinking
with the head elevated. | immediately pointed out the bird to
teal foyer —_t Jwho stopped
the line before the bird could enter the scalder and had the
bird removed from the line. After removing the bird from
the line, it was observed that there was a small shallow cut
on the neck hie would not have allowed ee bird to bleed
out properly. [ial faye) I gave the bird to exer]
[oxehy6) UF) who took the bird back to live
hang to show itto the backup cutter. [ay [610] performed
cervical disarticulation on the bird and made a deep cut on
the neck to allow proper bleeding. [ail [m7] then hung the
bird back on the line at the end of the bleed tank. [ll
eye), instructed the
backup cutter to pay more attention to birds that might
need a deeper cut,_| discussed my finding with Mail oy]
(eal aT and Ef y6)
per }otifying them of the pending MOT and the
establishment's failure to comply with 9 CFR 381.65 (b)
which states: Poultry must be slaughtered in accordance
with good commercial practices in a manner that will result
in thorough bleeding of the carcasses and ensure that
breathing has stopped prior to scalding. [ia] fower___]
IC, was also notified my findings. There was a similar
occurrence documented on 10/1/20 on MO!
RHB0006100401G. Ms.. Reynolds this MO! will be
forwarded to the District Veterinary Medical Specialist
(DVMS) in case additional follow-up is recommended.

\fyou have any questions or concerns regarding the
y' west ering
Respect,

37


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P6164A Foster Farms 0149151110 OGNOV2020 | 04C05 | PoultryGood | Finalized | On November 6, 2020, at approximately 1322 hrs, while
06G Commercial conducting a routine Good Commercial Practices (GCP)

Practices verification inspection, |, [al fay(6)

IIC/SPHV of P6164A, observed an

animal mistreatment event not consistent with GCPs. This
establishment employs a series of five hurdles of
intervention to assure birds do not die by methods other
than humane slaughter, specifically, an automated
neck-cutter, a back-up manual neck-cutter, two static neck
pulling devices, and on occasion, a manual head-puller.
The manual head-puller is tasked to attend birds that have
passed the fourth hurdle with their heads intact. On this
occasion, as | approached the manual head-pulling station,
l observed the employee repeatedly and

ineffectively pulling at the head of a live bird that had
travelled past the last hurdle and was approaching the last
tum before the line descended into the boiling water
scalding tanks. The bird was alive and alert, blinking and
looking around while lifting its head and working its beak in
between pulls by the employee. When the bird descended
into the boiling tanks of scalding water | observed no marks

of any throat cut. | immedi: notified (b)(6)
fens) ee al aceTihe
employee and accompanied me to the outlet of the

feather-pickers. [EY6)

soon joined us. Approximately five minutes later the bird
appeared, head intact and body only partially
exsanguinated. Examination revealed no neck cut, but
only a small nick on the back of its head and blunt trauma
tothe beak. The latter pathology appeared to be
post-mortem. [ii] stated that the employee was
newly hired and would be retrained. | expressed concern
for the safety of employees attempting to pull heads off of
live birds hanging on moving steel shackles, destined within
seconds of entering a boiling water bath.
replied that proper procedure directs that the employee
should not attempt to pull the head off; rather, he should
stop the line so that the head could be cut off humanely. |
stated that that was not my understanding of the station;
rather, in the several years in which | have observed the
head-puller employee, the employee pulled the heads, had
no knife, and never once stopped the line-indeed, the line
stop button was inaccessible in the other room. | asked
TEL the other hurdles would be examined for
possible contributing issues. [biimvar] replied that the
other interventions had already recently been verified so
that no corrective action was indicated. The next business
day, however, | observed the line stop button had been
moved to an accessible location in the same room. This
MOI reminds establishment that the PPIA and Agency
regulations require that live poultry be handled in a manner
that is consistent with good commercial practices and that



Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1137 Tyson Foods, Inc. ¥BO3721125 23DEC2020 04C05 | PoultryGood | Finalized | On Wednesday 12/23/2020 at approximately 1651 hours,
523G Commercial while performing a Good Commercial Practice Verification
Practices task in the kill room, Eo] [5Y6) observed a live

chicken travel past the automatic knife, as well as the
back-up cutter, on line #1 without the neck being cut. This
chicken then entered the scalder alive. At 1659 hours the
erved at the auto transfer station, line #1.
b)(6) OGM Was instructed to
remove the cadaver from the line. The bird was
immediately presented to {B)(6)
to show that no cut was present on the neck. This cadaver
was then condemned, by due to adulteration.
This type of situation presents concem for inspection
personnel as regulations require that live poultry do not die
from causes other than slaughter. GENEL “I went back
to the kill room and observed the automatic knife and back
up cutter on the affected line for the next twenty minutes.
During this time, no more deficiencies as described in this
MOI were observed. Tyson Management has noted in the
past that they take humane handling of animals seriously.
(eX6) _|stated that he will make sure to meet with the
Back-Up cutter for a refresher training course on humane
handling of poultry. This MO! will be forwarded to the
District Office and the District Veterinary Medical
Specialist (DVMS) in case additional follow-up is needed.
fore) _|kexe._— Toney

4


Table: Noncompliance Reports in Response to FOIA2021-118 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
P45910 SANDERSON | {C8D66A28-43B | GRIS5520 10/12/2020 | 04C05 | Poultry Good 381.65(b) At approximately 2130 hours while conducting a Poultry CLOSED
FARMS, INC D-4FC5-AE2B-7_ | 104912N Commercial Good Commercial Practice task, [ud {o)(6), and
CDA67F640D1} | =1 Practices myself. Eo] ‘observed the following non

compliance: At the end of the live hang belt was a large pile
of feathers, dander, and debris piled from the floor to the
top of the live hang belt. There were several birds under the
line and along the back wall of live hang opposite the live
hang door from the picking room. There were DOAs and
live birds scattered throughout the floor. When | confronted
(nie) Srvar Tver Jof the
large pile of feathers he began to rake the pile with his
hands towards the floor drain. It was at that point that he
uncovered a live bird, buried under approximately 6-7
inches of wet feathers and debris. As he dug further he
uncovered several more birds that were already dead. |
could not determine if the birds were DOAs or were alive
and died due to suffocation from the large pile of feathers.
A minute or two later First Processing Superintendent,
came to see what the issue was. | informed
him that there was a live bird that was buried under the pile
of feathers and that this was a GCP noncompliance. A
similar occurrence .d approximately 2 weeks ago of
the same issue. stated that he would make sure
to keep the pile up under control to prevent a further
occurrence. | waited until approximately 2145 to verify that
Jand [al [b\(6)} cleaned the pile up and
disposed of the remaining DOA birds before | left Live
Hang, |also notified [ail ex eyey

[oy6)_ pf the noncompliance, who had come tnt 1Ve
hang during my observation of the cleanup.

5


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Task

Date Code | TaskName Status

MO! Agenda

P7342+V734
2

Wayne Farms LLC

$CJ2405102
105G

050CT2020 | 04C05 | Poultry Good Finalized
Commercial

Practices

P7487

Koch Foods, LLC

SPG5423113
030G

30NOV2020 | 04C05 | Poultry Good
Commercial

Practices

Finalized

October 4th, 2020. Tonight, during my evening Good
Commercial Practices walkthrough at approximately 0330,
on fine 1, ! saw a bird riding on the top of the shackles. It
was not stunned and had no signs of being bled. It was
ooking around, bright, and alert. | observed the live bird go
into the scald tank. _| notified a maintenance man, who

went and got bott{inWay
and| ala lalso sent forfay(6
}

ha Tavar

VOT ind [a als
responded and were notified. | notified
that | was writing a GCP MOI.

On 11/30/2020, 3rd shift at P-7487 Koch Foods, while
performing a routine Good Commercial Practices
Verification Task, \{PXG)_—===SS~SCsépbserved 2
birds enter the scalder alive around 23-TT on theliI@E ine.
Shortly after the first bird went alive and uncut into the
scalder favay arrived and
observed the second bird go into the scalder alive and
uncut. ZalffaiCbhnd | continued to observe the line, and
observed several birds get past the back-up cutter uncut.
The plant stopped the line each time and allowed the
back-up cutter to cut them and restarted the line. The
establishment placed an additional plant employee after the
back-up cutter to watch for misses as well as a mechanic
on thefff¥@lline to observe and watch for live birds. |
informed [ail [x] that | would be issuing a GCP MOI to
document these events. | made a follow-up check to see
that corrective measures were effectively implemented. |
observed for 15 minutes after the plant break and did not
see any live birds enter the scalder.

P7487

Koch Foods, LLC

SPGS5101115
930G

30NOV2020 | 04C05 | Poultry Good
Commercial

Practices

Finalized

On 3rd shift November 29, 2020 at P-7487, as a follow up
to previous GCP violation |
performed a follow up directed Good Commercial
Verification Task. At approximately 02:23, while observing
birds entering the scalder on the ine | observed 3
birds enter the scalder alive with necks uncut. They were
holding their heads up and blinking their eyes | notified
fer the my findings and that | would be issuin
an additional GCP MOI, documenting these events.
G@azBiated that he would place someone on both lines as. a
back-up head puller.

56


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P72

Tyson Foods, Inc

JPJ2721103
106G

060CT2020

Finalized

On 10-06-2020, at approximately 2100 hours, while
performing a GCP task on Killing/Stunning, A Line had 14
birds missed by killing machine. The establishment's
program and limits for birds being missed by kill machine
are less than or equal to 10 per 500 birds. | notified
Bey of my findings.
At approximately 2205 hours, | performed a test for B
Line. Eight birds were missed by kill machine; however, 3
birds were hung by one leg. The establishment's program
and limits for birds hung by one leg is 0. | informed
Swain of my findings, Atapnroximately 2109 hours, while
Ia Tend LoIKONS) were adjusting the kill machine
on A Line, a bird on B Line had one leg hung in two
shackles with another bird hung on top. This caused the
bird huna on top to be missed by the kill machine. When
[el[©X©) Jreturned, | notified him of this finding.
‘Swain informed me that he would address the hanging
issues with his live hangers immediately. | performed a
retest for A Line at approximately 2211 hours, after
adjustments were made, and 6 birds were missed by killing
machine.

P72

Tyson Foods, Inc

JPIJ2620122
510G

10DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

On Thursday, December 10, 2020 while performing
Poultry Good Commercial Practices, five cages were
monitored during the dumping process at approximately
1751 hours. Four of the five cages presented with rips,
tears, and/or holes in the top coverings of the cages, an
empty water bottle was observed in a cage with birds, and
all the cages contained an excess amount of liter. The
dumping of these five cages coincides with birds being
processed from Lot #1 for the night. According to the
associated paperwork, Lot #1 was designated as coming
from the Waldron Complex — specifically Brian Farm,
Growet/Flock #1982-990001, House #7 — assigned to
Catch Crew Waldron 1.

54


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P7669

Turkey Valley Farms, Inc.

RZB3513123
018G

18DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

Est. 7669p Turkey Valley Farms, December 2, 2020 At
approximately 1413 hours, while performing a Good
Commercial Practices verification task, | observed 1 out of
100 carcasses showing signs of consciousness (blinking
eyes, open mouth breathing, raised head, and wing
movement) proceed onto the secondary stunner.

was present at this
en both observed
the same bird exit the second stunner while still showing
signs of consciousness (blinking eyes, open mouth
breathing, raised head, and wing movement) and proceed
into the scalder. [bi {iar Immediately went to the killer
and informed him that he needed to make deeper cuts on
the bird necks. This task was done at the end of the shift
and no birds were available for a recheck. A similar Good
Commercial Practices MO! was documented on
11/25/2020 (see MO! RZB4213123518G).

P7669

Turkey Valley Farms, Inc.

RZB4213123
518G

18DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

Est. 7669p Turkey Valley Farms, November 25th, 2020 At
approximately 0900 hours, while performing a Good
Commercial Practices verification task, | observed 1 out of
100 carcasses showing signs of consciousness (blinking
eyes, open mouth breathing, raised head, and wing
movement) proceed into the scalder. The bird was smaller
in size and appeared to not make constant contact with the
secondary stunner and seemed only partially stunned,
[exe ]. was notified
immediately. LMM fayayy Stated that ne would raise the
secondary stunner te ersure better contact with the smaller
birds. | advised [ial [)(6)__ that in addition to the
secondary stunner notbeing effective, at that point in the
slaughter process the bird should not have been
conscious. [ail {Sy6y__ftated that the person backing up
the automatic kill machine may have not made an adequate
cuton the neck. At approximately 0910 hours, an
additional 200 bird check was conducted, and no further
issues were observed at this time.

P768+V768

Tyson Foods, Inc.

BFC2311111
223D

23NOV2020

04C05

Poultry Good
Commercial
Practices

Finalized,

60


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P806 Tyson Foods, Inc. 0G¢4720114 OSNOV2020 | 04C05 | PoultryGood | Finalized | Est. PBO6, Tyson Foods, Inc. November 5, 2020 1640
805G Commercial hours. In attendance: [i]
Practices Reginald Cubbage, Plant Manager {avm_—_____]
At 1640 hours on November 5, 20201 met with
fnvAy }. and faifisyer]

(6) | in the USDA office to discuss

observations that | had recently observed in the live bird
hanging atea. | informed them that at 1537 hours when |
entered the live bird hanging area, | observed an excessive
number, approximately 80 to 100, of live chickens on the
platform where the live bird hangers stand for kill line #1,
The live birds completely filled the platform from the west
end to where the hanger was standing in the fourth
position, as there was no person hanging at the end (fifth)
position. When | went down on the floor to more closely
view the chickens on the platform, | observed that the
chickens were piled on top of one another two and three
layers deep. As | continued to observe, | saw that as the
chickens were coming in from the outside dumping
conveyor belt and merging on to the narrower hanging belt,
that the chickens consistently continued to be pushed
above the level of the side of the conveyor and continued
to fall from the conveyor belt onto the pile of chickens on
the platform. Throughout this period of time there was no
individual working on the floor, and no one was taking any
action to address this situation. At this point | took an
official control action and had them stop dumping any
more cages of live chickens onto the belt. The employees
were allowed to continue to hang the live chickens already
on the belt onto the kill lines, to reduce the number of
chickens on the belt. Subsequently an employee broke
from his position on the line and retrieved all the chickens
that were on the platform and returned them to the hanging
belt. The presence of these live chickens in multiple layers
on top of each other could lead to birds dying by being
suffocated. After all the live chickens had been hung on
the kill lines, [ail (oye)

pe arrived at the area. Around 1545,
hours Tmet with Lol Walker and [ell [5y6)_Ifover__]

[orer inthe Live Receiving
office. | discussed with them my observations and the
action taken. [i] @aza—stated that he now had
increased the speed of the hanging belt, to more evenly
distribute the chickens on the belt, and that he informed
the cage dump team member to ensure that the chickens
had cleared before dumping the next cage to allow for
more space between birds and not overcrowd the belt.
After these corrective actions had been provided, |
released the live bird dumping station at 1551 hours. {n
the meeting with [él] and IB[bY6)__]! reviewed
the requirement that the live chickens be handled in a
manner that is consistent with Poultry Good Commercial

64


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P7044

Tyson Foods, Inc.

GJJO221102
919G

190CT2020

Finalized

20 at approximately 1500 hour |,
pontey was alerted by Iai of
insanilary conditions in the picking room. While observing
the picking area | then walked further and entered the kill
room. Once entering the kill room, | observed a bird
covered in blood huddled in the corner across from the
back up culter. | then observed a bird beneath the stunner
onits back that had fallen from the shackles saturated with
water from the stunner. Alongside the wall there were 7-8
birds running loose that had fallen from the shackles upon
entering the kill room from the hanging area. The
establishment failed to identify measures to effectively
address collection of birds falling from the Picker Line.
The establishment is reminded it is important to treat
poultry in a way that minimizes accidental injury which
includes identification of areas where problems may occur
and to determine if their facilities are designed and
maintained to prevent excitement, discomfort, and
accidental injury to poultry the entire time that live poultry
are held in connection with slaughter. Birds falling from
the live hang shackles to the floor which is a 3-4-foot drop
could result in injury. The establishment is asked to
provide measures to show the issue has been resolved and
topreventrecurrence. Copies of this Memorandum of
Interview (MO!) will be distributed to the establishment,
inspection file, and District Veterinary Specialist per FSIS
Directive 6100.3.

P70S

Pilgrim's Pride Cor

poration

FTJ1113104
713G

130CT2020

04C05

Poultry Good
‘Commercial
Practices

Finalized

This Memorandum of Interview was written because of
B-line stunner not having the proper amount of water to
fully stun the birds. On October 9, 2020 while performing

the GCP task, | observed very little water in the B line
stunner, | then showed [b)(6) Yy(6) (ONG) ] and
bye) and they informed me the

stunner was just slow to fill up with water, October 13,
2020, while IPP was performing Good Commercial
Practices (GCPs) at 0534 hours at the B-Line stunner, IPP
observed there was not enough water in the trough to
properly stun the birds. | walked to the exit end of the
stunner and saw there was a lot of movement and wings
flapping, indicating they were not fully stunned. |
immediately had the line stopped and notified the

x then came to the
stunner and turned the water on and started the line. At this
time there was a proper amount of water to fully stun the
birds. After the line was started, | tolffayey____]6)]
(BAT Pf the findings and explained that the observation
would be documented under a Good Commercial Practice
Mol.

