Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 1

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

15 M12445 Kulana Foods, Ltd. WYF09161

10415G

15NOV2018 04C02 Livestock

Humane

Handling

Finalized The CSI observed a large sow brought into the

stunning area for electrical stunning. A stunning

attempt was applied, and the sow squealed,

remained standing, and was observed to be alert

and looking around. The operator then made

three additional ineffective stunning attempts

with the electrical stunning device. During all

stunning attempts, the sow stood with muscles

rigid and tense indicating that an electrical stun

had been applied. However, following each

stunning attempt, the sow was immediately alert,

standing, and was looking around. Additionally,

during the fourth stunning attempt, the sow

squealed again and laid down in lateral

recumbency but was still observed to be

conscious, as it was looking around with rapid

open mouth breathing.  The CSI informed the

establishment operator that repeated attempts to

stun with the electrical stunning device were

ineffective, and that further action needed to be

taken immediately to render the sow

unconscious.  The establishment employee then

retrieved a hand-held captive bolt gun from the

cattle stunning area by climbing a ladder to gain

access to the area. The charges for the captive

bolt gun were then retrieved from their storage

location in another room. After several minutes, a

fifth stun was applied with the hand-held captive

bolt which successfully rendered the sow

unconscious.  The CSI informed the stunning

operator and establishment management that

this was a noncompliance and placed US Rejected

Tag # B43042868 on the stunning area. The CSI

then informed the establishment that they would

be contacting the Denver District Office through

supervisory channels.
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 2

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

15 M12445 Kulana Foods, Ltd. WYF07111

21927G

27DEC2018 04C02 Livestock

Humane

Handling

Finalized At about 1220 on 12-26-18 at Establishment

M12445, the CSI observed a truck back up to the

higher unloading dock and open the tail gate.

There was one pig in the truck that was tied down

to the truck by a front foot and a back foot in a

lying position. Two men proceeded to untie the

pig from the truck bed. The pig stayed lying and

refused to stand. The two men began to pull the

pig out by the ropes that were tied to its feet as it

remained laying. The CSI informed the men that

they cannot drag a conscious pig. The men

stopped pulling the ropes and were trying pushing

measures and sounds to get the pig up. The pig

refused to stand so they lifted the pig up and

carried it out of the truck. Then they put the pig

down and she stood. They then pulled on the

ropes and she walked. After the CSI watched the

men cut the rope off the feet of the pig, the CSI

informed establishment President/GM Mr. Brady

Yagi of the occurrence, and he went outside to

talk with the men.

15 M12445 Kulana Foods, Ltd. WYF56091

21227G

27DEC2018 04C02 Livestock

Humane

Handling

Finalized
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 3

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

25 M17D Smithfield Packaged Meats Corp. WLJ56071

24818G

18DEC2018 04C02 Livestock

Humane

Handling

Finalized HATS Category IV – Ante-mortem Inspection On

12/14/2018 at approximately 1220 hours, while

performing antemortem inspection in the barns, I

observed questionable behavior by a truck driver

who was unloading hogs from his trailer. I was

standing in the alleyway between pens 301 and

501 when I observed a truck driver unloading

hogs from his trailer into the West Side Unloading

Alley #2.  The truck driver was a long distance

from where I was standing (approximately 100 to

150 feet away).  From my vantage point I could

see up the truck’s unloading ramp.    The truck

driver was moving hogs from the upper deck

down the trailer’s unloading ramp.  A group of 5-6

hogs had bottle necked at entrance of the barn, at

the bottom of the truck’s unloading ramp, just

prior to the company tattooer.  The trucker was

facing towards me, standing behind the group of

hogs, attempting to get them to move into the

barn.  One of the hogs was facing away from me

(and facing towards the trucker). For driving

implements the trucker was using a plastic jug

with BB’s in it and a sort board.  I observed the

trucker put the jug in close proximity to the hog’s

face (the hog was still facing away from me.)  The

trucker was using wrist flicks to use the jug, not

pronounced arm movements with a striking

motion.  Because of the vantage point and

distance of my location, I could not definitively

determine that the trucker was contacting the

hog’s face.  I did not observe the hogs jumping

erratically or hear them vocalizing.  The hogs were

deadlocked in the position. 

 was standing next to me and immediately

called for the trucker to stop moving the hogs.  A

company employee went into the trailer to help

the trucker move the remaining hogs off the

trailer without incident.     I spoke to

 and about my

observations.  I told them that I could not

(b) (6) (b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 4

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

definitively say that the trucker was striking the

hog in the face but reminded them that this

behavior was unacceptable, should it occur

 said that he would discuss this with his

employees.

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 5

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

25 M17D Smithfield Packaged Meats Corp. WLJ41071

23529G

29DEC2018 04C02 Livestock

Humane

Handling

Finalized HATS Category VI - Electric Prod/Alternative

Object Use At approximately 1045 hours, while

entering the barn to perform antemortem

inspection, I observed an employee using the

rattle paddle in an aggressive manner but could

not confirm that there was contact with a hog. I

was standing near the northwest side of pen 504. 