52


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P208+V208 | George's Processing, inc. XIC3215105 300CT2020 | 04C05 | Poultry Good | Finalized | On October 30, 2020 at approximately 1450 hours while
630G Commercial walking through the live hang area | observed that the live

Practices

hang belt for Kill Line #1 was not operating. Several
maintenance personne! appeared to be performing

repair on the belt at this time. As I walked through the live
hang area | observed approximately 200-300 dead
chickens near the entrance from the dumping area on the
jive hang belt for Kill Line #1. Several plant employees
were pushing the dead chickens down the belt to allow

them to be taken to the offal auger for removal, Live
[ove was in the area and

informed me that when the live hang belt had stopped
working the dump station operator continued to dump
chickens onto the belt, causing live birds to pile up on top
of each other. The dead chickens appeared to have died
by smothering as a result of this pile up. Chickens dying
other than by slaughter reflects poor commercial practices
for handling live poultry. | remained in the live hang area
and observed several plant employees transferring live
chickens from the live hang belt on Kill Line #2 to the Kill
Line #1 live hang belt. | observed an employee carrying
multiple chickens by the head and by the wing, which is
not consistent with poultry good commercial practices, |
immediately verbally rejected the Kill Line #1 live hang belt
for use at 1500 hours to stop the process of transferring
chickens between belts, | informed fwal___]thathandling
live chickens by the head or wing was not appropriate, He
immediately counseled the employees to correct the
improper handling of live chickens and | released the belt
for production at 1502 hours. At 15:20 | had adiscussion
with Fava who had been made
aware of the poor commercial practices in the live hang
area, He informed me that disciplinary action and
additional training would be performed with live hang

employees to prevent future occurrence. At 15:40 Live
(ove) \otified me that

disciplinary action had been implemented for improper
handling of live chickens and that all live hang employees
would receive additional training on five chicken handling
and poultry good commercial practices. On 11-2-20201
confirmed with {(©)(6)__ that the training had been

completed. He stated that [bW6)
(eve). had also been present during the training.

24


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
PS517 Mar-Jac Poultry-MS. Q002101121 23DEC2020.| 04C05 | PoultryGood | Finalized | I [By6p Ir Mar-Jac Poultry, MS
923G Commercial 1301 James Street Hattiesburg, MS 39401 Eailb)6)] at
Practices approximately 0002 hours on December 23, 2020, the

following less than Good Commercial Practices (GCP)
incident was observed at Mar-Jac Poultry in Hattiesburg,
MS. One (1) alert, live, young chicken with no cut to its
neck, it's head raised, breathing, and blinking from an
approximate 500 bird random subgroup sample entered the
scald tank on the south ine which feeds
evisceration line #2. [(6)(6)
was verbally notified of the incident
at approximately 0005 hours. A second verification check
of an approximate 500 bird random subgroup sample on
the south picking line at approximately 0055 hours did not
have any live bird(s) entering the scald tank. This incident
was determined to be an isolated event and not a loss of
process control or systemic event.
advised a GCP Memorandum of Intervi
to management documenting these events.
Respectfully, .

[ra

Hattiesburg, MS 39401

cc: [tbl frAT cake
ave)

42


Table: Noncompliance Reports in Response to FOIA2021-118

08:56 Thursday, January 7, 2021

EstNbr

EstName.

NR Id

NR#

Date

Task

TaskName

Regs

Description

Status

4

observing the carcasses prior to the pre-sorters and began
seeing cadavers emerging from the picker room. The
carcass sorter at the pre-sorter station removed the
cadaver from the line, The carcass had dark red/purple
swollen head and no signs of a cut. Atapproximately 2220
hours, |, {AWAY Jand Laud (eye) were
observing the carcasses prior fo the pre-sorters and
observed an additional cadaver emerging from the picker
room, The carcass sorter at the pre-sorter station removed
the cadaver from the line. The carcass also had dark
red/purple swollen head and no signs of a cut. | informed
At approximately 2226 hours, |,
by(6) jand Thikees— ere
observing the carcasses prior to the pre-sorters and
observed an additional cadaver emerging from the picker
room. The carcass sorter at the pre-sorter station again
removed the cadaver from the line, The carcass had dark
red/purple swollen head and no signs of a cut. | informed
fe He informed me that as
a corrective action he had added and additional person
pulling heads in the picking room. | observed the line until
approximately 2246 hours, | did not find any additional
cadaversAt approximately 0540 hours, im aa]
informed me that she had observed 3 cadavers within the
last 3 minutes on Line 1 in Evisceration area 1. The
carcass sorter at the pre-sorter station removed the
cadavers from the line. The carcasses also had dark

red/purple swollen heads and no signs of a cut. p
informed FANE ==" We monitored the ne
until approximate hours, no additional cadavers
were observed. |, (bey kpoke to

he informed me that the
bac ip Cutter could not see because their face shield was
dirty. The corrective action was to move running water
closer to the back-up cutter to facilitate cleaning of face
shield.Due to the observation of cadavers on three different
days and the inability to maintain effectiveness of the

corrective actions, | notified the [BNG)
BG) pat | would be documenting a noncompliance.

P533

FreeBird Chicken

{2721CEFS-4589
-AC6C-97A1-413
1FACEADF3}

AKB1223
124122N
a

12/20/2020

04C05

Poultry Good
Commercial
Practices

381,65(b)

At P533 FreeBird Chicken on 12/21/20 at approximately
0350 |, aid foyer ______] observed the following
noncompliance. | founda pile of chicken carcasses
(approximately 20-30 birds) on the floor in the live hang
room. A plant employee told me thata new employee
operating the dumper had dumped ane load of chickens on
top of another, suffocating them. Approximately 180-193,
birds died in the dumper hopper. Plant employees placed
all the dead birds into the condemn auger. | noticed that
some birds in the pile were still alive and instructed the
plant employees to place them on the live hang conveyor
belt. The large number of birds that died by means other
than slaughter is evidence that the process is outt of control
and represents a noncompliance with 9 CFR 381.65(b).

OPEN



Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

TMM46070+P46
070

Marble City Meats LLC

KLE1711104
621G

210CT2020

04C05

Poultry Good
Commercial
Practices

Finalized

On October 20,2020, around 1:00PM, after lunch, IIC was
informed by slaughter person that 30 chickens were dead
in the crates. IIC had performed an Ante-mortem

inspection that moming before the start of slaughter
operations and all birds looked fine with no indication of
any issues or aliments. However, noticed before lunch that
several birds in a crate were open mouth breathing,
Indicating severe heat stress. IC informed establishment
Owner Matthew Lawrence of issue, Upon hearing this
owner investigated issue and retum with his results. Owner
stated that it was not hot in the kill and nor on the 30ft
trailer the birds were being stored in crates on, He further
state that he believes that the fault ies on the producer who
over stuffed each crates causing birds to suffocate, as
well as overheat. Establishment employees sprayed all
crates of birds with cold water to help cool down.

M4653A+P46
53A+V4653A

Agri Star Meat and Poultry, LLC

HRJ1316100
7086

080CT2020

04C05

Poultry Good
Commercial
Practices

Finalized

At approximately 1520 | entered the poultry kill room and
observed approximately 60 live birds on the floor, including
several which had wandered into the picker room, one that
was under the rendering belt chute and had been blocked
in by a pile of inedible carcasses and parts, and one that
was in a dead bird barrel. | also witnessed a plant
employee step on a live bird that was on its back amongst
a cluster of dead birds in the walkway. | informed Poultry
[oer who was running the kill belt

EVEr TATE DTS TECTEM to be picked up. | later
informed Gaya bf my findings. At
the following weekly meeting, said since all
employees in the area were already vained to keep live
birds off the floor/pick them up, and the supervisor signed
for training only a month ago, corrective actions would
include disciplinary action for the foreman in the kill room.

5


Table: Noncompliance Reports in Response to FOIA2021-118 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
P45910 SANDERSON | {9BF5648C-3A13 | GRI4119 10/16/2020 | 04C05 | Poultry Good 381.65(b) As | was performing as Poultry Good Commercial Practice | CLOSED
FARMS, INC -4A82-A0D8-86E | 105016N Commercial task at approximately 1958 hours, | proceeded to enter live
DAA65BC7C} 4 Practices hang to observe establishment employees hanging and

handling the birds. As | walked in to ensure compliance
with Poultry Good Commercial Practices, | observed a live
bird flapping its wings and moving its legs trying to get is
Fight foot out of the drain, The floor person came and
removed its foot from the drain and then proceeded to
place it's head on the head puller, which they use to
decapitate birds that are suspect of being Dead on Arrival
(DOA) carcasses. When the floor person was halfway into
cervical decapitation, the|
stopped him from pulling off the head. There
condition of the bird prior to this appeared to be in good
body condition, bright, alert, and responsive, There was no
indication that this bird needed to be be euthanized. |
informed him that the animal was stil alive at the time.
ceeded to check the eyes to see if the bird was
siill alive, The eyes were shut and the bird was
unresponsive, the skin was also broken and ligaments in
the neck were visible. | instructed him to place the animal
on the floor to see ifit was still alive and able to move.
Once the animal was placed on the ground it proceeded to
flap its wings as well as moving its legs to confirm it was in
fact alive. We discussed the findings as | waited to see if
the bird was stil alive, but after about two minutes the
animal was unresponsive, especially after having it's head
partially separated before it was placed back on the head
puller to finish decapitating its head from its body. |
informed him that this was a noncompliance as per federal
regulation 9 CFR 381.65(b) since the bird died by means
other than slaughter. informed me that all of the
floor staff will be re trai mane handling practices.

6



Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P510 House Of Raeford Farms RHB0006100 010CT2020| 04C05 | PoultryGood | Finalized | Ms. Nicole Reynolds, Plant Manager, P-510 House of
401G Commercial Raeford Rose Hill, NC 28458 At
Practices approximately 0546 while performing the Good Commercial

Practices Verification task, | observed a live bird about to
enter the scalder. The bird at the time of my observation
had normal rhythmic breathing, eyes open and blinking
with the head elevated. | immediately pointed out the bird to
(oxe) [yey oye) Who stopped
the line before the bird could enter the scalder and had the
bird removed from the line byfpe)
After removing the bird from the

ine, [Twas Observed that there was a small shallow cut on
the neck which would not have allowed the bird to bleed out
properly. Ea Laid took the bird back to live hang to show it
to the backup cutter. ii] id placed the bird back onto the
kill ine to allow itto go back through the stunner and the kill
blade to allow proper bleeding. Talla) instructed the
backup cutter to pay more attention to the smaller birds

and to make deeper cuts. | discussed my finding with

[ed ang [ial (ET Jad notified them of the pending

MOI and the establishment's failure to comply with 9 CFR
381.65 (b) which states: Poultry must be slaughtered in
accordance with good commercial practices in a manner
that will result in thorough bleeding of the carcasses and
ensure that breathing has stopped prior to scalding. [i]
GERAL TIES | Twas also notifed my findings,

There was a similar occurrence documented on 8/8/20 on
MO! RHB2307085108G [Ayal this MOI will be
forwarded to the District Veterinary Medical Specialist
(DVMS) in case additional follow-up is recommended.
Ifyou have any questions or concerms regardin

for [il
Respectfully,

fevar

35


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P164

Tyson Foods Inc

1JM44211048
06G

060CT2020

04C05

Poultry Good
Commercial
Practices

Finalized

this from occurring again. To try to correct this issue, the
maintenance department made an adjustment to the kill
blade and the Live Dock Supervisor removed the team
member that was feeding the birds necks into the kill
machine and repaced the backup Kllers dul ile. After
speaking wih hefmu-—BYBL Jon
11/18/2620, about the i ee
11/17/2020, ftalfe¥6\_J instructed the 2nd shift Inspectors
if this occurs again, to stop the process untl it can be
brought back in contol.

On the morning of October 05, 2020 at approximately
0104, hours, while performing a portion of the Good
Commercial Practice task as tisha and [eal]

ol ere observing the conditions in the
ee NTSoTaET ing room area mh Ihe Establishment’s Evisceration
department. [may hnd Lfibyey_——_]
ool served a live bird entering the scalding tank
po mat Tcking Line# 2, the live bird was small, and no cut was
evident on the bird's neck area. The bird was alert, lifting
its head and looking around. We informed zwar]
CN TNT Jand
ve) Four

2h ———SSSSSSSSSSSSSaxe
observations, and Davai Nas notified of the
forthcoming GCP MOI.

ial 9

fey(e)

P164

Tyson Foods Inc

1JM45201136
03G

03NOV2020

04C05

Poultry Good
Commercial
Practices

Finalized

On November 03, 2020 at approximately 0420 hrs. |, [EWE
(ia Jobserved less than Good Commercial
Practices (GCP). On the back dock, while performing a
Good Commercial Practice Task, | observed two live bitds
inside the DOA bin. The head was still attached to the
birds. One small bird and one medium size bird was
breathing and constantly maving.BN6) ds Live

Hang Supervisor was nolified at approximately 0424 hrs of
my observations. [B)(6)
verbally informed tea SOE TENT

_smail bird and the medium sized bird was put back into
mmediately notified general

(OG)

Bt approximately 0422 his. of

the findings while performing the GCP Task. Establishment

management was notified of the forthcoming GCP MOI

documenting these observations.

exer ] eo eave

21


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P308

Koch Foods, Inc

SPL4903101
421G

210CT2020

Finalized

To: [ove) ] At
approximately 0311 hours, while performing the Good
Commercial Practice task as,
observing the conditions in the Live Hauling area. iaWal_1
[EY Jobserved a live bird breathing, partially
covered by a pile of DOAs inside the small bird DOA bin.
She immediately notified nearby Koch team member,
be ] of her findings. [BX6) Jremoved
the bird from the DOA bin and the bird was humanely
euthanized by a team member by cervical dislocation.

was notified of the
less than Good Commercial Practice observation and of
the record of that observation with this GCP MOI.

P308

Koch Foods, Inc

SPL4909120
814G

14DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

To: Mr. John Waggoner, Plant Manager Koch Foods of
MS, LLC 4650 Hwy 80 E. Morton, MS 39117 Reference:
MO! #SPL4909120814G Task #SPL42091223141 At
approximately 0656 hours, while performing a portion of
the Good Commercial Practice task and as | was
‘observing the conditions in the Live Hauling area, |, LEX)
Angelia Cross observed a live bird breathing but covered
by a pile of DOAs inside the large DOA bin. | immediately

notified nearby Koch team member, [(b)(6) | of my findings.
exe) as

informed and observed the bird inside the DOA bin. The
bird was removed from the DOA bin. The bird, once freed,
began ta flap its wings with eyes open and alert. | informed
x ot the forthcoming
issuance of a GCP MO! documenting these observations.

bye)
UbYG

eve)

P308

Koch Foods, Inc

SPL3210120
317G

17DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

To: Mr. John Waggoner, Plant Manager Koch Foods of
MS, LLC Morton, MS 39117 Reference: MOI
#SPL3210120317G At approximately 0645 hours, while
performing a portion of the Good Commercial Practice
task and as | was observing the conditions in the Live
Hauling area, | observed a live bird
breathing but covered By & PIE OTDOAS inside the large
DOA bin. limmediately notified nearby Koch team
member, Demetric, of my findings. The bird was
immediately removed from the DOA bin by [ill Demetric,
The bitd, once freed, beaan to fap its wings with eyes
open and alert. Live Hauling Area
‘Supervisor was informed and observed the bird from the
DOA bin as informed of the
forthcoming issuance of GCPMO! documenting these
observations.

o)(6)

27


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P17766

Southern Hens, Inc

SSNO717125
829G

29DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 12/29/2020 at approximately 1641 hours, the following
less than Good Commercial Practice (GCP) incident was
observed at P17766, Southern Hens Inc., Moselle, MS
while performing the Good Commercial Practices
verification task. In the back-dock area, |,

itnessed 1 live bird being ran over by a Wailer.
The bird was in front of the second set of tires closest to
the loading area. The trailer began to move and crushed
the bird. The trailer driver was then instructed fo reverse so
that the bird could be remover ill fapping
its wings and gasping for air. [aiK6) (OVE

Oo) was present at the fime, and
Th order to alleviate the animal's suffering, the head was
rapidly removed faar Iwas nolified of my
observations, and of the forthcoming GCP MOI,
documenting these events.

P18414

MB Consultants LTD

J¥113061115,
25G

25NOV2020

Finalized

On 11-24-2020, approximately at 1.00pm IPP informed
plant manager Phil that | noticed scalpel blade this morning
on floor near kill room. Same thing was noticed few weeks
ago. IPP was concemed about their reuse. Phil assured
to IPP that those blades are non-reusable and will ask killer
persons to dispose them properly every time.

P1949

Simmons Prepared Foods, Inc.

KLA3307125
721G

21DEC2020

Finalized

12/21/2020 Upon entering the live hang room, SCSI
observed the following good commercial practice
concerns: Line 1 live hang belt was piled so high with
birds that the live hang team members could not hang birds
onthe shackles. The Line 1 live hang team members
were walking on a platform completely coveredipiled with
dead and live birds. Approximately 80 dead birds were on
the concrete floor with one team member making an
attempt to pick them up and put into condemn barrels. 11
condemn barrels were being used to hold dead birds while
two additional team members continuously carried barrels
to the DOA dumper. Numerous live birds were under the
Line 1 live hang team members platform and the live hang
belt. Several live birds were observed under the Line 2 live
hang belt. Several dead birds were observed on the Line 2
live hang team member platform. Condemn barrels were
observed being dumped at the DOA dumper and carried
up to the condemn trailer without an application of a
denaturant. These concems were discussed with
management members
was stated that an error in Communication was the main
cause of these concerns and that videos were being
observed so corrective actions can be specific to those
responsible, IPP remained in the area until all birds were
handled appropriately and all dead birds were retrieved
and denatured correctly.



Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P510 House Of Raeford Farms RHB2904110 05NOV2020 Finalized | On 11/05/2020 at 0206 hours | was conducting a Good
2056 Commercial Practice verification task in the kill/picking

area which is behind the evisceration department. While
observing the birds on the line after they had exited the
blood tunnel and prior to the first scalder, | identified a bird
that had it's head elevated and was looking around. The
line was stopped, and the bird was removed from its
shackle, | observed the bird breathing, blinking, and
looking around. Upon further examination | noted that the
bird did not have a cut on its neck. | discussed the
concern with[RvaY ]
and later with |
reminded ther Ra per QUT BTESOTINCRS
poultry must be slaughtered in accordance with good
commercial practices in a manner that will result in
thorough bleeding of the carcasses and ensure that
breathing has stopped prior to entering the scalder. The
bird was retumed to the live hang area and placed on the
receiving line [(66)__] had a discussion with the
back-up cutfer about the issue and reported he would be
monitoring the back-up cutter during the remainder of the
shift to verify that there would be no further issues. |
continued monitoring the birds on the line before they
entered the scalder and saw no further issues. The last
occurrence of a similar issue was documented on
10/01/2020. This MO} will be forwarded to the District

b)(6) and to
Re CHEM younave any questions

you can contact me or the (oye)
Respectfully,

36


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P1254+V125
4

Koch Foods of Ashland, LLC

YFA2613112
803G

03NOV2020

04C05

Poultry Good
Commercial
Practices

Finalized

On November 3, 2020 at approximately 09:55 hours, |
observed less than perfect Good Commercial Practices
(GCP) near the cage dump area of the establishment.
While performing Ante Mortem inspection and a Good
Commercial Practice Check, | observed one live young
chicken in the dead-on-arrival (DOA) dumpster. The
dumpster contained approximately twenty DOA chickens.
The chicken was observed at the front, right comer of the
dumpster when looking into it, lying breast up, on top of the
DOA pile. | observed the bird's breast rising and falling
with ranid respirations. | notifiedfoye) id:

HG of my findings and the forncoming GCP Mo! at
09:57 hours. [Q¥6) verified my findings, took

corrective actions, and informed the rest of the
management team. Tim Worthy, plant manager, stated
that cervical dislocation/decapitation of all DOA chickens
would begin immediately to ensure live birds will not be
placed in the DOA dumpster. A copy of this Memorandum
of Interview will be forwarded to appropriate personnel in
the District Office. Respectfully submitted on November 3,

2020, a] ean ex6y

P1254+V125
4

Koch Foods of Ashland, LLC

YFA0514113
425G

25NOV2020

04C05

Poultry Good
Commercial
Practices

Finalized

Koch Foods of Ashland P1254, 515 Tyson Rd. Ashland,
AL 36251 On November 25, 2020 at approximately 08:40
hours, | observed less than perfect Good Commercial
Practices (GCP) at the cooling shed which housed six
trailers loaded with live chickens on the west side of the
establishment. While performing Ante Mortem Inspection
and a Good Commercial Practice Check, | observed one
live young chicken with its head stuck in the door of a
cage module. The module was the last one at the rear of
the trailer parked in bay 5, second cage from the bottom,
located on the passenger side of the trailer. The chicken
was observed breathing regularly with its beak open,
misaligned by approximately one inch horizontally, and
trapped near the top corner of the cage door. | notified
be ] of my findings
and the need for immediate action at 08:45 hours. When |
retumed to the USDA office, plant manager Tim Worthy
telephoned regarding a different matter at which time |
informed him, along with
of my findings. A copy of this Memorandum of
Interview will be forwarded to appropriate personnel in the
District Office. Respectfully submitted on November 25,

2020, [O\(6)_—_Ifover

18


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P794

B&B Poultry Co., Inc.

UCB0012115,
618G

18NOV2020

04C05

Poultry Good
Commercial
Practices

Finalized

hone conference: A R=}
Est P794 On November 18,

2020, at approximately 0655 hrs. in the picking
department, | witnessed the following: two birds entering
the scalders alive. | walked down to the end of the picking
machine and confirmed my observations, two cadavers
exiting the picking machine. | asked the plant staff to
remove the birds from the line for further inspection. |
continued my inspection and saw two additional cadavers
with uncut necks exiting the picking machine. | informed
faloxe) | of my
observations and he informed me that the back-up cutter
was late. | continued my inspection until 0725 hrs. and

witnessed no additional cadavers.

P794

B&B Poultry Co., Inc.

UCB4315123
408G

08DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

Attendees: [Ia] (ONG)

On December 8, 2020 at approximately T6T5 hrs. 1
witnessed two uncut cadavers birds exiting the picking
machine. Plant staff removed both birds from the line and
I notified

62


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M751+P1049 | Pitman Farms Inc. (Moroni Turkey Processing) | MMK041310 020CT2020 | 04C05 | PoultryGood | Finalized | On Friday, October 2nd, 2020, at approximately 0845
1902G Commercial hours, |, foW6y ent to the live hang area with
Practices eG) jafter concerns the birds were not

bleeding out properly. At that time, the trailer in the bay
had only a quarter of the cages left to unload, and a
second full trailer was pulled up behind it. While inspecting
the birds on both trailers | counted at least 9 loose hens in
the bay, including 3 that were congregated underneath the
wailer. While there was a bin for collecting DOAs, at least
6 carcasses were on the ground around the trailer. One
carcass, on the far side of the trailer near the hang stand,
was observed to be mangled and bloody, with a large
bloody smear on the concreate where the trailers drive
while being unloaded. As the trailer began to pull forward
so employees on the stand could reach the remaining
cages, several of the birds under it startled and tried to
move out of the way. One hen crossed in front of the
Wheel, and while able to move fast enough to stay out from
under it. was pushed forward by the wheel until the truck
came to a stop. The hen was then able to move completely
out from under the trailer. At that time, Evisceration

fer fib) came out to the live hang
bay and FSIS personnel pointed out concems with the
number of loose birds and them congregating underneath
the wales forgy—p structed several employees to
collect the birds and dispose of the DOAs on the ground,
All the loose birds were collected by employees and hung
on shackles appropriately. Over the past two weeks |
have observed an increasing number of loose birds in the
live hang area when running heavy hen lots. Thursday,
October 1st, during moming operations USDA IPP
observed over 10 loose hens in the bay and multiple DOAs
on the ground, one DOA appeared to have been run over
by the trailer. There was no disposal bin in the live hang
area to collect DOA carcasses. The Live Hang Supervisor
Was notified of conditions in the bay and said they would
make sure a disposal bin was brought in and would gather
up loose birds more oftenfipyey______] also talked to.

| TasTTaNY regarding

numbers of loose hens and concerns that birds being
allowed to remain loose in the bay or under trailers would
be caught under the wheels.

10


Table: MO!Is in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P46826 SHENANDOAH VALLEY ORGANIC BOK0310124 17DEC2020 | 04C05 | PoultryGood | Finalized | On 12/17/2020 at about 1050 hours, | was inspecting live
017G Commercial hanging operations as part of a Good Commercial

Practices

Practices verification of Lot 2. While | was in the blood
room, | inspected a yellow barrel intended to store
inedible/condemned carcasses. While examining the
carcasses, | noticed that there were at least two (2)
chickens alive, moving, breathing, and slowly blinking. |
garnered the attention of the area lead supervisor and
showed the alive chickens to him. After removing the alive
birds, three (3) more were discovered for a total of five (5)
living chickens in an inedible/condemned barrel
intermingled with Dead on Arrival (DoA) carcasses. | did
not determine any condemnable lesions antemortem and
determined that these chickens would bleed out if
slaughtered, so | permitted them to be taken to the live
hang line and hung. USDA regulation 9 CFR 381.65(b)
strictly requires that all live poultry, once on official
premises, die by no means other than regulatory slaughter
or, if rejected by the plant or condemned antemortem by
an lIC, euthanasia. Alive birds sent to rendering would be
killed by non-regulatory means and considered cadavers.
Had | not been present to intervene, it is reasonable

to conclude that these chickens would not have died by
methods approved by regulation. The ambient
temperatures on this day of operation were below freezing
and birds can be mistaken for DoA due the effects of the
cold on their behavior and responsiveness to stimuli.
Regardless, it is incumbent on the establishment to
accommodate for the weather's effects on its live poultry
and take adequate measures to confirm that birds
condemned as DoA are truly dead or euthanized if they
are judged unfit for slaughter. A reasonably determined
pattern of negligence in this regard may be documented in
a Noncompliance Record as a violation of 9 CFR
381.65(b).

33


Table: MOl!s in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P935, Allen Harim Foods, LLC. | YXA5217100 190CT2020 | 04C05 | PoultryGood | Open Date: 10/16/20. From: [lier Subject:
619G Commercial Removal of U.S. Reject Tag. Meeting Dale: 10/16/20
Practices Meeting Time: 1530 hours. Establishment: Allen Harim

Foods LLC Attendees: Scott Yackel, Plant Manager.

Taal ray (ov)
Tet Talia T. Today
at about 3.20pm IbMlfipye reported as under

On Thursday October 15 at approximately 1530 hrs., while
performing zero tolerance inspection verification at
CCP1A , whole reprocessed salvage birds, | observed
several finished product standards defects (3 gall birds, 2
IP, 2 lungs), on the 10 randomly selected carcasses that
were inspected. | proceeded to apply US Retained Tag
B45242290 to the affected bin.
was notified. [al

was requested to let me know when the
reworking of bin be completed as they had already started
to rework in my presence. At approximately 1945 hrs.,
while performing direct observation for Raw Intact
inspection verification, QA technician proceeded to hand
me my tag, which | referred to his [[b)(6) }

Tay | informedfAiAy jof the establishment's
failure to comply with 9 CFR 416.6, US Rejected Tag
B45242332 was applied to the salvage department on
10/16/20. [fever and
Scott Yackel, Plant Manager were informed accordingly.
Immediately requested a meeting with establishment
management and Mr, Scott Yackel andy) _r carne
to USDA office and discussed the issue. The USDA
reject tags can not only be removed by the by the USDA
personnel only. Lis violation of the Federal law to remove
US reject tag other than by the inspection team member.
The establishment is aware of the fact and has already
been documented for the similar Federal Violation of
removing the tag on 7/22/2020. As a result of this
violation, the Salvage/Reprocessing privilege is rescinded
until further notice. The establishment is requested to
provide a corrective/preventative action plan to address

this very serious matter, cc: [B)6)

69


2

Table: Noncompliance Reports in Response to FOIA2021-118 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
P511 Butterball, LLC | {8EF3AF71-82C7 | HUG1111 42/09/2020 | 04C05 | Poultry Good 381.65(b) On Wednesday December 9, 2020, at approximately 0927, | OPEN
-4550-9FBF-364 | 123709N Commercial while walking through the pinning room, | noted the back
£413903A6} 4 Practices up killer working hard to keep up. The employee verbalized

some sounds that indicated he was attempting to get some
assistance. | quickly brought [by6)

Pia} over to the area, She prompily stopped the
line and lowered the stunner tank. Two other employees
then joined (=7=——}0 help with what was later described
as, replacing a bolt on the kill machine. The stunner was
raised, and the line started back up. Standing along the
east wall, turkeys all appeared to have a cut along their
neck, but some were posturing with some rigidity looking
upwards. | then went fo the east wall scalder exit, followed
by a reentrance into another tank. and saw 3 birds enter
with the ability to gape their mouth. | witnessed no other
birds enter this way, but a total of 20 carcasses, ina
approximately under 2 minutes, exited the picker with a
deep red coloration to their skin indicating they were still
breathing while entering the scald tanks and had
incomplete exsanguination. These carcasses are cadavers
as they died from a cause other than slaughter. The
plant's loss of process control and failure to handle the
birds in accordance with Good Commercial Practices
violates 9 CFR'381.65(b)



x

Table: Noncompliance Reports in Response to FOIA2021-118 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
M6137+P613 | Foster Farms {14452389-943A- | BXL1708 10/15/2020 | 04C05 | Poultry Good 381.65(b) On 10/15/2020, | observed a noncompliance with the OPEN
7 48C3-A1A6-A92_ | 104123N Commercial regulatory requirements of 9CFR 381.65(b)On 10/12/2020,
A328C10F3} 4 Practices

at approximately 2222 hours in Evisceration Area 1 on Line
2, Lo) bbserved the first sorter
remove a Cadaver from the Kill line; the head was still

attached and there was no cut at all on the neck. |
inspected the condemn barrel and there was another
cadaver with the head attached and no neck cut. |
informedfoye) _________ that the cadavers
were unacceptable. Tie €stabishmient took corrective
action by adjusting the stunner and counseling the back-up
cutter. No further incidents of cadavers were observed.On
10/15/2020, in Evisceration Area 1 on Line 2. AL
approximately 2212 hours, |, {o¥@)_———idiwas
observing the carcasses prior {o the pre-Sorlers and began
seeing cadavers emerging from the picker room. |
removed 2 cadavers from the line before the Pre-sorter
station, The carcasses had dark red/purple swollen heads
and no signs of a cut was with
me when the cadavers where observed, He informed me
thatas a cotrective action they would change the back-up
cutter. | returned at approximately 2218 hours to watch
carcasses emerging from the picking room prior to the
pre-sorter station. At approximately 2222 hours once again
| observed 2 cadavers emerging from the picker room. The
carcasses had dark red/purple swollen heads and no signs

WAS going fo stop hanging birds on the
kill ine, At approximately 2224 hanging on Line 2 stopped.
At approximately 2231 hours once again | observed 2
cadavers emerging from the picker room. The carcasses
had dark redipurple swollen heads and no signs of a cut.
At approximately 2232 hours, the last carcass exited the
picker room, and the line was empty. During this time
period the company took corrective action by counseling
the live hang lead persons that they should ensure that
proper personnel was in place before starting. They also
added a person pulling heads off carcasses before they
enter the scalders. At approximately 2245 hours,
production had started and carcasses again to emerge
from the picker room. At approximately 2256 hours, |
observed 1 cadaver emerging from the picker room. The
carcass had dark redipurple swollen head and no signs of
acut. | Informedfpyey of the
additional Cadaver and his corrective action was to add an
additional person pulling heads in the picking room. At
approximately 2307 hours, | once again observed 1
cadaver emerging from the picker room. The carcass had

dark red/purple swollen head and no signs of a cut.
coos aconied
to adjust the auto kill machine. | observed the line until
approximately 2330 hours, | did not find any additional
cadavers.On 10/18/2020, in Evisceration Area 1 on Line 1.

At approximately 2216 hours, Laz ——Wwas



Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P4a5 Wayne Farms, LLC FKA1713122 09DEC2020.| 04C05 | PoultryGood | Finalized | On 12/4/2020, at approximately 2040, while performing the
409G Commercial Good Commercial Practices (GCP) Task, | observed one
Practices live bird in the DOA condemn vat in the live receiving

department, The bird was breathing and still had its head
attached. There were also approximately 15 dead birds
visible on the surface of the vat without their heads
removed or denaturant applied. (The normal procedure is
to remove the head before placing the bird in the DOA vat).
The vat was nearly full and the fork lift was in place to
transport the vat to offal.

es beside me when | noticed the live bird, He
removed the bird from the vat and placed it on the Live

Hang Belt [b6)
was notified at 27:50. | also discussed my findings with
[oer ifthe live bird would have

remained in the DOA condemn vat, itis likely it would have
died by asphyxiation due to being smothered by dead
birds being placed on top of itin the DOA condemn vat or
inoffal. PPIA and Agency regulations require that live
poultry be handled in a manner that is consistent with good
commercial practices (GCP), and that they do not die from,
causes other than slaughter. | recommend that
management review Federal Register Notice Vol. 70, No.
187, published September 2005 [Docket No. 04-037] for
FSIS recommendations concerning treatment of live
poultry before slaughter. A copy of this document can be
provided on request. Please provide an explanation for
this incident. A copy of this MOl and your response will
be forwarded to the Raleigh District Office and the District
Veterinary Medical Specialist (DVMS) in the event that an
additional follow-up is recommended.