I was observing employees move hogs off the

west scale, which is approximately 50-70 feet

away.  The small door on the on the northwest

side of the scale was being utilized to tattoo hogs

as they left the scale.  The large scale gate on the

north side was closed, obstructing my view of the

hogs.  I saw an employee standing south of the

scale using a rattle paddle to drive hogs

northward through the small open door to get

tattooed. I observed the employee with the

rattle paddle gradually increase the intensity of

the striking motion.  The motion started with

using the rattle paddle below the shoulder at a

moderate speed and gradually shifted to picking

the paddle up above the shoulders and repeatedly

swinging the paddle downward in a very fast

motion.  Because the gate was obstructing my

view of the pigs, I cannot definitively say the

employee was contacting the hogs with these

aggressive paddle swings.  Due to the small size of

the pen, I thought it was likely the employee was

contacting hogs and not striking the ground. I

yelled from my position to get the employees

attention and motioned for the employees to stop

using the paddle.  I discussed my findings with

 and .  I told

 if hogs are not moving well, hitting them

harder is typically not the ideal solution. Again, I

cannot definitively say the hogs were being hit. 

But if they were being struck with the rattle

paddle with the motions I observed, it would be

considered excessive use of a driving implement.

(b) (6) (b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 6

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

25 M20863 JNB, Inc. PNA24141

05905G

05OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/1/2018 through 10/5/18 at

6:05am I preformed extra duties for Hat

Categories at EST.20863. Stunning 1hr , conscious

animals on the rail none on conscious for 1 hr. I

review the records that designate monitor is

checking every 5 sow, I observed the Supervisor

cleaning the 22 magnum and the stunners daily, I

reviewed the SOP plan.

25 M20863 JNB, Inc. PNA33091

03213G

13OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/8/2018 through 10/12/18 at

6:05am I preformed extra duties for Hat

Categories at EST.20863. Stunning 1 hr, conscious

animals on the rail none on conscious for 1 hr. I

review the records the that the designate monitor

is checking every 5 sow, I observed the Supervisor

cleaning the 22 magnum and the stunners daily, I

reviewed the SOP plan.

25 M20863 JNB, Inc. PNA34091

04313G

13OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/8/2018 through 10/12/18 at

6:05am I preformed extra duties for Hat

Categories at EST.20863. Stunning 1hr, conscious

animals on the rail none on conscious for 1 hr. I

review the records the that the designate monitor

is checking every 5 sow, I observed the Supervisor

cleaning the 22 magnum and the stunners daily, I

reviewed the SOP plan.

25 M20863 JNB, Inc. PNA35091

05213G

13OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/8/2018 through 10/12/18 at

6:05am I preformed extra duties for Hat

Categories at EST.20863. Stunning 1 hr, conscious

animals on the rail none on conscious for 1 hr. I

review the records the that the designate monitor

is checking every 5 sow, I observed the Supervisor

cleaning the 22 magnum and the stunners daily, I

reviewed the SOP plan.
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 7

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

25 M20863 JNB, Inc. PNA04171

00119G

19OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/15/2018 through 10/19/18 at

6:00am I preformed extra duties for Hat

Categories at EST.20863. Stunning 1hr , conscious

animals on the rail none on conscious for 30 min,

I review the records the that the designate

monitor is checking every 5 sow, I observed the

Supervisor cleaning the 22 magnum and the

stunners daily, I reviewed the SOP plan.

25 M20863 JNB, Inc. PNA06171

05919G

19OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/15/2018 through 10/19/18 at

6:00am I preformed extra duties for Hat

Categories at EST.20863. Stunning

45min , conscious animals on the rail none on

conscious for 1 hr. I review the records the that

the designate monitor is checking every 5 sow, I

observed the Supervisor cleaning the 22 magnum

and the stunners daily, I reviewed the SOP plan.

25 M20863 JNB, Inc. PNA08171

05719G

19OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/15/2018 through 10/19/18 at

6:05am I preformed extra duties for Hat

Categories at EST.20863. Stunning 1hr , conscious

animals on the rail none on conscious for 1 hr. I

review the records the that the designate monitor

is checking every 5 sow, I observed the Supervisor

cleaning the 22 magnum and the stunners daily, I

reviewed the SOP plan.

25 M20863 JNB, Inc. PNA11171

03219G

19OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/15/2018 through 10/19/18 at

6:05am I preformed extra duties for Hat

Categories at EST.20863. Stunning

45min , conscious animals on the rail none on

conscious for 1 hr. I review the records the that

the designate monitor is checking every 5 sow, I

observed the Supervisor cleaning the 22 magnum

and the stunners daily, I reviewed the SOP plan.

 did his observations no deviancies

were found.

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 8

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

25 M20863 JNB, Inc. PNA13171

02519G

19OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/15/2018 through 10/19/18 at

6:05am I preformed extra duties for Hat

Categories at EST.20863. Stunning

45min , conscious animals on the rail none on

conscious for 45 min, I review the records the that

the designate monitor is checking every 5 sow, I

observed the Supervisor cleaning the 22 magnum

and the stunners daily, I reviewed the SOP plan.

25 M20863 JNB, Inc. PNA58101

00029G

29OCT2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/22/2018 through 10/26/18 at

6:10am I preformed extra duties for Hat

Categories at EST.20863. Stunning

30min , conscious animals on the rail none on

conscious for  30 min, I observed employee

knocking for 30min, I review the records the that

the designate monitor is checking every 5 sow, I

observed the Supervisor cleaning the 22 magnum

and the stunners daily, I reviewed the SOP plan.