30


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M7100+P710 | Tyson Foods, Inc. ZHB2721105 270CT2020 | 04C05 | PoultryGood | Finalized | Est. 07100P, Tyson Foods of Nashville, AR, October 27,
0+V7100 527G Commercial 2020, at approximately 20:30 hours, while performing Ante
Practices Mortem and verification of Good Commercial Practices, |

witnessed a live bird that had been discarded into a DOA
bin. The bird had fallen into the bin was completely buried
under a carcass and was breathing normally causing the
carcass to move rhythmically, It was near the top of the
pile in the current DOA bin that was 3/4 full. The bird was
able to hold its head up and look around when GPM

unburied itand removed it from the bin. | notified

b of the situation and

forthcoming MOI, The bird was immediately taken to be
hung on the kill line for slaughter. | reminded [ial [y(] that
the PPIA and Agency regulations require that live poultry
be handled in a manner that is consistent with good
commercial practices (GCPs) and that they not die from
causes other than slaughter. | notified [Za] GU] that this
MOt will be forwarded to Springdale District Office and the
District Veterinary Medical Spetals CMS) in case
additional follow-up is recommended. stated that
the lead and driver had been retrained in animal welfare
and he would review their training and decide upon further
measures to prevent reoccurance, Est, 07100P, Tyson
Foods of Nashville, AR, October 27, 2020, 20:30 hours, In
attendance: [(5)@)

Evisceration - Taterview wit
Evisceration GPM: Are you aware that allowing a live bird
to be smothered by DOA's is a failure to comply with good
commercial practices? Yes. compliance with
goad commercial practices is important to Tyson Foods.
Whatis the policy for ensuring live birds are not disposed
ofwith DOA’s? [e\G)) bY The suspect DOA carcasses
will be gathered and assessed by the floor personnel to
ascertain true DOA status before being placed in the DOA
bins. After the possible stimulation of the belt loading the
DOA bin, the contents of the DOA bin will be assessed for
any signs of life, including breathing, movement, and/or
blinking. How do you plan to ensure a similar incident
does not happen? OKO | will review the training
status of the employee handling suspect DOAs. If their
training was not up to date, | will train them in current
policy, If their training is current, their training will be
refreshed and the incident of found live bird in DOA bin
documented. | will review the procedures and consult with
the APM and PM about adequacy of the procedures.
Respectfully,

[Gy] Tyson Foods or Nashville, AR

e


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M7100+P710 | Tyson Foods, Inc. ZHB3621101 090CT2020 | 04C05 | PoultryGood | Finalized | Est. 07100P, Tyson Foods of Nashville, AR, October 9,
0+V7100 009G Commercial 2020, 21:10 hours, In attendance: [bT6)

Practices

Bye) eatin Thy |. At
approximately 20:45 hours, while performing Ante Mortem
and verification of Good Commercial Practices, |
witnessed a live bird that had been discarded into a DOA
bin. The bird had fallen into the bin was breathing normally
and was on top of the pile in a full DOA bin that was no
longer the current in-use DOA Bin. The bird was able to
hold its head up and look around when

removed it from the bin. | notified (day)

pe bf the situation and forthcoming MOI.

The bird was immediately taken to be hung on the kill line
for slaughter. | reminded [faiH(oy( that the PPIA and
Agency regulations require that live poultry be handled in a
manner that is consistent with good commercial practices
(GCPs) and that they not die from causes other than
slaughter. | notified [I Laud that this MO! will be forwarded
to Springdale District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended. Interview with Evisceration
GPM: Are you aware that allowing a live bird to be
smothered by DOA’s is a failure to comply with good
commercial practices? Yes. compliance with
good commercial practices is important to Tyson Foods.
What is the policy for ensuring live birds are not disposed
of with DOA’s? [EMV] [ibid The suspect DOA carcasses
will be gathered and assessed by the floor personnel to
ascertain true DOA status before being placed in the DOA
bins. How do you plan to ensure a similar incident does
not happen? vr] J will ensure that the floor

fully,

(06) Hryson

Foods of Nashville, AR



Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1362 Tyson Foods, Inc. LPC2120104 070CT2020 Finalized | At 1837 hours on 10/07/2020 while performing my GCP
807G task | observed a live bird in the DOA bin. Itwas in the rear

area of the bin, with its head sticking up and its eyes open.
Iwas able to locate a team member with a radio who |
asked to call{(6)6)

While waiting for Hugo to respond more birds continued to
fall on the live bird. At that time a team member from Live
Hang came out and was asked if they could get the bird for
me. By this time other birds had covered up the live bird.
The bird was removed from the bin and began flapping its
wings and moving its head around. The Live Hang team
member took the bird back fo the live hang area to be
rehung, | went back to USDA office to wait for
[GL hnd notify him of the MOI. This will be
addressed in the next weekly meeting.

19


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

Task
MOINbr Date Code | TaskName

Status

MO! Agenda

381.69(c)-establishments operating under the New Poultry
Inspection System must reduce their line speed as
directed by inspectors-in-charge when in their
iudgement...factors indicate a loss of control. | advised
that in one hour another observation of
chickens entering the scalder would take place. | advised
that as long as the establishment had their process back
under control and birds entering the scalder were not
breathing, | would release regulatory contral of the line.
This observation occurred at approximately 07:30 and the
establishment's process was back in control, and so |

relinquished {tory control of the line speed on line 1
ma] said that due to staffing issues

at that time.
on a Saturday, they had placed a trained but

inexperienced backup killer on the line just after the kill
blade. The establishment's corrective action was to
immediately replace her with an experienced backup killer,
one of the live hang leads. The establishment's preventative
measure was to evaluate the experience level of trained
backup killers more fully before assigning them to the line

in that position regardless of short staffing issues. This
MO! will be forwarded to the District Office and the District
Veterinary Medicine Specialist (VMS) in case additional
follow up is recommended. If you have any questions or
concerns regarding this MOl, please feel free to contact

me, or (5X6) l
Respectfully, [ONe) ]

pa ]



Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P3 Mountaire Farms of Delaware, Inc, 0CG1122113 41NOV2020 | 04C05 | Poultry Good | Finalized | On the evening of November 11, 2020 at approximately
ANG Commercial 2225 hours while completing GCP/Antemortem
Practices verifications, the following was observed faye]

fE)6)_}found:two birds in a bay of the Establishment

Po live holding shed. This bay did not have a trailer in it.
The one bird was live and unharmed. The other bird was
lying breast down and crushed across its neck and wings,
and the head was no longer attached to the neck. The skin

and feathers of the anterior was also ripped off the
carcass back. | brought this tof)
erator, and he took the dead crushed bird to
the be tanked and the live bird to the dumper. It

is reasonable to conclude that this crushed bird died by
being ran over by a tire, not slaughter. No other significant
findings were observed. itis recommended that
establishment management review the Federal Register on
"Treatment of Live Poultry before Slaughter", published
‘September 2005 for FSIS recommendatioy ing
treatment of live poultry prior to slaughter, ()(6)
was notified that this MOI will be forwarded to the
District Office and the District Veterinary Medical
‘Specialist (VMS) in case additional follow-up is
recommended. Sincerely, [AWaT-———_]
Mountaire Farms of Delaware, Establishment P3 29005
John J Williams Highway Millsboro, DE 19966

25


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M17980+P17 | Pilgrim's Pride Corporation ZBB5813102 270CT2020| 04C05 | Poultry Good | Finalized | in Attendance:fayA—— 7}
980 2276 Commercial by6)
Practices Your ‘On Thursday, October 22, 2020 at

approximately 1004 hours, |
observed a live bird entering the scalderin the picking
room while performing a Good Commercial Practice
verification. was
shown this bird coming out ofthe Scalder with a dark red
neck and head with no cut to the neck. [(5)(6)__] removed
the bird from the line and was told to place it in the
condemn barrel. The PPIA (21 U.S.C. 453(g)(5)), and 9
CFR 381.90, provide that poultry carcasses showing
evidence of having died from causes other than slaughter
are considered adulterated and must be condemned.

was informed that agency regulations do require live
poultry do not die from causes other than slaughter. On
Tuesday, October 27, 2020 at approximately 1124 hours, |,
fie pb served a live bird entering the
scalder in the picking room while performing a Good
Commercial Practice verification. After exiting the scalder,
the bird's neck and head were dark red in color with no cut
to the neck. A production team member at the rehang
station was shown this cadaver and was told to remove this
bird off the line and to place it in the condemn barrel. |,

(a) \en Notified b)(6)
[over this cadaver. | then found Production
superintendent, and informed her of this

repeated instance of birds still breathing when they enter
the scalder and also that a USDA food inspector had to pull
and condemn a cadaver bird off the evisceration

inspection line earlier on 10-27-20 because it was not
pulled off previously [S(@]in160] was informed that the
process the establishment is employing is not able to
prevent these problems from reoccurring and that the PPIA
and Agency regulations do require live poultry to be
handled in a manner that is consistent with good
commercial practices, and that they do not die from

causes other than slaughter. | informeciWa nia] that an
MOI would be documented and forwarded to the District
Office and District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

Respectfully, [oJ [by6) _] Kee) P-17980

Pilgrim's Pride

1


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P622 ‘Tyson Foods NLB2117103 060CT2020 | 04C05 | PoultryGood | Finalized | Est. P-622, Tyson Foods October 5.2020 Time: 1840
7066 Commercial hours In attendance: ein

Practices

Lenora Bull At approximately 1835 hours while observing
the DOA dumpster in the poultry receiving area, |,
Bull, observed a single live and weak young chicken in the
dumpster which contained approximately 25-30
dead-on-arrival (DOA) chickens. A team member who was
pushing a wheel barrel of dead birds, approached the
dumpster to throw them in and was instructed by me not to
put any more birds in at the time due to the live bird |
observed. | summoned
[O16] CCM, was also notified. Both
arrived at the DOA dumpster and were shown the live bird.
immediately removed the live bird and elected to
euthanize it via cervical dislocation in the presence of
USDA personnel at 1842 hours. Agency regulations
require that live poultry be handled in a manner that is
consistent with good commercial practices and that they
not die from causes other than slaughter. Because this is
an isolated incident that does not represent Tyson Foods’
loss of process control, a Good Commercial Practices
noncompliance will not be issued. However, an ongoing
issue or trend may be developing. A similar incident
occurred on July 2, 2020 and is documented with
MOI #NLB2512074502G by E{(BVe1_]n which, multiple
carcasses (23 total) were observed by IPP in the DOA
dumpster with heads still attached to the carcasses. The
lead person and a floor team member started pulling all the
carcasses with heads still attached out of the designated
dumpster. Upon pulling two carcasses with heads stil
attached off the pile, a live bird which was underneath the
two dead carcasses raised its head up at that moment. The
live bird was properly euthanized by the floor person. The
Procedure for handling DOAs is that the DOA carcasses
heads are to be removed prior to placing in the DOA
Dumpster. In addition, on May 5, 2020,
MOI #NLB4007053709G was document by Ea]{O®) jin
which, a large pile of DOA birds (approximately 80 birds)
were observed at the end of the live hang conveyor belt
Jine #2. Upon examination of these birds and after
approximately 10 birds were removed, 4 live birds were
found completely buried under the dead birds , these birds
were breathing and blinking their eyes, by removing more
dead birds , three more live birds were found, during the
time of the observation , there were no supervisors in the
area was shown the observation. Also,
a large pile of irds (approximately 50 birds) at the
end of the conveyor belt line #1 was observed. Upon
examination of these birds, 3 live birds were found, these
re breathing and blinking their eyes.
was notified
and observed the incident. Rapid decapitation is the



Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M7875+P787 | Joe Jurgielewicz & Son, Ltd. MKJ1714124 12DEC2020:| 04C05 | PoultryGood | Finalized | This meeting was held with{6)(6)
5+V7875 1126 Commercial Complex. & Special Projects Manager Atapproximately

Practices

1120 hours, while conducting the Good Commercial
Practice task | observed the following issues in the live
hang area, | observed an employee in the live hang area
carry at least five (non ambulatory) ducks from the truck
by the neck and place them on top of the ducks that were
already located in front of the conveyor into the tunnel, As
the employee turned and noticed me and another
employee made who also saw me call out to all the
employees in Spanish. Only one employee was observed
taking this action all the other employees observed were
placing the ducks on the floor at the end of the conveyor, |
observed the employees wait until the ducks that were
gathered along the entry point of the tunnel had cleared
before additional ducks were brought tothe area. |
relayed by observation to [iailéy immediately

afterward since (b)(6) ‘Cupied due to staffing

issues.

12


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName MO! Agenda
M751+P1049 | Pitman Farms Inc. (Moroni Turkey Processing) | MMKO11310 300CT2020 | 04C05 | Poultry Good | Finalized | At approximately 0918 hours on October 29, 2020. 1, [i]
4830G Commercial fexe) Jwas informed by (YG)
Practices that the slaughter ine had stopped. {O)(6)

immediately went back to the slaughter line only to return at
approximately 0928 hours to inform IPP that establishment
personnel were told to go to break. At approximately 0935
hours, (bX6) b) formed me,

) ander that the
Slaughter Ine was Stopped and&wa{(b)(6)___ Pasked if UCI
[lunch break could begin when the line was
stopped instead of at the usual 1000 hours|
also mentioned that she was currently tryingTo7Tga
what to do with the live birds for the following hour while the
line was being fixed. Upon hearing that live birds were still

(06) Wavy —T and | informed foyey
fe) __[(ON6)_Jthat the live birds wouta nave To Take

immediate priority over conversations about changing
lunch hours. Upon entering live hang receiving at
approximately 0940 hours, | observed live birds hanging
from live hang through to the electrical stunner, and dead
birds hanging from just past the electrical stunner through
past the scalder to immediately prior to the evisceration
floor. All birds on the evisceration line had been cleared. |
observed approximately 19 birds submerged in water within
the electrical stunner with electrical current running, where

(Px) LMG1— observed 4 birds in the electrical stunner
exhibiting movement. In addition, 3 live birds prior to the
electrical stunner were dripping wet and shivering. There
were 2 maintenance workers working on fixing the shackle
chain outside in the live hang area, but no one was

addressing the live birds hanging or the live birds in the
stunner. as immediately informed that the
electrical stunner needed to be turned off and that live
birds needed to be addressed as priority over fixing the
line. The electrical stunner was immediately tumed off
starting at 0944 hours and by 1002 hours, all 19 live birds
were removed fram the submersion within the electrical
stunner. Immediately following that, all live birds prior to the
stunner were removed from their shackles. This is a
failure to implement Pitman Farms SOP #332 Bird Care
during an Equipment Breakdown which states that (TE
(by4))
verbally
notified {b(6) \by6)__ that a Gc
MO! would be documented for this poultry mistreatment
event. There have been no GCP MOl's documented for
the same root cause within the past 90 days.

un


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P7903 Perdue Foods, LLC UYN3409122 JODEC2020 Finalized | On December 10, 2020, approximately 0549 hours, a
010G mechanical breakdown involving Kill Line 3 occurred. The

line was stopped. At 0630 hours, a GCP inspection ensued
from the live hanging area to the scalder. Approximately
4-5 hung birds were observed to have recovered
consciousness, attempting to right themselves and
voluntarily breathing, These birds were located after the
stunner, but before the neck cutting blade. Water nozzles
near the blade wheel were drowning one bird attempting to
breathe. The backup cutter had not monitored the line and
did not cut the necks of the birds. [al

was verbally notified and then
asked what the establishment's plan was for extended
emergency breakdowns to address animal welfare. He was
not aware of an emergency plan. The 4-5 affected birds
were immediately bled out at 0640 hours. Birds that could

be safely removed by personnel were removed from the
line. | contacted tal Kens)

| Tea Jto view the plant's animal welfare plan in the
HACCP office. He did not have a specific plan other than
a Perdue directive to plants. | asked him to please contact
me when the plan was found. In the meantime, the plan
stated “A plan is written, available and followed that
addresses bird care in event of power failure leading to
line shut down, or other extended line stoppage.” At 0717
hours, Kill Line 3 was still down and birds were still on the
line past the cutting blade up to and including the scalder.

) was present. |
asked him if he was aware of the plant's specific animal
welfare actions to be taken in the event of an emergency
shut down. He was not aware. | verbally notified
[@\6)__]that an MO! would be written for failure to monitor
the line during an extended line stoppage. | reminded him
of the plant's responsibility and obligation to handle the live
birds in a manner consistent with the requirements of their
Animal Welfare Plan and the Code of Federal Regulations.
Approximately 0820 hours, the plant's animal welfare plan
was found, In addressing bird care in the event of a
prolonged line shut down, the plan states that “in excess of
30 minutes, live birds will be moved to functional slaughter
line(s) to be processed’. All the aforementioned
Statements are true and correct to the best of my
knowledge, as indicated by my electronic signature below.

61


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P6137A Foster Farms NJN3312103 070CT2020| 04C05 | PoultryGood | Finalized | This MOI is intended to document the Poultry Good
707G Commercial Commercial Practices incident that occurred at P6137A on
Practices Thursday, October 1, 2020 at approximately 1240 hours.