25 M20863 JNB, Inc. PNA08131

13402G

02NOV2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/29/2018 through 11/2/18 at

6:05am I preformed extra duties for Hat

Categories at EST.20863. Stunning

15min , conscious animals on the rail none on

conscious for 15 min, I review the records the that

the designate monitor is checking every 5 sow, I

observed the Supervisor cleaning the 22 magnum

and the stunners daily, I reviewed the SOP plan.

25 M20863 JNB, Inc. PNA11131

12502G

02NOV2018 04C02 Livestock

Humane

Handling

Finalized The week of 10/29/2018 through 11/2/18 at

6:05am I preformed extra duties for Hat

Categories at EST.20863. Stunning

15min , conscious animals on the rail none on

conscious for 15 min, I review the records the that

the designate monitor is checking every 5 sow, I

observed the Supervisor cleaning the 22 magnum

and the stunners daily, I reviewed the SOP plan.
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 9

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

25 M20863 JNB, Inc. PNA29111

14019G

19NOV2018 04C02 Livestock

Humane

Handling

Finalized The week of 11/12/18 through 11/16/18 I

preformed extra duties on HAT Categories at

EST.20863. stunning 15 min, conscious animals

on the rail, none on conscious for 15 min. I

reviewed records that the designate monitor is

monitoring every 5th sow, I observed 

 cleaning the 22 magnum and the stunners

daily, I reviewed all records.

25 M20863 JNB, Inc. PNA35111

10419G

19NOV2018 04C02 Livestock

Humane

Handling

Finalized The week of 11/12/18 through 11/16/18 I

preformed extra duties on HAT Categories at

EST.20863. stunning 15 min, conscious animals

on the rail, none on conscious for 15 min. I

reviewed records that the designate monitor is

monitoring every 5th sow, I observed 

 cleaning the 22 magnum and the stunners

daily, I reviewed all records.

25 M20863 JNB, Inc. PNA50161

12830G

30NOV2018 04C02 Livestock

Humane

Handling

Finalized The week of 11/19/18 through 11/23/18 I

preformed extra duties on HAT Categories at

EST.20863. stunning 15 min, conscious animals

on the rail, none on conscious for 15 min. I

reviewed records that the designate monitor is

monitoring every 5th sow, I observed 

 cleaning the 22 magnum and the stunners

daily, I reviewed all records. was here

the morning of Monday the 19th everything went

good no NRs , this week we will work Monday

thru wednesday Thursday and Friday no work for

the holiday.

25 M20863 JNB, Inc. PNA05141

22710G

10DEC2018 04C02 Livestock

Humane

Handling

Finalized The week of 12/03/18 though 12/07/18 I

preformed extra duties on HAT Categories at

EST.20863 stunning for 15 min, 15 min on

conscious animals on the rail none on conscious,

for 15 min I reviewed the designated monitor is

monitoring every 5th sow, I observed 

 cleaning the 22 magnum and the stunner

daily, I reviewed all records. I am off Thursday and

Friday will cover for me.

(b) (6) (b) (6) (b) (6) (b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 10

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

25 M20863 JNB, Inc. PNA07141

22610G

10DEC2018 04C02 Livestock

Humane

Handling

Finalized The week of 12/03/18 though 12/07/18 I

preformed extra duties on HAT Categories at

EST.20863 stunning for 15 min, 15 min on

conscious animals on the rail none on conscious,

for 15 min I reviewed the designated monitor is

monitoring every 5th sow, I observed 

 cleaning the 22 magnum and the stunner

daily, I reviewed all records. I will be gone on

Thursday and Friday will be in my

place.

25 M20863 JNB, Inc. PNA20141

20110G

10DEC2018 04C02 Livestock

Humane

Handling

Finalized The week of 12/10/18 through 12/14/18 I

preformed extra duties on HAT Categories at EST.

20863 stunning 15 min, 15 on conscious animals

on the rail none on conscious, I reviewed

designated monitor for 15 min. I observed 

cleaning the 22 magnum and the stunner daily, I

reviewed all records.

25 M20863 JNB, Inc. PNA52161

20820G

20DEC2018 04C02 Livestock

Humane

Handling

Finalized The week of 12/17/18 through 12/21/18 I

preformed extra duties on HAT Categories at

EST.20863. stunning 15 min, 15 min on conscious

animals on the rail none on conscious, I reviewed

the records that designate monitor is monitoring

every 5th one, I observed cleaning the 22

magnum and the stunner daily, I reviewed all the

records.

25 M20863 JNB, Inc. PNA48131

20821G

21DEC2018 04C02 Livestock

Humane

Handling

Finalized The week of 12/17/18 through 12/21/18 I

preformed extra duties on HAT Categories at

EST.20863. stunning 15 min, 15 min on conscious

animals on the rail none on conscious, I reviewed

the records that designate monitor is monitoring

every 5th one, I observed cleaning the 22

magnum and the stunner daily, I reviewed all the

records.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 11

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

25 M20863 JNB, Inc. PNA31141

24528G

28DEC2018 04C02 Livestock

Humane

Handling

Finalized The week of 12/24/18 through 12/28/18, I

preformed extra duties on HAT Categories at

Est.20863. stunning 15 min, 15 min on conscious

animals on the rail, none on conscious, I reviewed

all  records, I  reviewed that the designated

monitor is monitoring, I observed 

cleaning the 22 magnum & the stunner daily.

25 M20863 JNB, Inc. PNA34141

22528G

28DEC2018 04C02 Livestock

Humane

Handling

Finalized The week of 12/24/18 through 12/28/18, I

preformed extra duties on HAT Categories at

Est.20863. stunning 15 min, 15 min on conscious

animals on the rail, none on conscious, I reviewed

all records, I reviewed that the designated

monitor is monitoring, I observed 

cleaning the 22 magnum & the stunner daily.

40 M337 STX Beef Company UNG34181

22907G

07DEC2018 04C02 Livestock

Humane

Handling

Finalized 43 head of had no signed/inspected pen card. All

carcasses, offal and head were tag and lock out.

40 M337 STX Beef Company UNG26121

20411G

11DEC2018 04C02 Livestock

Humane

Handling

Finalized Verification Plan  60th day review was done by

. New recommendations: 1.

Addition flap on the knockbox. 2. Possible foot

control knobs for the stun gun operator to free

both hand for the control of the stun gun. 3.Stun

gun operator found to be doing a good jib. 4. All

relevant records were up to date.

(b) (6) (b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 12

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

15 M34056 Olsen Farms Meats LLC XIC581211

3827G

27NOV2018 04C02 Livestock

Humane

Handling

Open On November 27, 2018 at approximately 0830

hours, I, while performing a

routine Livestock Humane Handling task HATS

Category VIII, Stunning Effectiveness, at Est.

34056 Olsen Farm Meats observed the following

inhumane event. The first beef cow, was loaded

into the headgate.  The beef was tossing her head.

 using a .357

caliber rifle with .357 magnum bullets, applied a

stunning attempt. The beef was conscious as she

remained standing with blood dripping from her

nose.  The beef did not vocalize or thrash

 applied a second stunning attempt with

the .357 rifle. Again, the beef remained conscious

as she remained standing with more blood

pouring from her nose. Again, there was no

vocalizing or thrashing.  applied a third

stunning attempt which rendered the animal

unconscious. Upon inspection of the beef head I

found the first two shots were low.  They were

both at eye level. One shot was centered and the

other was slightly to the left.  The third shot was

about 2 inches higher and at the correct

placement of the x pattern. 

informed me that the first two bullets were from a

new box of .357 magnum caliber bullets and that

the third bullet was from the previous box of

bullets. I immediately stopped production and

tagged the knock box with yellow USDA

Retain/Reject tag #B38177336, and contacted the

Denver District Office through supervisory

channels.

(b) (6) (b) (6)

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 13

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

15 M34056 Olsen Farms Meats LLC XIC211412

5113G

13DEC2018 04C02 Livestock

Humane

Handling

Finalized On December 13, 2018 at approximately 0800

hours, I, while performing a

routine Livestock Humane Handling Task  HATS

category VIII, Stunning Effectiveness, at Est. 34056

Olsen Farm Meats observed the following

inhumane event. Two Highlander beef cows were

located inside the barn in the second pen.  The

two cows were calm, standing and milling around

each other inside the pen. They were not loaded

into the head gate because each had horns too

wide for the head gate. There were no restraints

used and the first cow was effectively stunned.

 The second beef cow  was stunned by 

 using a .357 rifle and using

.357 mag 140 grain bullets.  The cow was stunned

 and remained standing. She did not vocalize but

tossed her head wildly and spun in repeated

circles.  re-aimed the  rifle and allowed

the cow to calm prior to second stunning attempt.

The cow was rendered immediately insensible

after the second stun. Upon inspection of the

placement of the two shots, I found them both

centered but just a quarter of an inch above eye

level.  The shots were approximately one inch too

low for the correct placement of the X pattern. I

immediately stopped production and tagged the

knock box with yellow USDA Retain/Reject tag

#B38177471. I then contacted the Denver District

Office through supervisory channels.

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 14

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

85 M40244 Gray's & Danny's Investment, Inc. LCP370812

0324G

24DEC2018 04C02 Livestock

Humane

Handling

Finalized December 21st, 2018 At approximately 1155,

while verifying the establishment’s

implementation of their humane handling

program at the cattle stunning area, I observed

 attempt to stun a beef heifer with a

410 shotgun. After the first shot hit, the heifer

remained standing, continued to have rhythmic

breathing, and controlled eye movement as it

moved its head to look at its surroundings. A

second shot was immediately made, but the

heifer continued to stand, have rhythmic

breathing, and controlled head and eye

movement. At this point, ran over to

the ATV parked nearby and searched for bullets in

the ATV while the heifer remained in the chute.

He then came over to the chute, manually loaded

the gun, and shot the heifer again. The heifer

remained standing with rhythmic breathing and

controlled head and eye movement. The gun then

had to be manually reloaded in order to take a

fourth shot, and two more shots had to be

administered before the heifer was rendered

unconscious, with manual reloading occurring

between each shot. A total of six (6) shots were

fired before the heifer was effectively rendered

unconscious. U.S. Rejected tag (#B40160524) was

placed on the chute and was

notified that regulatory action had been taken to

stop further killing of all federally inspected

animals. At postmortem inspection, the head was

skinned and five distinctive holes were observed

on the head.