Atapproximately 1240 hours. while performing GCP Task,
\ TufONe) pbserved the following: approximately
100 birds pled up on the ground directly behind the live
hangers, This pile was approximately 3 feet high and 6 feet
wide and contained live and DOA birds. | immediately
approached 16) to communicate
this piling YG was

called to the area to help observe the proces

approximately 1245 hours. At this time, [Eu
observed [()(6) roll up the side door

and he began to remove and dispose the dead birds
outside in the red bins designated for this purpose. We
also observed as establishment Lead Enrique separated
the live birds and returned them to the line. Establishment
Supervisor Lino Teran anived to help with the removal of
the DOA’s and was informed of the piling concem [(5)G)|
[eXEL___}as informed of the concern immediat
the incident occurred. |(y(6)___ immediately coike
with Supervisor Lino ae ‘and informed him of the
forthcoming MO! {(b)(6) communicated the
establishment's re5po V to handle live birds ina
manner consistent with good commercial practices and to
prevent needless injury/suffering. [o6)____Jand|
met with|
the MOI,

hang table after the NPIS conversion to allow for the line
speeds with NPIS. He explained thal the table was not level
and the birds were falling off the end. We advised him that
preventing the mistreatment of poultry decreases the
chances of producing adulterated carcasses. We asked
about the preventative measures the establishment will take
to avoid reoccurrence [b)(6) informed us that the
table has been leveled, more railings were added to the
sides of the table and covers were installed. We also
discussed the establishment's Animal Welfare Program
criteria that should have the concern observed above: The
Animal Welfare Program states, “Zero loose birds in yard
and no excessive loose birds in live hang. No live birds in

DOA bins.” respectfully, Had fore, _)

44


Table: MO!Is in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P4602A

NEW MARKET POULTRY, LLC

YCG0113123
701G

01DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 12/01/2020 at 1345 hours, | was inspecting Lot 3 as
part of the Good Commercial Practices verification task.
Upon ascending the outside staircase to the stoop outside
of the live hang shelter, | noticed movement from one of
the condemned heads of poultry in a yellow USDA
condemned barrel that was parked on the stoop. On top of
the pile of carcasses condemned was alive rooster still
breathing, moving, blinking, and defecating. | garnered

the attention of the line lead, demonstrated the live rooster
intermingled with condemned carcasses, and observed
him euthanize the rooster by cervical dislocation. The
barrel in which the live rooster was lying was full to
capacity and stationed where barrels are placed prior to
emptying in a common dumpster. Had | not been present
to intervene, itis reasonable to conclude that this rooster
may have died by means other than regulations approved
slaughter or euthanasia methods thus representing
noncompliance with 9 CFR 381.65(b).

P4602A

NEW MARKET POULTRY, LLC

YCG0206122
702G

02DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 12/02/2020 at 0645 hours, | was inspecting operations
in the live hanging area as part of the Good Commercial
Practices verification task. | was inspecting the contents
of the yellow USDA condemned barrels used to contain
Dead on Arrival (DOA) carcasses. In the one nearest the
shackle line, | saw that there was one chicken alive and
moving head down with the DOAs unable to correct its
posture. | kept my flashlight tracked on the live bird and
garnered the attention of the area line lead to show him the
live chicken in the condemn barrel. The lead extracted the
chicken held it for my inspection, and | saw that it was in a
grossly fit condition for slaughter and permitted him to
hang the chicken in the shackle line. This incident
occurred soon after a similar documented event on
12/01/2020 around 1345 hours in which | discovered a
live rooster in a yellow barrel on top of the DOAs which
was sitting on the stoop outside of the live hang building.
The Poultry Products Inspection Act of 1957 and agency
regulations pursuant to it require that poultry be handled
and slaughtered in accordance with good commercial
practices. The negligent placement of live birds in
condemned barrels is mistreatment of live poultry
specimens. The repeating reoccurrence of said
mistreatment, construable as lost process control over
GCPs, may be documented as noncompliance with 9 CFR
381.65(b).

32


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

method of euthanization most utilized by the establishment.
However, based upon findings in recent months, this
method is not being properly executed. Itis the
establishment responsibility to ensure that the birds are
slaughtered in accordance with 9 CFR 381.65(b). If you
have any questions in reference to this Memorandum of

Interview, you may contact the USDA office. Sincerely,
[by6) P-622, Tyson Foods

P622

Tyson Foods

NLB3021115
403G

03NOV2020

04C05

Poultry Good
Commercial
Practices

Finalized

At 2212 hours, while performing a Poultry Good
Commercial Practices task and observing birds entering
the scalder, |, served a live bird on the line
which had its neck arched and looking around. This bird
was about to enter the scalder. | immediately ran to the Kill
room and took regulatory control of both kill lines by
instructing back-up neck cutter team members to stop the
lines as | did not know at the time whether the line was #1
or #2. | informed the team members that there was a live
bird on the line. When we arrived back at the scalder, the
team member pulled through the birds which were just
beyond the scalder entrance and found the live bird. The
bird's head was already in the water but his body wasn’t
and the bird was still alive. The bird was taken by the team
member back to the Kill room where the neck was cut and
the bird hung back on the line, which was Kill line #2.
Regulatory control was then relinquished and both kill lines
resumed operation. EaaY Iwas verbally
informed by me of the live bird entering the scalder and
notified of the forthcoming Memorandum of Interview
(mo). EelfGay ——} GPM, was also notified. Had
USDA IPP not taken action upon this observation, the bird
would have drowned alive in the scalder. It is the
establishment's responsibility to ensure that the birds do
not die by any means other than slaughter and that they
are slaughtered in accordance with 9 CFR 381.65(b),
Please contact the USDA office with any questions.
Sincerely, (SISWEB nv Tyson Foods, P-622,
Monroe, NC

P6504

Peco Foods, Inc,

CHK1610103
122G

220CT2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 10/22/2020 at approximately 0949 hours while
performing Good Commercial Practices verification at the
entrance of the scalder on line # 1, |, SPHV Jacqueline
Fountain, observed the following GCP violation.
Approximately the 300th out of a 500 bird check, |
observed a live bird with the head still attached, 1.5 cm cut
to right side of neck with bubbles of blood present,
blinking, and actively trying to right itself by lifting its head
and neck [fayay
notified of my observ:
Aiter notifying plant management, | went back and
observed the entrance of the scalder on the affected line
for an additional 500 birds and saw no further deficiencies
as described in this MOI.

49


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P45910 SANDERSON FARMS, INC GRI0706125 22DEC2020: 04C05 | PoultryGood | Finalized | On December 22, 2020 approximately 0522H In the
022G Commercial Picking Area near the Scalders tank | observed the
Practices following issue. While performing a Good Commercial

Practices Verification | observed two birds flapping their
wings on the final approach to the Scalder Tank and

entering the scalder. No supervisor was nearby so | went
and found Bye) Jand

informed him of this issue, (b)(6)__| went to adjust the
ment and came back to the scalders. [ee]
[vas standing beside me and we observed another
bird flapping slightly as it was approaching the scalder
system one (oa) Treached ‘out and pulled this bird off
the line but as he was walking away two more live birds
entered the scalder, | ask To stop the line until
the problem was corrected. He stopped the line and called
for maintenance to correct the problem. While
maintenance was correcting the problem with system one,
| watched as the birds entered the scalder system 2 and
observed a bird flapping slightly as it entered the scalder. |
told|(6)(6)__] there was an issue on this line also. We
watched as birds entered the scalder when another bird
was having involuntary muscle movement on the final
approach to the scalder, got this bird off the line
before it entered the scalder. He was walking away when
two more birds that was slightly flapping was approaching
the scalder | got his attention and we both witnessed the
birds enter the scalde stopped the line and
Notified Maintenance. Maintenance evaluated the
equipment and adjusted the stunners on both lines. The
birds were not being stunned properly. | notified
Fulton of the plants failure to comply with 9 CFR 381.65 (b)
and | would be issuing a Memorandum of Interview (MO!)
for failure to follow good commercial practices. The PPIA
and Agency regulations require that live poultry be handled
in amanner that is consistent with good commercial
practices and live poultry should not die of causes other
than by slaughter. The Federal Register on Treatment of
Live Poultry before Slaughter gives recommendations on
how to prevent these occurrences.

3


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P9197 Perdue Foods, LLC. UAB2906122 18DEC2020 | 04C05 | PoultryGood | Finalized | On 12/15/20 at approximately 1230 hours while in the live
818G Commercial hang area for Lines# 23 |, along
Practices with my menteqfamar——— observed 5 birds on the live

hang belt, mixed in with the DOA birds. Three of the birds
were buried under the DOA birds to varying degrees, One
of the birds | observed had its head completely covered by
DOA birds and appeared to be having difficultly breathing.
This determination was made by the fact that bird could be
seen breathing heavily and rapidly and when it was
uncovered, it began open mouth breathing. After the bird
was uncovered for a short period of time its respiration

rate appeared to slow and it stopped open mouth
breathing. Without USDA intervention, the live birds buried
in the pile of DOAs would have likely suffocated due to
having other birds piled on top of them. Additionally, there
was one bird that was stuck under the end of the live hang
belt that is between the live hang and DOA belts. The bird
was lodged under the belt ina way that prevented it from
being able to free itself. Every time that the Live hang belt
activated the bird's head and neck would be forcefully
dragged along the bottom of the belt in a manner that
caused visible distress to the bird. | immediately looked for
management in the immediate live hang area and was not
able to find anyone, so | sought assistance from the
nearest live hang employee. The employee removed alll the
live birds from the DOA pile and tried to remove the bird
that was stuck under the live hang belt. The employee was
not able to pull the bird forward out of the belt because of
how it was lodged in place and instead needed to push the
bird backwards so that it fell the short distance,
approximately 2 feet, from the bottom of the belt onto the
floor below. We verified that there were not anymore birds
present on the DOA belt for lines 2/3 before leaving the
area to inform management. A few minutes later | spoke to
and | informed him of what |
just witnessed. After seeing the location where the bird was
trapped under the live hang belt informed me
that he would work with maintenance to create a barrier to
that location to prevent another bird from getting trapped in
that location. | reminded [b]bN6)__fhat the PPIA and
Agency regulations require that live poultry be handled in a
manner that is consistent with good commercial practices.
| referred him to Federal Register Notice Vol. 70, No. 187,
which the establishment has been previously provided, and
| recommended that he review it for FSIS.
recommendations concerning treatment of live poultry
before slaughter. | notified them that this MO! will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended.

68


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M737+P737 | House of Raeford - Wallace Div DHAQ109114 44NOV2020 | 04C05 | PoultryGood | Finalized | P737 House of Raeford-Wallace Division, November 14,
514G Commercial 020 at 07:00 am. In attendance{()(6)
Practices (b)(6) and [oN6) n

‘Saturday, November 14, 2020 at approximately U5:T5 as |
walked from the USDA office to enter the evisceration
department, | notified| [exer

( that | was a FGOOT
Practices (GCP) task. This is the agreed-upon practice at
this NPIS establishment as the establishment does not
support FSIS personnel stopping the line at the scalders
nor FSIS personnel removing birds from shackles. [ENN

ate —Fjpoxe on the radio, and a minute or two later,
when | walked to the area where the chickens emerge from
the bleed tank to go over a drip pan protected walkway and
into the scalders, | saw one of the live hang leads awaiting
my arrival at Line 1, There were two live chickens without
cuts on their necks directly behind him on the floor along a
wall. | have not included these in the countas | did not see
them pulled from shackles before entering the scalder,
The line was running at [oirds per minute (bpm) (this
establishment has a validated line speed waiver and may
operate the lines on first shift up tof opm), and within
roughly 3.5-4 minutes, | observed the establishment
remove 13 birds alive and without cuts on their necks just
before entering the scalders. These birds could have died
by means other than slaughter. The had
calleq(6)(6) and she and other evis management
personnel had come out to help remove birds from
shackles. Even with increased establishment assistance it
appeared that keeping up with removing live chickens from
the line was an issue. | did not, however, see any live birds
enter the scalders, At06:20, | notified that
both a Good Commercial Practices (GCP) MOI would be
issued and a noncompliance report using the Other
Inspection Requirements task to document that | was
assuming regulatory control of the establishment's Line 1
and lowering line speed. | lowered line speed to gJbpm.
Because of the agreed-upon practice of having
establishment personnel accompany FSIS while observing
chickens entering the scalder, and that | did not see any
live bird enter the scalder, | chose to issue a GCP MOI and
a Other Inspection Requirements noncompliance to
document line speed reduction due to loss of process
control. Regarding the GCP MOI issued
(DHA0109114514G), the establishment needed to
immediately take significant corrective actions to ensure
compliance with 9 CFR 381.65 (b) -poultry must be
slaughtered in accordance with Good Commercial
Practices and ensure that breathing has stopped prior to.
entering the scalder. Regarding the Other Inspection
Requirements noncompliance (DHA2610112914N), the
establishment was cited with 9 CFR



Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

Task
MOINbr Date Code | TaskName Status

MO! Agenda

+

P164

Tyson Foods Inc

1JM30221104 03NOV2020 | 04C05 | Poultry Good Finalized
03G Commercial
Practices

At approximately 2112 hours, while performing a portion of
the Good Commercial Practice Task as | was observing
the birds entering the scalder in the Picking room area in
the Establishment’s Evisceration department, |,

observed a live bird entering the scalding tank for
Picking Line # 2. The live bird was small, and no cut was
evident on the bird’s neck area. The bird was gbea

iftng its head and blinking its eyes. informed TM®) |
al and (be)
(ENGV = oslofmy observations... Atapproxinately

2157 hours, while performing a portion of the Good
Commercial Practice Task, I went back to observe the
birds entering the scalder in the Picking room area in the
Establishment's Evisceration department. |,

observed a live bird entering the scalding tank for
Picking Line # 2. No cut was evident on the bird's neck
area. The bird was alert, looking around and blinking its
eyes. | informegby6) ji)
and (BYey of my
observations of another live bird going into the scalder, and
of the forthcoming GCP MOI documenting these

observations.
He ]
Ine Theyre ind

P17766

‘Southern Hens, Inc

SSN0409123 17DEC2020 | 04C05 | Poultry Good Finalized
117G Commercial
Practices

On 12/16/2020 at approximately 1510 - 1513 hours, the
following less than Good Commercial Practice (GCP)
incident was observed at P17766, Southern Hens Inc.,
Moselle, MS while performing the Good Commercial
Practices verification task. In the back-dock area, |,

IC, witnessed 2 live birds commingling with
dead bird carcasses within the DOA bin. The first live bird |
observed was on its side and eyes opened looking around.
The bird was alert and vocal when manipulated. The
second live bird was crouched under two bird carcasses in
cold water. This live bird was also alert and vocal when

manipulated and attempted to run off before being
captured. | irre ae

of my observations, and of the forthcoming
GCP MO! documenting these events.

22


Table: MOlIs in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P7632 Zorro Leasing LLC HYE2607122 15DEC2020 | 04C05 | PoultryGood | Finalized | To:
615G Commercial [over From: [ind Re: Poultry
Practices Good Commercial Practices Date: December 15, 2020

Subject: Memorandum of Interview This MO} is intended to
document the Poultry Good Commercial Practices concem
that occurred at P7632 on Tuesday, December 15, 2020

at approximately 0417 hours, and the discussion with
management. While performing a routine Good
Commercial Practices (GCP) task at approximately 0417
hours, [aWiVEY Walked through the live hang area.
Upon inspecting the nearly full denature/dead bird gondola,
he noticed one bird was still breathing at the top of the pile
of carcasses. The [ald immediately located the employee
that was staged at the end of the live hang conveyor and
requested to speak to the lead or a supervisor. The lead
was located at the end of the line hanging birds at this

time. The lead was shown the still breathing bird and upon
shifting some of the dead carcasses around to reach it, a
second bird lifted its head up and began looking around.
This bird was completely covered by dead carcasses when
the [ai] first came upon the gondola. Birds were not
properly being sorted at the end of the conveyor which
allowed live birds to be tossed into a disposal bin and
consequently covered with dead birds.
came over to the gondola at this time and was informed ot
the findings. The lead had already removed the two live

birds from the bin by this tim
by6) was informed of the

situation and the forthcoming MO at approximately 0451
hours by [owe jand WE

and met with [aay Fon 12/15/20 at
0454 hours to discuss the findings. fawar explained

that a newly hired employee had taken it upon himself to
sort at the end of the belt. stated he had not
been instructed nor trained to do that task.
explained further that the employee has been instructed not
to do anything he is not trained to doffoye) __ tated that
the entire live hang crew would be retrained on their roles
and duties in the department fy{6) _] stated during the
meeting that one bird was near death and was allowed to
die, and then was euthanized by manually disarticulating
the head from the neck per establishment procedure. The

second bird he line
for slaughter. (0)(6) iat
preventing the mistreatment of poultry decreases the

chances of producing adulterated carcasses.

Respectiully, Layo) _]

59


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P890 Peco Foods, Inc. cyp1611124 08DEC2020 | 04C05 | PoultryGood | Finalized | Est. P-890, Peco Foods, Inc. December 7, 2020, 0914
608G Commercial hours. At approximately 0912 hours, FSIS Personnel
Practices was nolified by plant management that lot 2D was changing

tolot 1D.1, by(6) proceeded to perform
the Good Commercial Practice task and Ante-mortem

check at 0914 hours. | entered the Scalder Room and
observed the birds for approximately 4 minutes. | observed
one (1) live and conscious bird enter the scalder. The neck
of the bird was partially cut and not properly bleeding out.
The bird was observed with rhythmic breathing and
blinking and looking around. While observing conditions
in the live hang pen in the poultry receiving department, |
observed approximately five (5) live, weak young birds
comingled with approximately five (5) dead-on-arrival
(DOA) birds on the floor. A plant lead employee began to
separate the live birds from the dead-on arrival birds. |
notified [il foy(6) lof this finding
as well as the finding in the Scalder Room. As!
proceeded to the outside to perform Ante-mortem
inspection, upon approaching the trailer, | observed a
forklift driver moving forcibly towards the cage at the top of
the trailer. The single cage contained approximately 192
birds. The cage tilted to the side, the forklift driver backed
up, and the cage dropped approximately 7 feet to the
ground. The doors of the cages flew open and half of the
birds in the cage fell onto the ground. The birds on the
ground were covered in black sludge. Some birds inside of
the cage were jammed into the cage.