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 15

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

60 M4390 Curtis Custom Meat LPK261211

1607G

07NOV2018 04C02 Livestock

Humane

Handling

Finalized At approximately 2pm on 11/7/18, a meeting was

held between USDA and establishment

management, attended by ,

, and 

, to discuss an incident that occurred earlier

in the day. A cow and a bull got loose while being

unloaded from the trailer at approximately

9:30am; the bull was returned to the premises

several hours later in good condition. At that time,

 and observed

truck unloading proceed without issue. The cow

was not returned. Because animals have escaped

control in the past at this establishment, USDA

requested that management provide us with

preventative measures that they will use to assure

this does not happen again stated that the

cause of the incident was a gap left between the

trailer and the barn door, through which the

animals were able to escape. In the future, the

establishment will ensure that all trailers are

backed up straight to the barn, so that no gaps

are present. They will also have at least two

employees present to help and are looking into

building a fence around the unloading area.

(b) (6) (b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 16

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

90 M44779 Faulkner Meats VMV20111

05324G

24OCT2018 04C02 Livestock

Humane

Handling

Finalized On Tuesday, October 23, 2018, IPP were verifying

conditions in the holding pens of the barn at

Faulkner Meats (M44779) Taylorsville, KY.  A goat

was found lateral recumbent in a holding pen at

approximately 1030 hrs. EDT; the goat was alive

but was diagnosed to be in a moribund state

(“U.S. Condemned”) by the SVMO. The SVMO

instructed IPP the goat needed to be euthanized

based upon its condition.  IPP informed the

establishment of the condition. Plant personnel

euthanized the goat by cutting its throat, allowing

it to expire by exsanguination. The cutting of the

throat is not considered an acceptable method of

euthanasia in a federally regulated facility. The

owner of the establishment considers all animals

held in the barn to be custom exempt, thus the

basis for this MOI.

90 M44779 Faulkner Meats VMV27131

03830G

30OCT2018 04C02 Livestock

Humane

Handling

Finalized October 30, 2018 The verification of livestock

holding pen conditions was made by the SVMO at

Faulkner Meats (M44779) Taylorsville, KY.  A pen

with approximately 37 lambs/sheep was found at

approximately 1400 hrs. EDT to be without access

to water; the bottoms of plastic drums (2) being

used for watering troughs were dry. While the

owner of the establishment considers all animals

in the barn to be custom exempt, per  FSIS USDA

Directive 5930.1 revision 4, the Humane Methods

of Slaughter Act applies and all livestock are to

have access to water in the holding pens at all

times. Because the animals have yet to be

declared for Federally Inspected Slaughter, they

are considered Custom Exempt at the point of

discovery and as such this Custom Exempt MOI

was issued instead of a non-compliance record.
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 17

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

90 M44779 Faulkner Meats VMV37071

12921G

21NOV2018 04C02 Livestock

Humane

Handling

Finalized November 20, 2018 Federally inspected

slaughter activities regularly occur at Faulkner

Meats (M44779) Taylorsville, KY on Tuesdays of

each week. While verifying conditions in the barn,

the SVMO made the following observations in a

holding pen at approximately 1330 hrs. EST: A

holding pen containing approximately 20 head of

swine varying in size from roughly 20 pounds to

over 500 pounds were found to be without water;

the 50 gallon plastic drum converted to a gravity

fed waterer was observed lying on its side in the

corner of the pen.  Secondly, the floor was

covered, near its entirety, in approximately one

inch of soupy, liquid manure; if all animals were

to lie down simultaneously, some would have to

lie in the liquid. The above animals had not been

declared for Federal Inspection at the time of

these observations; the owner of the

establishment considers all animals in the holding

pens to be custom exempt until such time as they

may be declared for federal inspection. FSIS

USDA Directive 5930.1 revision 4 states the

Federal Meat Inspection Act (FMIA) and the

Humane Methods of Slaughter Act (HMSA) applies

to custom exempt operations. The lack of water

access and the absence of pen maintenance raise

humane handling concerns, and also in the case of

the latter, create insanitary conditions. The basis

for the issuance of this Custom Exempt MOI

instead of a non-compliance record is the fact the

swine had not been declared for Federal

Inspection. This observation continues a recent

trend in humane handling concerns.
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 18

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Task

Code TaskName Status MOI Agenda

90 M44819 Fatback Pig Project LLC BQY13121

03102G

02OCT2018 04C02 Livestock

Humane

Handling

Finalized At approximately 11:15 am on Friday, September

28, 2018, I, , observed an

employee using the electrical stunner on a hog in

the knock box. The 1st, 2nd, and 3rd attempts to

render the hog insensible to pain failed. On the

4th attempt the hog was rendered unconscious

and remained so throughout shackling, hoisting,

and bleeding. The knock box was tagged with US

Reject/Retain tag Number B42031085.  The

establishment has been informed there will be no

more slaughter until notified by the District Office.

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 19

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Task

Code TaskName Status MOI Agenda

25 M45471 New Angus, LLC VUE31091

20211G

11DEC2018 04C02 Livestock

Humane

Handling

Finalized On 12/7/18 a meeting was held with

management representatives to review IPP

findings/concerns with fractured mandibles on

bovine carcasses, and discuss establishment steps

for determining the cause and subsequent

corrective actions.  On 12/5/18 while giving

break at heads, IPP saw a fractured mandible and

on 12/6/18 a FI reported three heads with both

mandibles fractured mid-length.  IPP reported the

concern to establishment management and they

did an inquiry.  When I reported to the knock box,

management had discovered a failure in a pin on

the head restraint.  There were no reported

fractures on heads the rest of the day.  I watched

the stunning for several minutes throughout the

day and was unable to find a distressed animal.  A

note is that the chin basket lift cylinder has 8

inches more travel than required to restrain the

head of the animals I saw.  This also allows the

chin basket to be lift up and out of the way

when the carcass is rolled off the belly chain.  The

knock box controller stops lifting the head when

the face levels out.  If the knock box controller

were to use that extra distance with an animal in

the box, they would very likely fracture a

mandible. In response to IPP concern, a

deficiency was recorded in the 12/6/18 animal

Handling Structural Audit under the knock box. 

“The head restraint was not closing and lifting

heads properly.”  Equipment repair: Cylinder pin

mounting bracket was repaired.  QA has increased

monitoring time at the restrainer. On 12/7/18 at

approximately 1400 hours, IPP found another

fractured mandible.  This was similar to the one

from 12/5/18.  The right mandible fractured mid

shaft from outside pressure.  The fragments were

pushed medially.  and 

 and I watched the box for several

minutes and found no animals in distress

did say that this equipment is becoming worn and

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 20

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Task

Code TaskName Status MOI Agenda

a new restrainer was ordered.  We also looked at

the possibility of the Up Puller head restraint

causing the problem but, that was unable to

replicate the fractures.
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 21

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Task

Code TaskName Status MOI Agenda

25 M45629 Andy's Meats Inc. DJP381111

1021G

21NOV2018 04C02 Livestock

Humane

Handling

Finalized At approximately 0830, while observing HATS

Category VIII, Stunning Effectiveness, I, 

, observed the following. A

nonambulatory hog tagged as U.S. Suspect was

stunned with a hand held captive bolt gun. The

hog was moving slightly, but the operator took his

time, aimed, and shot the hog. The operator

immediately walked away from the shot hog. The

hog flopped seemingly as though properly

stunned. I asked the operator what he is supposed

to do right after stunning a hog. He responded to

check the eyes. When I looked at the hog, still

flopping, I observed that it blinked its eyes as a

normal conscious hog would. The other barn

employee pointed out that the hog didn't seem

dead yet, and the stunner operator retrieved

another shell for the captive bolt gun. During this

time, I approached the hog and observed that it

was still blinking in a normal fashion and

breathing rhythmically, although it was lying on

its side. I moved my hand in front of the hog, and

it failed to track the movement; but did blink. At

this time, the stunner operator told me he has

never missed a shot, and we both saw that the

wound appeared centrally, approximately 1/2"

rostral to the front edge of the ears.  He placed

another shot into the hog's forehead, rendering it

completely insensible. I tagged the stunning area

with US Reject Tag B37571016 and described the

situation with . I observed him

discuss the matter with the stunner operator and

instruct the operator to always carry an additional

charge with when stunning so if an ineffective

stun occurs, he will be prepared to shoot it again.

The company took further preventive measures by

instructing employees to perform safety shots on

all hogs stunned with a captive bolt gun. The tag

was removed and slaughter allowed to continue.

At approximately 0915, I met with 

to inform him that the recommendation for the

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 22

Dist

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Task

Code TaskName Status MOI Agenda

incident was an HH MOI. We discussed safety shot

policies, specifically that safety shots are always

acceptable; however, FSIS expects that the animal

be rendered unconscious on the first shot. We

also discussed additional stunning training in

different formats, as well as signed statements of

training understanding- especially in stunning aim

locations, always checking the eyes for

unconsciousness after the shot, the

establishment’s decided use of safety shots, and

communication between the captive bolt

operator and the electrical stunner operator.

50 M45649 Homestead Springs ZSR571012

1404G

04DEC2018 04C02 Livestock

Humane

Handling

Finalized Discussion with establishment management

between and . 

 observed hogs reluctant to

move when being brought in from the outside pen

into the knock box on multiple occurrences. The

establishment personnel was observed using a

hog sorting board to drive the hogs into the knock

box while pushing the hogs with the board

 spoke with 

regarding these observations. 

stated he would speak with the establishment

personnel. suggested a rattle

paddle in addition to the sorting board to assist

with sorting and moving the hogs.