NGL ]

Dy) [anc
[feve) Were notified of this

finding and the forthcoming GCP MO! documenting these
observations. Plant management began retrieving the loose
birds from the ground, removing the remainder of the birds
from the dropped cage, separating the live birds from dead
birds, and transferring the live birds into a new cage.
Respecttully, [aud P-890 Peco

Foods, Inc. Canton, Mississippi

66


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P51179+V51 | Sanderson Farms, Ine. RQE2814100 160CT2020 | 04C05 | PoultryGood | Finalized | Est. P-51179 at Sanderson Farms, 16th of October
179 2166 Commercial 2020 . In attendance are the following: ia]
Practices [6)6)_] USDA Relief SPHV: {fByO)

a BOHEY El
hours, 16th of October 2020,
found one young chicken cadaver inside the
condemned barrel by the wall dividing the picker’s floor
and evisceration floor while performing poultry GCP.
verification task. The head and neck are intact with
hematoma. Which means this chicken did not even bleed
out when it entered the scalder. The skin of carcass and
neck exhibit reddish to purple discoloration. 1st
Processing Superintendent [aiai_1| is notified
accordingly. He looked at the bird and concurred itis
cadaver, Cadavers are not physiologically dead and are
still breathing when they enter the scald vat. Carcasses of
poultry that die from drowning may exhibit signs of
incomplete exsanguination (bleed-out), resulting in
an unwholesome carcass. When submerged in the hot
water, they drown, and the physiological reaction to the
heat is for the blood vessels to expand or dilate causing the
remaining blood to flow to the surface of the skin in an
attempt to coo! the bird. This is what causes the skin of the
carcass or neck to become cherry red to purple. |
reminded [yey] (6)(6] [()(] that the PPIA and
Agency regulations require that live poultry be handled in a
manner that is consistent with good commercial practices
and that they not die from causes other than slaughter. |
also recommended GIO Mm to review Federal
Register Notice Vol. 70, No. 187, published September
2005 [Docket No. 04-037N) for FSIS recommendations
concerning treatment of live poultry before slaughter. |
also told him that an MO! will be forwarded to the District
Office and the District Veterinary Medical Specialist
(DVMS) in case additional follow-up is recommended.

39


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

Task
MOINbr Date Code | TaskName Status

MO! Agenda

P51179+V51
179

Sanderson Farms, Inc.

RQE4117111 O1NOV2020 Finalized
601G

Atapproximately 1145 hours, while performing Antemortem
inspection accompanied by Dr. Jennifer McKean, Dallas
District Manager, we decided to verify operations in the
Live Hang area. Upon entering the area, | observed that
Line 1 was stopped. The facility had been having
problems with the line at the Rehanger in the Evisceration
department, | observed that birds were hanging on the line
in the live hang area. | went into the Picking area and
observed that there were birds in the stunner. The heads
of the birds were still submerged in water. | asked the
management employee in the area why the stunner had
not been drained to prevent the birds from drowning. He
stated that the lever to the hydraulic system that lowers the
stunner was broken. | then suggested that he drain the
stunner by pulling the drain hose on the equipment to allow
the water to drain, He did this immediately and drained the
stunner. Allowing birds to remain in the stunner when the
line has stopped for an extended period of time results in
the drowning of those birds causing them to die by means
other than slaughter. | discussed the finding with inh
He stated that he would
investigate why the establishment's procedures were not

followed by the management employees in the area. [B)G)]

PS1179+V51
179

Sanderson Farms, Inc.

RQE3505112 10NOV2020 | 04C05 | Poultry Good Finalized
210G Commercial
Practices

From: Date: November 09,
2020 Time: 11:11 am While performing a Good
Commercial Practices Task after walking around the
‘outside of the building | re-entered the piant at the Live
Hang entrance to find circumstances out of control. There
were at least a dozen live birds on the floor along with
multiple dead birds and massive feathers on the floor.
[BWG) was already responding to the situation and getting
itunder control.



Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P72

Tyson Foods, Inc

JPJ3300121
430G

30DEC2020.

04C05

Poultry Good
Commercial
Practices

Finalized

On Tuesday, December 29, 2020 at 2010 hours, a GCP
(Good Commercial Practices) check was performed in the
Killing/Stunning area of the establishment. The
establishment's program limit for this area is less than or
equal to 10 per 500 birds missed by the kill machine and 0
per 500 birds hung by one leg. The kill ine was running
bpm and the check lasted 3 minutes and 27
seconds to include a total of birds. During this check,
ee was present. The
check for Kill Line B resulted in a pass; the check for Kill
Line A resulted in fail with 14 birds being missed by the kill
machine. At the end of the check (Gy)

(eve) ind FAY were
informed of my findings and that they had failed in meeting
their limits. | was informed at 2038 hours that adjustments
had been made and that the line was ready for a retest.

At 0004 hours, a retest was performed only on Kill Line A.
The kill ine was operating at the same speed as before
and the check lasted the same 3 minutes and 27 seconds.
During this check, Kill Line A resulted in a pass for the
number of birds being missed by the kill machine (3), but
failed due to having one bird that was hung by only one
leg. Again, Fat was

esent for the check, and both he and Oo
FRI “Fwere informed of he falure. Also
during the retest, | observed that on eight separate
shackles, a bird was hung on top of a paw that had

recirculated. | informed
that this was unacceptable and asked I someone was
responsible for removing the paws that were not kicked off
on the initial pass, to which he informed me that the
hangers were supposed to be removing them prior to
hanging another bird. A final retest was performed at
0201 hours on Kill Line A that resulted in a pass for both
criteria, As for the paw removal, the situation had
significanily improved at this time, but is not an acceptable
practice. Without the removal of paws that do not eject
normally, there is no way to determine if the retained paws
are those of healthy, passable paws or those of unhealthy,
condemnable paws, or for that matter, how long the
non-ejected paws have been circulating.

P727+V727

Simmons Prepared Foods, Inc.

VCF3323110
502G

02NOV2020

Finalized

On 11-01-2020 at approximately 2015, while preforming
GCP’s, | was inspecting trailers and noticed two (2) live
birds between cages. These birds were caught by hand
by two of the establishment's employees and were
unharmed. Upon further inspection, | noticed two (2) more
live birds hanging halfway out of the top cage, which had
no door. [EWaT— Was present and had
the cage in question removed from the trailer and the
remaining two (2) live birds were caught by hand and
removed unharmed.

55


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P39 Pine Manor inc. ULLO420111 04NOV2020 | 04C05 | Poultry Good | Open On Wednesday. November 4th, 2020 at 17:48, | (
604G Commercial 00039) while performing a Good

Practices

Commercial Practices (GCP) task, observed a live chicken
in the bottom of one of the DOA barrels at the end of the
conveyors at the hanging platform. It was a small sized
chicken (less than 2 lbs. in weight) and there were 2 larger
(5-6 Ib.) DOA chicken carcasses also in the barrel. The
chicken did not appear to be in any distress and was
standing on the bottom of the barrel with it's head down. |
[xs) |

immediately notified] ( VAY
(ole) ————s |

quickly retrieved the live chicken from the barrel and
humanely euthanized and disposed of it. While the
chicken did not appear to be in any distress, itis
reasonable to assume that it would have been crushed to
death as more carcasses were added to the barrel as the
slaughter kill continued. | must remind the plant that the
Poultry Products Inspection Act (PPIA) and USDA/FSIS
Regulations do require that live poultry do be handled in a
manner that is consistent with good commercial practices,
and that they do not die from causes other than slaughter.
advise that the plant review Federal Register Notice Vol.
70, No. 187 published September 2005 [Docket No.
04-037N] for an outline of the USDA/FSIS guidelines
concerning treatment of live poultry prior to slaughter.
USDAVFSIS recommends that Pine Manor implement
procedures that will prevent similar future occurrences. Mr.
Roger Stearns (Plant Manager) will receive a copy of this
Memorandum of interview (MOI) and will also be notified
that this MOI will be forwarded to the District Office and the
District Veterinary Medical Specialist (DVMS) for review
and any follow-up.

28


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Task

Date Code | TaskName Status

MO! Agenda

P7487

Koch Foods, LLC

SPG3223123
303G

03DEC2020 | 04C05 | Poultry Good Finalized
Commercial

Practices

While performing the GCP Verification Task for 3rd shift at
Koch Foods P7487 around 22:45 on Thursday, December
3rd, |, ENG) pbserved 2 birds enter the
scalder alive on the ISline. They both were conscious
and alert, with heads raised looking around and blinking
There was no evidence of cutting or bleeding on the first
bird. Drew Cole, third shift plant manager, witnessed the
second bird enter the scalder alive and attempted to
remove it unsuccessfully before entering the scalder.

was notified of my observations and pending MOI.
The plant responded verbally by saying they were slowing
down theff@il ine speed to(J@B.o assist in training the new
back up cutter.

P7487

Koch Foods, LLC

SPG5201121
203G

03DEC2020 | 04C05 | Poultry Good
Commercial

Practices

Finalized

While performing the GCP Verification Task for 3rd shift at
Koch Foods P7487 around 2:15am on Thursday,
December 3rd, |[oyie)_____} observed 2 birds
enter the scalder alive on the| ine. They both were
conscious and alert, with heads raised looking around and
blinking. [V4 [56] plant manager, witnessed the second
bird enter the scalder alive and attempted to remove it
unsuccessfully before entering the scalder. [b\éll was
notified of my observations and pending MOI. The plant
responded verbally by saying they were slowing down the
ine speed tc[fSfENto assist in training a new back up

58


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P9197 Perdue Foods, LLC. UAB0013103 280CT2020 | 04C05 | PoultryGood | Finalized | On 10/27/20 at approximately 1310 hours while in the live
328G Commercial hang area for Line#1 |, [EvRL_______]observed
Practices approximately 50 birds or more that where off of the live

hang belt and running freely around the live hang room.
The birds were huddled together and moving around the
room especially when approached, but | saw approximately
40-15 birds near the picking room door, 20-30 birds near
the offal exit door, and approximately 10-15 birds under the
DOA belt, in the drain and next to the live hangers.
Additionally, the entire DOA belt was filled with DOA birds
and live birds. | observed several live birds standing on top
of the DOA birds on the belt and | observed at least 10-15
birds that were buried to some degree under the DOA
birds on the belt. Of the live birds that were buried in the
DOA birds | observed at least 5 birds that had their heads
completely covered by DOA birds and appeared to be
having difficullly breathing. This determination was made
by the fact that birds could be seen breathing heavily and
rapidly and when they were uncovered, they began open
mouth breathing. After they were uncovered for a short
period of time their respiration rates appeared to slow and
they stopped open mouth breathing. Iwas in the live hang
room for approximately 30 seconds before one of the live
hangers left the line and began retrieving the birds off the
floor. He caught the birds that were running free on the
floor and began removing the live birds from the DOA belt.
observed as he removed the buried birds from the DOA
belt. After he had appeared to be done clearing the DOA
belt of live birds, | went through the DOA birds running the
length of the belt and discovered 2 additional live birds that
were completely covered by DOA birds. When | removed

the DOA birds off the 2 live birds they also appeared to be
breathing heavily. At this time{(b)(6)
had entered the department and aformed him of what

just witnessed. | reminded [aleyey_}hat the PPIA and
Agency regulations require that live poultry be handled in a
manner that is consistent with good commercial practices.
| referred him to Federal Register Notice Vol. 70, No. 187,
which the establishment has been previously provided, and
| recommended that he review if for FSIS
recommendations concerning treatment of live poultry
before slaughter. | notified them that this MO! will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended.

67


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

+

M27389+P27
389+V27389

Pitman Farms

NCO2913102
513G

130CT2020

04C05

Poultry Good
Commercial
Practices

Finalized

M32130+P32
130+V32130

Dakota Provisions LLC

JEB5906123
008G

08DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

This Memorandum of Interview (MOI) is to document the
discussion of the mistreatment of poultry with
Establishment P27389 on 10/12/2020 at approximately
13:05. Io)

observed a single live duck
inside a gray balrel, The barrel contained trash, located
directly in the sun, and next to the establishment's
chemical storage area. [(0)(6)

6) asked why the duck was in the gray
rref©X8) was not sure, Duck slaughtering was
completed at approximately 06:15. {(5)(6)
informed [Bia ]that duck slaughter was completed
approximately 6.75 hours ago, IPP and the SCSI asked
how long was the duck in the barel? (eens "a no
response for the question. SCSI explémecrmerthis duck
has been in direct sunlight for an unknown number of
hours. The duck was breathing heavily (panting) potentially
due to being in direct sunlight for unknown number of
hours informed IPP and the SCSI they would
gas the bird, slaughter, and dispose of it. IPP informed [nil
jat a (MO!) would be documented for future
reference. The duck removed from the area and taken to

the CO2 stunning area.
At approximately 0500 while performing ante-mortem
inspection, IPP observed a dead bird on the ground beside
trailer #096592. Upon closer examination, it was noticed
that the cage door was open on the top cage, fourth row
from the back of the trailer. This is approximately an 8-10
foot drop to the concrete below, The bird appeared to have
succumbed to his injuries. The cage door was located on
the drivers side and did not appear to be fully functional.
Immediately nouned, he establishment must employ
humane methods of handling and slaughtering consistent
with Good Commercial Practices in a way that minimizes

injury to poultry,

4


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

they not die from causes other than slaughter. It also
recommends review of Federal Register Notice Vol. 70,
No. 187, published September 2005 [Docket No. 04-037N]
for FSIS recommendations conce
poultry before slaughter. | notified [(2)(6)
[That this MO! will be forwarded to The Distal
Office and the District Veterinary Medical Specialist
(DVMS) in case additional follow-up is recommended. A
review of records revealed no events of similar
mistreatment; however, events of dissimilar mistreatment
were documented on October 20 by September
11 by EBIOX6)_] No adulterated product was allowed to
enter commerce.

47


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P6164A Foster Farms 109121031 200CT2020 | 04C05 | PoultryGood | Finalized | On October 20, 2020, at approximately 0759 hours, while
20G Commercial performing a routine Good Commercial Practices (GCPs)

Practices

inspection task |, [Bye)___________J observed
practices not consistent with GCPs. Normally, the cage
dump operator tilts a cage module against steel-framed
set of chutes so that the caged birds slide out of the cage
module and through a set of slick steel chutes to land ina
pit where a conveyer belt floor transports them for hanging,
After the birds are dumped, the cage module is lowered
and rolled away, To avoid needless repeat trauma to live
birds that are advertently ‘pinned! in machinery, itis a good
commercial practice and establishment policy to neither
‘re-tilt! nor 'shake' cages in which birds are pinned. (An
exception of ‘double-dump' is allowed when a large number
of birds are safely trapped inside the cage when one or
more flip-doors does not open.) Establishment policy
directs employees to simply roll the cage module away
from the steel chute frame and with two-hands, deposit the
bird into the conveyer belt. Specific issues observed:1.
Operator tilted the cage module, causing the flip-doors of
the cage module to open and thereby freeing birds onto
the conveyor belt, When the module was lowered back
down into the horizontal position, the operator observed a
single bird was pinned at the wing between the steel frame
of the dump chutes and the flip-door of the cage module.2,
Knowing the bird was stil there, the operator titted the cage
a second time thereby ‘double-dumping’.3. When the bird
failed to come out the second time the operator lowered
the cage module into the horizontal position and rolled it
away. As the cage module rolled away the bird fell out. The
operator then gently picked up the bird and placed it on the
conveyor belt. Initially | was unable to find a supervisor, $o

| completed my GCP task. After the task was completed, |
was able to track down [()(6)

DVB) and informed him I'd be issuing an MOI,
a said he'd be discussing the incident with the
operator and retraining him with subsequent disciplinary
action. A single bird event does not serve as any indication
of loss of process control (or regulatory non-compliance);
however, this type of GCP-inconsistent event(mishandling
of pinned/trapped birds) has been observed twice in the
past 90 days(9/11/2020 — 01J2015090111G;

7/24/2020 — O130615074224G).

45


Table: Noncompliance Reports in Response to FOIA2021-118

08:56 Thursday, January 7, 2021

EstNbr

EstName.

NR Id

NR#

Date

Task

TaskName

Regs

Description

Status

1

P4734

New Lee's Live
Poultry Market
Inc.

{7F6D67D9-C160
-43D5-ABC2-938
6096A88B0}

XKD3409
100813N
4

10/13/2020

04C05

Poultry Good
Commercial
Practices

381.65(b)

At 10AM while conducting routine ongoing GCP inspection
activities, | observed the following incident which is a
violation of 381.65(b) Kill floor employees had broken down
the bleeding cones in preparation for the end of the days’
lot and were proceeding with slaughtering silkies and
instead of using the bleeding cones, they were placing
them in the barrels. | observed several silkies jumping out
of barrels and flapping around trying to get out. |
immediately stopped operation and addressed the situation
with plant owner, Chen. Birds must bleed out thoroughly in
the cones until breathing has stopped in accordance with
good commercial practices. This is a noncompliance with
381.65(b). Failure to comply with good commercial
practices can result in further enforcement action. U.S.
Retain tag B-45182178 was applied to the birds and IIC
supervised the killing and placing into cones of the
remaining birds.