(b) (6) (b) (6) (b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 23

Dist

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Task

Code TaskName Status MOI Agenda

90 M46240 Light Hill Meats MKE52131

23311G

11DEC2018 04C02 Livestock

Humane

Handling

Open At approximately 1245 hrs., 

observed a small ruminant sheep, weighing 130

lbs. being loaded into the knock box at Light Hill

Meats (est. 46240).  Using a captive bolt, the plant

employee standing in the stun box with the

animal administered 1 stunning attempt to the

forehead wherein the animal remained standing

and consciously breathing.  A second attempt was

administered to the forehead with the same

resulting behavior.  The employee requested

additional captive bolt stunning charges.  A

third stun attempt to the forehead was

unsuccessful as the animal remained standing and

consciously breathing, shaking its head and licking

the blood from the previous attempts.  A fourth

stunning attempt was administered to the back of

the head, rendering the animal unconscious.  It

remained unconscious and insensible to pain

throughout shackling, sticking and bleeding. 

Upon examination of the sheep head, there were

3 entry wounds on the forehead, and one

penetrating wound in the back of the head.  The

knock box was rejected and tagged with No.

B37373551.  Plant manager Jennifer Spray was

notified of the regulatory control action.  Light Hill

Meats (est. 46240) is not currently operating

under a Written Robust Systematic Approach to

Humane Handling Plan.

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 24

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Task

Code TaskName Status MOI Agenda

25 M5537 Sioux-Preme Packing Co. TJF240712

4004G

04DEC2018 04C02 Livestock

Humane

Handling

Finalized Food Safety and Inspection Service 1400 

Independence Avenue, SW. Washington, D.C.

20250 From: Date:

11/28/2018 Subject: Human Handling- incident

at 5537 M on 11.27.18 Meeting Date:

11/28/2018 Meeting Time: 7:15 AM 

Establishment: M5537 - Sioux-Preme Packing Co. 

Reason Code: Other Reason Code: Comments: 

On Tuesday, November 27, 2018, at

approximately 1515 hours, while I was walking to

yards to perform ante mortem inspection, I heard

one pig was vocalizing; there were 3-4 pigs in this

group, at the start of walkway leading to butina.

The vocalizing pig's tail was caught in narrow

space of sliding door and concrete structure. The

sliding door is controlled by stunning area

personnel. The yards person who was walking

with me instructed stunning area supervisor to 

humanely euthanize animal, animal was

successfully euthanized with a captive bolt, 

transported to place on line for processing. This

morning, (Wednesday, November 28, 2018 at

approximately 0720 hours), Mr. Rick Getman,

Plant Manager told me that management will put

a corrective action for the above incidence.

Management was informed a MOI will be

documented and communicated to to 

and at Des Moines District Office for

further guidance. Respectfully, 

 Cc: To and

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)

Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 26

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Task

Code TaskName Status MOI Agenda

inspection, there was a third hole on the back of

the head. Upon a discussion with plant

management, they confirmed that the employee

had attempted to stun the animal on the back of

the head before had arrived. As the

animal was still standing and vocalizing upon his

arrival, this attempt was unsuccessful. Two holes

were also observed on the front of the head at

post-mortem inspection. 

immediately tagged the knock box and no other

animals were stunned. notified Greg

Dronen that knock box was tagged. The

establishment was allowed to clear the line of

carcasses pending my arrival from another

establishment. This information provided in this

Memorandum of Interview includes all the topic

discussed during this meeting.

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 27

Dist

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Task

Code TaskName Status MOI Agenda

90 M7356 Harmon Brothers Meats, Inc. IJK3107103

715G

15OCT2018 04C02 Livestock

Humane

Handling

Open HATS category VIII: Stunning Effectiveness At

approximately 0725 hours after a medium sized

Angus steer was presented for ante-mortem

inspection and brought into the knock box, I,

 observed the following: A

stun was attempted with a captive bolt gun and

proved unsuccessful. The steer remained standing

after the shot ( conscious righting reflex,

conscious eye tracking ), I moved to the front of

the knock box and observed a wound to the

forehead with a small amount of streaming blood.

The employee immediately reloaded and a second

stun was attempted with identical

results ( conscious righting reflex with conscious

eye tracking ). At this point the same employee

grabbed a .22 magnum rifle and shot the beef,

this 3rd attempt was successful and rendered the

animal insensible. The animal never vocalized but

there were two visible bleeding wounds to the

forehead, both captive bolt attempts appeared to

be well placed. I immediately informed 

 of this noncompliance and tagged

the knockbox entrance with USDA rejected tag # 

B42200560 and stopped any further slaughter. I

notified Plant Manger Roy Palmer about the

mis-stun attempts and of my regulatory control

actions. I called and 

and informed them of my observations and

regulatory control measures. I also emailed

 and DDM Dr. Thompson at

Jackson District office.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 28

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Task

Code TaskName Status MOI Agenda

25 M7644 Kota Meats Inc. NBO40111

00805G

05OCT2018 04C02 Livestock

Humane

Handling

Finalized At 1100 hours on 10/5/18 during slaughter

operations, the SPHV noted a potential humane

handling concern.  The fifth cattle of the day, a

steer, had been knocked with a hand held captive

bolt (HHCB) device, the neck cut had been made

to facilitate bleed out, and it was lying on its side

in the knock box area; but was still rhythmically

breathing.  The chest and abdomen were rising

and falling approximately 5 times per ~15

seconds, the mouth was opening and closing, and

there were guttural noises derived from its mouth

due to the expiration of air during breathing. 

There was no righting reflex, palpebral/corneal

response, or eye tracking, and the tongue was

limp.  The SPHV and CSI asked the plant to

perform a second stun, which was performed with

a HHCB device and resulted in continued

breathing in the same manner as described

above.  A third stun was performed with a HHCB

device, which resulted in diminished breathing

and guttural noises but no other signs of

consciousness.  The neck cut was then made

deeper by the owner, Mr. Alex Adame, after the

third stun to speed bleed out.  All skull stun holes

located high and centrally focused on the

forehead; head was not split to determine

accuracy of shots into the brain. Two HHCB

devices and a shotgun are available on the kill

floor for stunning.  A U.S. Reject Tag 529570 was

placed on the knock box while further information

was gathered.  After discussion with the district

office and establishment management, the tag

was removed.  Our observations were discussed

with the owner, Mr. Alex Adame, and the concern

with making cuts on an animal with signs of

rhythmic breathing was discussed.  We discussed

that this could be a potential sign of returning to

consciousness.  Mr. Alex Adame agreed that cattle

should have a security stun if still rhythmic

breathing after the first stun or any additional
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 29

Dist

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Task

Code TaskName Status MOI Agenda

stuns thereafter.  He then translated this

information to stunner employee .

15 M889A J.F. O'Neill Packing Co. Inc. DSC490712

2708G

08DEC2018 04C02 Livestock

Humane

Handling

Finalized I briefly met with Pat ONeill (President) and

 on the morning of

December 10th to inform them of a situation that

occurred last Thursday.  Apparently, an animal

was found dead in a pen sometime during the late

morning or early afternoon.  The first I heard

about this was on Friday, December 7th, when

 asked about a

condemnation certificate for the animal in

question.  The establishment was able to provide

documentation on Saturday from the rendering

company confirming receipt of a carcass.  While

this is the first incident to my knowledge where I

have been unable to verify the natural death of a

presented animal, without that confirmation FSIS

personnel can not responsibly issue a USDA

Condemnation number and certificate. 

Furthermore, the establishment may be held

liable for allowing a non-ambulatory animal

through the production system which could lead

to a recall scenario.  Mr. ONeill stated that he had

seen the slashed and denatured carcass, and Mr.

Acosta indicated that he had been unaware until

much later after the incident initially occurred.  At

this time I will be completing a condemnation

certificate, however, in the future any animals

dying on the premises must be presented to FSIS.

(b) 

(6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 30

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Task

Code TaskName Status MOI Agenda

60 M9442 Groff Meats Inc. UTC271010

5305G

05OCT2018 04C02 Livestock

Humane

Handling

Finalized A stunning NR was written on August 29, 2018 for

an ineffective first stunning attempt and NR

number UTC5211085429 documented.

Management response is “this was just a human

mistake – stunner will not work if both

probe[s] – [do not] make contact – don’t think

hog received any electric”. Corrective actions

indicating human error are not adequate

corrective actions. Please advise on further

planned measures. Thanks,
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 31

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Task

Code TaskName Status MOI Agenda

15 M960 Greater Omaha Packing Co., Inc. PEE170810

4824G

24OCT2018 04C02 Livestock

Humane

Handling

Finalized Observations and discussions with establishment

management were made by 

, during the ninety day verification plan

humane handling visit. On October 23rd, 2018 at

approximately 0854 hours, I observed the

following concern with HATS Category

VIII – Stunning Effectiveness.  A black bovine

entered the restrainer with its head down.  The

establishment employee attempted to use the

pneumatic captive bolt device to render the

animal unconscious.  I heard the device make its

normal sound followed by vocalization from the

animal.  The animal vocalized an additional time

and then moved its head away from the

employee.  The establishment employee then

used the same pneumatic captive bolt device to

immediately and effectively render the animal

unconscious.  I verbally requested the line be

stopped and requested a supervisor through

  

 had the pneumatic captive bolt device

removed from service, replaced with a new device

and replaced the employee with a more

experienced stunner.  The establishment

employee was interviewed and stated the first

stun attempt did not make contact with the head

of the animal (grazed the hair line) but rather fired

after the animal moved its head up and towards

the stunner.  The animal was not marked or

retained for viewing after the incident and was

not located after skinning.  During the

observations, no head wound was observed after

the first stun attempt as the animal’s head was

down and out of viewing sight.  After discussing

the incident with establishment management

stunning resumed with no further incident or

concern. At approximately 1245 hours, during

the exit meeting the previous observations were (b) (6) (b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-143 10:47 Wednesday, March 20, 2019 32

Dist

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Code TaskName Status MOI Agenda

discussed with establishment management. 

Attendees: 

, 

; 

; ;

and . We discussed the

establishment employee’s response to the

stunning attempt and making sure to immediately

and effectively stun the animal on the second

attempt.  We also discussed the importance of

investigating these incidents to determine the

cause prior to continuing operations.  We also

discussed the operation and mechanics of the

pneumatic captive bolt device and its ability to

fire when contact is not made with the animal. 

We correlated on animal movement in the

restrainer and the importance of patience when

stunning animals in a center belly conveyor

restraint system. Establishment management

will further investigate the incident and provide

associated records as they are available.

(b) (6) (b) (6) (b) (6)

(b) (6) (b) (6) (b) (6)