P4734

New Lee's Live
Poultry Market
Inc.

{A37A4CB3-DAC
D-420C-8C42-A6,
E4A815FDFE}

XKD3708
125305N
a

12/05/2020

04cos:

Poultry Good
Commercial
Practices

381,65(b)

CLOSED

Around 9:30 AM during normal operations, | observed the
kill floor employee place a live chicken that had not been
bled out nto the barrel for scalding. The barrel was moving
and | told them to stop and inside the barrel was a young
chicken flapping its wings around trying to get out. Upon
my return with the owner, | observed one of the kill floor
employee's ignore lIC direction to stop killing as he had
continued to place birds inside the barrels after being told
to stop. Kill floor was rejected with tag B-42078621 and
Chen was notified immediately of the noncompliance and
operations ceased temporarily while the situation was
addressed. This is an ongoing problem that needs to be
corrected immediately as itis associated with a previous
NR. Birds must bleed out thoroughly in the bleeding cones
before being placed into the barrels and when birds are
placed alive in the barrels it often results in injury to their
wings and possibly cadavers which is when the bird dies
by drowning and not slaughter. Birds that are not bled out
thoroughly are considered adulterated. This is a violation of

| 381.65(b).

OPEN

P18414

MB Consultants
LTD

{CFSECD6B-513.
4-4F60-AE66-0F
EB217F5D6A}

J¥125111
10418N-

11/18/2020

04c05

Poultry Good
Commercial
Practices

381.65(b)

AT 1200 while passing by live hang area IPP observed the
following non compliance.IPP observed one live chicken in
dead on arrival carcass bin. IPP spoke to Establishment
personal. IPP asked him to remove that live chicken from
bin and put in separate crate. of
live hang area was informed. This is failure to meet
381.65(b).

CLOSED



Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1243 Perdue Foods, LLC. XLB5310102 290CT2020 Finalized | Atapproximately 9:40 am, a brief power outage occurred
529G within the establishment (Perdue Farms P-1243). This

prompted me, Jo walk out onto the
evisceration floor where Tnobced both lines were stopped.
| proceeded to walk into the kill room to ensure the
establishment was taking appropriate measures
concerning the live birds in the stun machine; at this time
(9:42.am) | started a timer on my stopwatch,
During my time in the kill room establishment employees
were seen in the area, but no one was taking the initiative
to follow the establishment's humane handling procedures:
the water was not drained nor was the power turned off. At
approximately 9:47 am both lines restarted, and this is
when | stopped my timer which displayed 5 minutes and 23
seconds, which is how long the birds were left in the stun
machine with their heads submerged below water.
At 12:54 pm there was another brief power outage which
resulted in both evisceration/picking lines to stop. |
‘observed the same incident which occurred at 9:40 am;
line #1 resumed at approximately 12:58 am and line #2
resumed at approximately 1:00 Astatement
was provided to USDA from hich states:
“Handling of birds in stunner during prolonged periods of
downtime In the event a line goes down for greater that 3
minutes and the birds cannot be cleared thru the stunner
the following should occur. The water level will be drained
below the stunning grate, which will keep their heads out of
water plus power will be shut offto the stunner. This
addition to our program will be implemented beginning
Thursday night November 21, 2019.” The
establishment failed to implement the statement above.
Agency regulation require that the poultry be
handled in a manner that is consistent with Good
Commercial Practice, and that they do not die from causes
other than slaughter. Itis the establishment's responsibility
to ensure that the birds are slaughtered in accordance with
9 CFR 381.65(b). AMOI (record no.
XLB3410083705G) was written on August Sth, 2020 which
documented similar findings.

15


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Task

Date Code | TaskName Status

MO! Agenda

P7487

Koch Foods, LLC

SPG3105125
401G

01DEC2020 | 04C05 | Poultry Good
Commercial

Practices

Finalized

P7487

Koch Foods, LLC

SPG4622125
101G

01DEC2020 | 04C05 | Poultry Good
Commercial

Practices

Finalized

On 3rd shift November 29, 2020 at P-7487 Koch Foods,
while performing a routine Good Commercial Practices
Verification task, | {May at
approximately 00:20 observed on the{&@line, 2 birds
enter the scalder alive. | had the engineer call the
supervisors on the radio. | initially informed
live hang supervisor, that a GCP MO! would be written. |
then informed Drew Cole, 3rd shift plant manager, and
informed him that a GCP MO! would be written.

said that he would stay back and observe to see what the
issue is. | made an additional verification check, and
observed approximately 5000 additional birds enter the
scalder prior to the plant break, with no additional
deficiencies observed.

On December 2nd, 2020 at approximately 22:20 while
performing the Poultry Good Commercial Practices Task,
ere and [awar

observed a live bird enter the scalder on thel

Koch Foods Chattanooga, TN P-7487. The bird had its
head up, was blinking, and looking around. There was no
visible cut on the bird's neck. | notified Drew Cole, the 3rd
shift Plant Manager and Gary Tallent, the plant general
manager of the observations and of the forthcoming GCP
MOI. This MOI is similar to the MOls created on
11/29/2020, 11/30/2020 and 12/01/2020. MO!
SPG3105125401G MOI SPG4305120601G

MOI SPG5101115930G MOI SPG5423113030G

P7487

Koch Foods, LLC

SPG4305120
601G

O1DEC2020 | 04C05 | Poultry Good Finalized
Commercial

Practices

On 3rd shift at P-7487 Koch Foods 12/01/2020, while
performing a follow up directed Good Commercial
Practices Verification Task, iss]
observed 2 birds enter the scalder alive arou on
the B@ine. These birds were alive, alert, heads held up
and blinking. Drew Cole , 3rd shift Plant Manager was with
me when | observed them going in. The additional
observers assigned to monitor as a corrective measure
were in place when this occurred. We discussed further
options to bring process in control and that another MO!
would be issued.

57


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P7987 Amick Farms, LLC QKA3821125 07DEC2020 | 04C05 | PoultryGood | Open At approximately 2015 on 12/6/20, while performing a
907G Commercial Poultry Good Commercial Practices task to verify that the
Practices birds where hung on the line humanely, | [)(] {ayer

(b)(6)__}) saw several birds hanging off the live hang belt.

There were no associates hanging birds on the slaughter
line at the time. There were numerous birds piled on top of
each other, and many of the birds were dead. | concluded
that the birds had piled up on the belt, suffocated, and
died. | went outside to get an employee to call the
bacieSck sue sot Nea | crn
and | showed him what was going on. asked him to call
aa rear] thefioyr6y

(eer ‘ame, tumed off the live hang belt, and had
associates remove all the dead birds. | informed
Brazell that the plant would receive an NR or MOI, and!
informed my SPV. {v8 Tipfover_Fame to the live hang
area. There were dozens of dead birds being gathered up
by the establishment. He spoke to Ell
‘Superintendent Brazell informed i]
chemgrate (that the employees stand on) was stored
across the live hang belt. The cage dump associate
dumped birds onto the live hang belt. but there was no one
monitoring the birds dumped on the belt.
concluded that live birds were dumped onto other live birds
already on the belt, resulting in a pile of birds. Birds on the
bottom of the pile suffocated and died.
explained that there was a lack of communication by the
establishment employees. [ib] Asare notified Ifavar—pf
the poultry mistreatment and that it would be documented
inan Mol. also remained in the area until all the
dead birds were retrieved and to make sure no live birds
were mistreated. The establishment is reminded that
poultry must be slaughtered in accordance with good
commercial practices. Poultry that die from causes other
than slaughter are considered adulterated and must be
condemned. Employing humane methods of handling and
slaughter reduces the likelihood of producing adulterated
product.

63


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P1254+V125
4

Koch Foods of Ashland, LLC

YFA0514100
516G

160CT2020

04C05

Poultry Good
Commercial
Practices

Finalized

Koch Foods of Ashland P1254, 515 Tyson Rd. Ashland,
AL 36251 On October 16, 2020 at approximately 9:55
hours, | observed less than perfect Good Commercial
Practices (GCP) near the cage dump area of the
establishment, While performing Ante Mortem Inspection
and a Good Commercial Practice Check, | observed one
live young chicken in the dead-on-arrival (DOA) dumpster
that contained approximately twenty DOA chickens
adjacent to the cage dumper. The live chicken was
observed sitting upright at the top of the DOA pile,
breathing regularly with its eyes closed. | looked fora
member of the management team, | could not find anyone
in the immediate vicinity or in their offices, so | called the
plant manager, Mr. Tim Worthy and explained my findings
at 10:01 hours. He stated he would get it taken care of. |
proceeded back outside to finish my GCP task and verified
that the live chicken was removed from the DOA dumpster
and placed in the adjacent holding cage. A copy of this
Memorandum of interview will be forwarded to appropriate
personnel in the Distri esnecthully submitted on

October 16, 2020, BIG)

P1254+V125
4

Koch Foods of Ashland, LLC

YFA5413112
002G

02NOV2020

04C05

Poultry Good
Commercial
Practices

Finalized

Koch Foods of Ashland P1254, 515 Tyson Rd. Ashland,
AL36251 On November 2, 2020 at approximately 09:15
hours, | observed less than perfect Good Commercial
Practices (GCP) near the cage dump area of the
establishment. While performing Ante Mortem Inspection
and a Good Commercial Practice Check, | observed one
live young chicken jn the dead-on-arrival (DOA) dumpster.
The dumpster was nearly full and contained approximately
fifty DOA chickens and litter debris. The chicken was
observed at the back, right comer of the dumpster when
looking into it. It was near the top of the DOA pile, partially
covered by another DOA young chicken. | observed the
bird move its head and it exhibited irregular gasping

respirations. | notified|
pe }f my findings atusrT7 nours. Pram

personnel removed the young chicken from the dumpster,
verifying it was alive, and placed it in the adjacent holding
cage. At 10:05 hours, after finishing my check, | returned
to the office and called Tim Worthy, plant manager, to
discuss my findings. He informed me that he and other
department managers were already working on corrective
actions. A copy of this Memorandum of Interview will be
forwarded to appropriate personnel in the District Office.

est submitted on November 2, 2020, [ih] axev]

7


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

M20322+P20
322

Equity Group Eufaula Div LLC

ATF1001124
102G

02DEC2020

04C05

Poultry Good
Commercial
Practices

Finalized

On Tuesday, December 2, 2020, at approximately 0030
hours, |, ear SPHV, was conducting a
Review and Observation of Good Commercial Practices in
the Small bird Live hang area. | observed a pile of 15 dead
birds at the end of the live hang belt. There was a live bird
on top of the pile; one live bird comingled, being partially
covered with dead birds over the back half of it's bady,
After about 15 seconds, my presence was noticed, and a
plant team member came over and picked up the 2 live
birds. | then moved about 2-3 dead birds and found
another live bird underneath. This bird flapped a wing, and
lifted it's head. | pointed it out with the flashlight, and the
team member picked it up and hung it on the line.L
immediately notified
BQO of the incident. within the hour, (noted [NO]
Koy6)_ fone) Jand (oye) |e

foyer Jofthe
incident. Live birds intermingled, and/or covered with dead
birds may die by means other than proper slaughter.

M2130+P213
0

Cooper Farms Processing

HEF3702104
614G

140C€7T2020

04C05

Poultry Good
Commercial
Practices

Finalized

At approximately 0250 on 10/14/2020 while performing a
routine Good Commercial Practices task | observed that a
top cage door on trailer CF59 was damaged and bent
‘outward so that approximately half of the cage was open.
Live turkeys were observed in the affected cage with
several being close to the open cage door. There is a
considerable distance between the top open cage and the
ground. No loose turkeys were observed at this time.
was notfied ofthe damaged

cage door,

3


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P510 House Of Raeford Farms RHB1510121 08DEC2020.| 04C05 | PoultryGood | Finalized | Ms. Nicole Reynolds, Plant Manager, P-510 House of
5086 Commercial Raeford Rose Hill, NC 28458 Ms. Reynolds At
Practices approximately 0729 while performing the Good Commercial

Practices Verification task, | observed a live bird about ta
enter the scalder. The bird at the time of my observation

had normal rhythmic breathing, eyes open and blinking
btheheadelevated, Ubifby6)
no was present during my observation
immediately removed the bird from the line before it could
enter the scalder. After the bird was removed from the
line, it was observed that there was no cut on the neck

which would not have allowed the bird to bleed out
properly. [bil jave the bird to

a who took the bird back to live hang to

show it to the backup cutter. [hil [ii] placed the bird back
onto the kill line to allow it to go back through the stunner
and the kill blade to allow proper bleeding,

instructed the ind cutter to pay more attention to all
birds qoing through. _| discussed my finding with Ill

po po a El noting them of the MO! and the
establishment's failure to comply with 9 CFR 381.65 (b)
which states: Poultry must be slaughtered in accordance
with good commercial practices in a manner that will result
in thorough bleeding of the carcasses and ensure that
breathing has stopped prior to scalding.
rrorama te was also notified my findings. There was
a similar occurrence documented on 11/23/20 on MOI
RHB4811114123G. Ms. Reynolds this MO! will be
forwarded to the District Veterinary Medical Specialist
(DVMS) in case additional follow-up is recommended.
Hfyou have any questions or concerms regarding the

above, please contact in]f(by(6) or ial oe]

ya) RE loectiuke

38


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P3

Mountaire Farms of Delaware, Inc,

0CG2922115
718G

18NOV2020

04C05

Poultry Good
Commercial
Practices

Finalized

At approximately 2300 hours on November 18, 2020,
Inspector EBA EENSI——] while completing
GCP/Antemortem verifications, the following was observed.
At Establishment P3, below the roller line leading to the
east live bird dumper, a dead bloody chicken was found
about 25 feet from the loading end. The skin and feathers

were scraped off the breasts and when Live Hang

picked up the bird, it was obviously
dead. The roller line consists of hydraulic powered rollers
and stee! grates between the gaps from the rollers. Looking
directly above where the bird was found, the steel grate
was torn open, and there was fresh bload on the jagged
edges of the grate tear. | also showed Live Hang

this deficiency as well. Itis reasonable
to conclude that this chicken died by getting caught in the
steel grate opening, not slaughter. No other significant
findings were observed. tis recommended that
establishment management review the Federal Register on
"Treatment of Live Poultry before Slaughter", published
September 2005 for FSIS recommendations concerning
treatment of live poultry prior to slaughter.

was notified that this MOI will be forwarded to the
District Office and the District Veterinary Medical
‘Specialist (DVMS) in case additional follow-up is
recommended. Sincerely, HEME] [bye
Mountaire Farms of Delaware, Establishment P3 29005
John J Williams Highway Millsboro, DE 19966

P3.

Mountaire Farms of Delaware, Inc.

0CG3109122
602G

02DEC2020

04C05

Poultry Good
‘Commercial
Practices

Open

On the moring of December 2, 2020 at approximately 857
hours while completing Good Commercial

Practices / Antemortem verifications, the following was
observed [nvr found a crushed bird
in bay 5 of the live holding shed under a trailer. The
breasts were exposed, feathers and wings still attached to
the carcass. This bird was crushed flat and muddy,
suggesting that it had been lying on the ground for several
hours and was ran over several times. | showed the
crushed bird to live hang He hada
employee scoop up all the parts of the bird with a shovel
and dispose of it. It is reasonable to conclude that this bird
died by being ran over by a truck tire, not by slaughter. No
‘other significant finding were observed. Itis
recommended that establishment management review the
Federal Register on "Treatment of Live Poultry before
Slaughter", published September 2005 for FSIS
recommendations concerning treatment of live poultry prior
to slaughter. was notified that this MOI
will be forwarded to the District Office and the District
Veterinary Medical Specialist (OVMS) in case additional
follow-up is recommended. Sincerely,

SCSI Mountaire Farms of Delaware, Establishment P3
29005 John J Williams Highway Millsboro, DE 19966,

26


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M17980+P17 | Pilgrim's Pride Corporation ZBB3613115 48NOV2020 | 04C05 | Poultry Good | Finalized | On Wednesday. November 18, 2020 at approximately
980 018G Commercial 1130 hours, |, (6) [5¥6) 1} was notified that
Practices USDA inspector station 3 had held back a bird for

veterinary disposition, After observing this bird, it was
determined to be a cadaver. This bird was then shown to
the inspection helper to record the disposition and was
placed in the condemn barrel. At 1310 hours, while
performing a Good Commercial Practices verification in
the Live Hang Area, | observed a bird that was hung up on
the transfer belt at the cage dumper. | notified reve
production supervisor, to stop the cage dumping
until the bird could be removed without being further
crushed, Upon removal of the bird, it was determined to
have already died from being crushed in the belt. It had
gotten hung up at the junction of the two transfer belts. [i]
said that he would notify maintenance to fix this hole
between the two belts where the birds were getting stuck.
At approximately 1317 hours, | observed two live birds
entering the scalder in the picking room. After exiting the
scalder, the both of the bird's necks and heads were
engorged with blood and dark red in appearance. There
was no cut to the neck on either bird. A production team
member at the rehang station was asked to remove this
bird off the line and | then showed [all Lava) 1 [(6)(6] both
of the cadaver birds. He then took the birds to show the
back-up killer and placed the birds in the condemn barrel.
The PPIA (21 U.S.C. 453(g)(5)), and 9 CFR 381.90,
provide that poultry carcasses showing evidence of having
died from causes other than slaughter are considered
adulterated and must be condemned. According to
regulatory requirements, poultry are required to be
slaughtered ina manner that is consistent with good
commercial practices and in a manner that results in
thorough bleeding to ensure that breathing has stopped
prior to scalding, The establishment was notified that this
MOI will be forwarded to the District Office and the District
Veterinary Medical Specialist (DVMS) in case additional

follor mended. Respectfully, [da]

2


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P6505,

Norman W. Fries, Inc,

BBA1107120
417G

17DEC2020,

04C05

Poultry Good
Commercial
Practices

Open

On Tuesday, December 15, 2020, at approximately 0923
hours at Claxton Poultry, P6505 located in Claxton, GA.
Il foyey observed a live and conscious bird

caug the two receiving belts for the
Evisceration Department's live hang system. One of the
belts moves in an east to west direction and the other runs
in a north to south direction. At the point where they cross
one another there was a pile of what appeared to be dead
birds that were mangled. Portions of the dead birds had
tumed black in color from the belts continually moving
across them. The live bird was lying on its keel bone on
the belt that moves east to west. The bird's head was
facing me, its eyes were open, it's left leg was caught in
between the belts, it was breathing at a slow rate, appeared
lethargic, and was making an abnormal repetitive noise. |
was unable to immediately make contact with a Lead or
Management team member to notify them of the live bird
that was caught in the belt. | observed the Establishment
team member that is responsible for operating the cage
dump system dump two cages of birds onto the east to
west belt and north to south on top of the live bird. The bird
stuck in an area where the birds were dumped and was
subsequently covered by live birds until the conveyor belt
moved the live birds down the line. Atapproximately 0928
hours | notified the dump system team member to stop
dumping cages. At that point, a live hang team member
climbed onto the stopped belt which runs north to south in
an effort to retrieve the bird. However, this belt is an
automatic intermittently moving belt and the belt began to
move with live hang team member on the belt. This
knocked the team member down. Then apparently
someone tured the belt off which allowed the team
member to retrieve the live bird. Establishment personnel
elected to perform humane euthanasia of the bird by rapid
cervical dislocation.
was immediately notified of my observations and the
forthcoming GCP MOI.

P6529

Koch Foods of Alabama

AVI55051122
30G

30NOV2020

04C05

Poultry Good
Commercial
Practices

Finalized

Tuesday on night 11/10/2020 while conducting Good
Commercial Practices (GCP) Verification task in the Live
hai n in poultry receiving department, | , [aid{(o)6)
feat hade the following observations. There was 1 weak,
approximately 56 days old live chicken in the
Dead-on-arrival (DOA) red condemn barrel which had
approximately 7 to 10 DOA chickens in the red condemn

barrel. | notified{b)(6) jof
my findings. lorwood removed the live chicken from
the condemn barrel. | also informed plant management

pu TONS jand [sey
(oye) TD) of my findings and the

forthcoming GCP MOI.

50


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P48304 Lincoln Premium Poultry YOT0707112 OGNOV2020 | 04C05 | PoultryGood | Finalized | On November 5, 2020, at approximately 0430 hours, while
606G Commercial conducting antemortem inspection at Lincoln Premium
Practices Poultry (Est. P48304) in the lairage room, | observed a

poultry goad commercial practices (GCP) concem. The
top screen of a transport module on Line 3 was not closed
all the way, leaving a gap where the chickens could get
out, The tops of the transport modules are approximately
10-15 feet above the floor. Below this module, there was a
dead chicken on the floor with blood on the wing feathers
and under its head. There were also two live chickens on
the floor beneath this module. | observed another loose live
chicken perched on the top edge of a different transport
module on Line 3, approximately 15 feet off the ground.
The screen covering the module was not closed all the
way. | observed three loose live chickens on the floor
underneath line 2, and one loose live chicken under line 1.
There were also two chickens with their wings stuck
between the module trays on line 2. | notified live hang
the poultry good commercial
practces concem, He and another establishment
employee retrieved the live loose chickens and placed
them back into modules. He was not able to retrieve the
loose chicken perched on top of the module at that time
due to safety reasons. Loose live birds in the
establishment is not consistent with poultry good
commercial practices and results in an increased risk of
live birds dying by means other than slaughter. The Poultry
Product Inspection Act and Agency regulations (9 CFR
381.65(b)) require that live poultry be handled in a manner
that is consistent with GCPs. The establishment is
encouraged to maintain the standards of GCP through a
systematic approach that focuses on treating poultry in
such a manner as to minimize excitement, discomfort, and
accidental injury the entire time that live poultry is held in
connection with slaughter. Establishment management
may review Federal Register notice “Treatment of Live
Poultry before Slaughter" Fed. Reg. 56624 (September 28,
2005), for FSIS recommendations concerning the
treatment of live poultry before slaughter. | met with First
exer Jto discuss the
situation and notify him that a GCP MOI would be
documented. [hyf6)____Jaddressed the issue right
away. There was a Shortstaffing issue in live receiving at
the time the modules were unloaded. He said he would
review the expectation that all modules should be checked
carefully, regardless of staffing, even if this necessitated a
change in process and instructed the live receiving
employees to closely monitor the modules when they are
unloaded from the trailers. This MO! will be forwarded to
the Denver District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is

recommended. Regards, [bW6)

34


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P522 Sanderson Farms, Inc. (Processing Div) 1KB06161013 120CT2020 | 04C05 | PoultryGood | Finalized | On 10/09/2020, while La] [EY] EWA) was performing
126 Commercial an ante-mortem inspection of birds, he informed me that
Practices the process was out of control at the live rehang area.

Upon arrival, at approximately 1840 hours; | Me
[exe 1 [6)(6)_] anc Lad Eaves 7 Gal observed
numerous live birds on the floor, down the entire length of
the conveyor belt (outside line). While in the process of
looking for a supervisor, an employee was present on that
side of the conveyor and began to retrieve birds one by
one from the floor and aggressively/orcefully throw then
onto the conveyor, which could cause injury to the birds.
Supervisor |(6)(6)_][iS6] was present on the inside line
of rehang belt. The employee was still in the process of
removing birds from the floor. | pointed to the
mistreatment/mishandling of birds in process.
[XG] immediately stopped the employee and
removed him from the area. (b)

informed me that the employee will be written up and
receive training. In an interview with Haid [by6) he
informed me that progressive disciplinary action and
training will be conducted with the employee to correct the
issue. Preventing the mistreatment of poultry decreases
the chances of producing adulterated carcasses.
Management is advised to adhere to Good Commercial
Practice. (ey(6)_] and

were notified verbally and with this MO! in writing. This
issue will be discussed in the upcoming

USDA/Management Weekly Meeting.
rave Ne I (eyey



Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P425+V425_ | Northem Pride, Inc. MYG0808111 48NOV2020 | 04C05 | PoultryGood | Finalized | Thursday 11/12/20 at.approximately 11 am | was called to
318G Commercial the evisceration by [RYAY
Practices He informed me that he had condemned 4 birds as

cadavers. | proceeded to the stun/kill area where |
preformed a 5 minute, 200 bird check. During my check |
observed 2 live birds. | immediately informed [b)

xe and Plant manager Eric Eastman

of my findings. At approximately 11:50 am | preformed
another 5 minute, 200 bird check, and observed no issues
at this time. Mr. Eastman informed me that the corrective
action taken was increasing the amperage of the stunner.
At approximately 1:15 pm | was called back to the line by
where he had hung-back a
cadaver bird at my request. After further examination of
the carcass | determined that the neck cut was ineffective.
| then informed Eric Eastman, [bY6) | and
fof my findings. The kill continued
until approximately 2:00 pm with no further issues. A
meeting was held Friday 11/13/20 between myself,

Wer ] and fEWaY
1 was then informed that the 2nd corrective

action that was faken the previous day was instructing the
backup cutter to be more attentive in watching for live
birds, and make more thorough cuts.

29


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1137 ‘Tyson Foods, Inc. ¥BO5814120 03DEC2020.| 04C05 | PoultryGood | Finalized | On Wednesday 12/02/2020 at 1901 hours, while
703G Commercial performing a Good Commercial Practice task in the live
Practices hang room, |, lobserved two (2) live, weak

young chickens in the catch bin at the end of the conveyor
belt with approximately ten (10) dead-on-arrival chickens
(DOA). Both chickens, one too small to be processed and
the other of normal size, were underneath the pile of
DOAs. No supervisor was available at the time, therefore
the ECON (5716) | was made aware of the
situation. He elected to euthanize the chicken that was too
small to be processed by cervical dislocation and the other
chicken was hung back on the line for processing.
ey was made aware
ofthe situation. At 1934 hours, another young, live
chicken was observed in the catch bin at the end of the
conveyor belt with a DOA chicken. was again
made aware of the situation and removed the chicken from
the catch bin, He then hung the chicken on the line to be
processed fipy(e) [YG] was made
aware of the situation. This has been an ongoing issue
and was previously discussed and documented in two
weekly meetings, dated November 10, 2020 and November
24, 2020, Tyson management has had a meeting with plant
personnel, specifically live hangers, on how to verify if a
chicken is stil alive and breathing before placing it in the
catch bin with the DOAS. This type of situation presents
concern for inspection personnel as there is potential for
the live birds to be smothered by the DOAS. Regulations
require that live poultry be handled in a manner that is
consistent with good commercial practices and that they
not die from causes other than slaughter. This MO! will
be forwarded to the District Office and the District
Veterinary Medical Specialist (OVMS) in case additional
follow-up is recommended.

13


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Task

Date Code | TaskName Status

MO! Agenda

Practices in order to minimize any suffering or harm to the
birds and ensure that they do not die from causes other
than slaughter. FSIS recommendations conceming the
treatment of live poultry before slaughter are presented in
Federal Register Notice Vol. 70, No. 187 [Docket No.
04-037N], published September 2005, and a copy of this
document can be provided to management upon request.
Atthe point when | discussed the comments and actions
by aiaway hin indicated that they had
performed a time study and that there is an optimum
setting for the speed of the hanging belt and that the speed
should not be changed and he would be addressing that
item. [I f6)(6) | acknowledged that a primary issue
appeared to be That too many chickens were being
dumped too rapidly causing the belt to be overcrowded. He
also stated that there should be a person positioned at the
fast hanging station on each kill ine and he would address
the staffing situation to find out why this occurred and why
no one had responded earlier when it was apparent that
birds were falling off of the belt. To conclude the meeting,

assured that the proper handling and
treatment of the live chickens is viewed as a serious matter
and that Tyson Foods is committed to their Live Animal
Wellbeing program and that a refresher training would be
conducted with all members of the live receiving
department tonight. This MO! has recorded in summary
all the pertinent matters discussed during the meeting with
plant management and a copy will be forwarded to the
District Veterinary Medical Specialist (DVMS) in the
District Office in case additional follow-up is

recommended. Respectfully, ]foye) id

Est. P806, Tyson Foods, Inc.

65


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

Task
MOINbr Date Code | TaskName Status

MO! Agenda

P6616+V661
6

Peco Foods, Inc,

1RE58121033 230CT2020 | 04C05 | Poultry Good Finalized
2G Commercial
Practices

IS _] Peco Foods, of MS
Sebastopol ONG)
15292 Hwy. 15S. Sebastopol, MS 39359 [d]|

At approximately 1143 hours while performing the
routine PHIS Poultry Good Commercial Practices
verification task, the following less than Good Commercial
Practices incident was observed at the entrance of the
scald tank on picking line #1. A live bird with head tucked
over the back and no visible cut to the neck, and rhythmic
breathing, from a random 500 bird subgroup entered the
tank. Zifby6)
and [el /ere notified at approximately 1152 and
1154 h tively. A retest of picking line #1 was
performed at approximately 1156 hours on a random 500
bird subgroup. No live birds entered the scalder durin
this observation. A meeting was held with fer
in the Quality Assurance office to discuss the single
incident of a bird entering the scalder. fava]
stated the back up cutter would be retrained. [h]

was notified at this time, a Memorandum of

Interview was be issued documenting the incident. This
Good Commercial Practices Memorandum of Interview will
be discussed at the next regularly scheduled week
meeting with plant management. Respectfully, ran ST
ey ] Starkville
Circuit Office of Field Operation, DO-90 Jackson Food
Safety and Inspection Service, USDA 713 S. Pear
Orchard Rd. Ste. 402 Ridgeland, MS 39157
[= usda.gov cc: ral

[pvr {it}
Damon Ranftle, DDM __ [ib] Kermit Harvey , DDM.

fol rer ) Hee ]

P6638

Pilgrim's Pride Corporation

UDG4605115 18NOV2020 | 04C05 | Poultry Good Finalized
918G Commercial
Practices

At approximately 0505 hours on Wednesday, November
18, 2020 at Pilgrim's Pride P-6638 Enterprise, AL, | was
performing a Good Commercial Practice verification task
and observed (1) live bird entering the scalder on Picking
line #1. The bird was smaller in stature than the other birds
trailing in front of and behind it with its neck hyperflexed.
There were no observed cuts to the neck. | notifiediawar]
bE,

(oye) Jor my observations and noted

of this Good Commercial Practice Memorandum of
Information (GCP MOI) describing their Less than Poultry
Good Commercial Practices. A copy of this Memorandum
of Information (MO)) will be forwarded to the Jackson
District Office and the District Veterinary Medical

Specialist (DVMS), Respectfully Submitted, Sm
eye) Cefed ed TC) Cell
a

(GH

51


Table: MOls in Response to FOIA2021-118 07:59 Friday, January 8, 2021
Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P7085+V708 | Tyson Foods, Inc HMO0015123| — 01DEC2020:| 04C05 | PoultryGood | Finalized | At approximately 0845 hours, while performing ante
5 001G Commercial mortem inspection on Lot4 — trailer 053, | observed a
Practices chicken with its head caught between the cage door and

the top of the cage frame which resulted in the
strangulation death of the chicken. This cage was located
on the top level, 3rd row from the tail end of the trailer. |
immediately went to locate a person in management. |

asked away to have GPM.

BNE) Tand

to meet me in the live shed. When faa Jand
arrived, | showed then the chicken
that had been strangulated when the head was caught
between the door and the cage frame. | explained to both
of them that since the space between the door and the
cage frame was too small for the chicken to have stuck its
head through the gap, this had to have occurred while the
chickens were being loaded into the cages and the door
was shut on the birds neck, thus trapping his head which
resulted in strangulation and death. | then determined the
need to look at all the trailers in live shed to ensure that no
other chickens had been subjected to this treatment. On
another trailer, | observed a live chicken with its wing firmly
trapped between the door and the cage frame. The
chicken was notable to move because the cage door had
been closed directly on the major wing bone called the
humerus. | showed [bil (GWeTthe caught wing on the
chicken and expressed my concern that the entrapment of
the wing could result in the breakage of the humerus when
the cage door opened to be dumped onto the belt._|
informed both(¥6)_—_ Jandfay(6y
the observations that were mat zetthe
basic requirements for Good Commercial Practices in
which chickens would be handled in a humane fashion. |
informed them that although USDA has not observed these
types of issues before at this establishment, the mere fact
that two incidents were observed within a few minutes of
each other may indicate that a trend may be developing.
BVay tadioed for AWAY
come to the live shed so that he could show him
the GCP issues that had been identified. USDA
encourages the establishment to review their GCP written
program and improve on the plan that is already written to
avoid these incidents in the future. USDA also encourages
the establishment to respond to this MOI.

53


Table: MOls in Response to FOIA2021-118

07:59 Friday, January 8, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P1243

Perdue Foods, LLC.

XLB4009110
116G

16NOV2020

Finalized

At approximately 8:25 am, while performing a routine
Poultry Good Commercial Practice verification, |

[aay Lonjobserved numerous (roughly 20 - 25 birds)
DOA carcasses in the small enclosure at the DOA belt
drop off. During my observation, an establishment
employee was actively removing live and dead birds from
this enclosure. As | continued to observe this employee
remove dead birds from the top of the pile, | noticed live
birds which were previously undemeath the dead birds,
breathing. After these observations were made

(er nd [BY6) ]were
notified. ‘Agency regulation require that the poultry
be handled in a manner that is consistent with Good
Commercial Practice, and that they do not die from causes
other than slaughter. Itis the establishment's responsibility
to ensure that the birds are slaughtered in accordance with
9 CFR 381.65(b).

P1243

Perdue Foods, LLC.

XLB2309120
119G

19DEC2020

04C05

Poultry Good
‘Commercial
Practices

Finalized

On December 19th, 2020 at approximately 10:15 am, while
performing a routine Poultry Good Commercial Practice
(GCP) verification, | [fexq{(5)(6) observed a live bird

in the DOA bin outside by the cage dumping area. |
‘observed this live bird with green denaturant on

its feathers, surrounded by dead carcasses and attempting

to stretch out its neck and open its mouth gasping for air.
Immediately after this observation was made | asked an

employee to call for the D6)
When Kell) =] arrived, | informed him of my
observations and the forthcoming GCP MOI. Agency

regulation require that poultry be handled in a manner that
is consistent with Good Commercial Practice, and that they
do not die from causes other than slaughter. Itis the
establishment's responsibility to ensure that the birds are
slaughtered in accordance with 9 CFR 381.65(b).

16