iiiiii United States Department of Agriculture 

November 22, 2023 

Honest Meats, LLC 

M7420+V7420 ELECTRONIC MAIL on November 22, 2023 

256 Charles Street 

Harrisonburg, VA 22802-4612 

office@temeats.com; lauren@temeats.com 

540-434-4415 

Attention: Lauren Iverson, Managing Partner 

NOTICE OF INTENDED ENFORCEMENT 

Dear Ms. Iverson: 

This letter confirms the verbal notification given on November 21, 2023, at approximately 1326 

hours, by the Food Safety and Inspection Service (FSIS) Inspection Program Personnel (IPP), of 

the intent to suspend the assignment of inspection program personnel for the slaughter process at 

your establishment located at 256 Charles Street, Harrisonburg, VA, herein after referred to as 

“your establishment”. This action was initiated in accordance with Title 9 of the Code of Federal 

Regulations (9 CFR) 500.3, after FSIS determined that your establishment failed to slaughter and 

handle animals humanely. 

On September 9, 2004, FSIS published “Humane Handling and Slaughter Requirements and the 

Merits of a Systematic Approach to Meet Such Requirements;” in the Federal Register Notice (54 

Fed. Reg. 54625). On September 24, 2020, FSIS released FSIS Directive 6900.2, Revision 3, 

entitled, “Humane Handling and Slaughter of Livestock.” These documents describe the four 

components of a systematic approach to humane handling. A review of your systematic approach 

to humane handling reveals documentation and activities consistent with the four components of 

a “robust” system as defined. The decision to issue a Notice of Intended Enforcement (NOIE) in 

lieu of a Notice of Suspension is based on a review of FSIS records identifying your compliance 

with humane handling regulations; the historical absence and infrequent occurrence of humane 

handling violations at your establishment; and the successful design and consistent implementation 

of a robust systematic approach to humane handling. 

Background and Authority 

The Federal Meat Inspection Act (FMIA) (Title 21 of the United States Code {21 U.S.C.} 603 et 

seq.) provides that for the purpose of preventing the inhumane slaughtering of livestock, the 

Secretary shall cause to be made, by inspectors appointed for that purpose, an examination and 

inspection of the methods by which cattle, sheep, swine, goats, horses, mules, or other equines are 

slaughtered and handled in connection with slaughter in the slaughtering establishments inspected 

under this Act. The Secretary may refuse to provide inspection to a new slaughtering establishment 

or may cause slaughtering to be temporarily suspended at a slaughtering establishment if the 

Secretary finds that any cattle, sheep, swine, goats, horses, mules, or other equines have been 
 

 

 

 

 

 

 

 

 

 

 

 

LAUREN IVERSON, MANAGING PARTNER Notice of Intended Enforcement 

HONEST MEATS, LLC, M7420+V7420 November 22, 2023 

slaughtered or handled in connection with slaughter at such establishments by any method not in 

accordance with sections 1901 to 1906 of Title 7 until the establishment furnishes assurances, 

satisfactory to the Secretary, that all slaughtering and handling in connection with slaughter of 

livestock shall be in accordance with such a method. 

The Humane Methods of Slaughter Act of 1978 (7 U.S.C. 1901 et seq.) provides that Congress 

finds that the use of humane methods in the slaughter of livestock prevents needless suffering; 

results in safer and better working conditions for persons engaged in the slaughtering industry; 

brings about improvement of products and economies in slaughtering operations; and produces 

other benefits for producers, processors, and consumers which tend to expedite an orderly flow of 

livestock and livestock products in interstate and foreign commerce. It is therefore declared to be 

the policy of the United States that the slaughtering of livestock and the handling of livestock in 

connection with slaughter shall be carried out only by humane methods. 

Under the authorities of the above Acts, FSIS has prescribed rules and regulations for 

establishments engaged in the slaughter of livestock and the production of meat products, 

including requirements pertaining to humane handling of livestock in connection with slaughtering 

operations in 9 CFR 313. FSIS has also developed Rules of Practice regarding enforcement (9 

CFR Part 500). The Rules of Practice describe the types of enforcement actions that FSIS may 

take and include procedures for taking a withholding action and/or suspension, with or without 

prior notification, and for filing a complaint to withdraw a grant of Federal inspection. 

Findings/Basis for Action 

At approximately 1310 hours on Tuesday, November 21, 2023, at Honest Meats, Est. M7420, IPP 

identified an egregious humane handling non-compliance in which a hog regained consciousness 

after being stunned. IPP observed that a large market hog was presented for slaughter and was 

stunned using an electrical stunning device. There were no signs of consciousness, and the 

employee stuck the hog to allow it to bleed out. A few seconds later, the hog stood up and began 

walking away from the stunning area. The employee immediately applied a second stun with the 

electrical stunning device and rendered the hog unconscious. The employee than applied a security 

stun with a hand-held captive bolt device, and the hog remained unconscious through the 

remainder of the shackling, hoisting, and bleeding processes. IPP applied US Retain/Reject Tag 

#39315386 to the stunner to prevent further slaughter of livestock; this is in accordance with 9 

CFR 313.50(c). IPP notified establishment personnel of the recommendation for further 

enforcement action at approximately 1314 hours. 

The occurrence of this inhumane handling incident as observed supports a conclusion that your 

methods of handling livestock violated the provisions of 21 U.S.C. 603, Section 3 (b) of the FMIA, 

7 U.S.C 1902 of the HMSA of 1978, and 9 CFR 313. Specifically, you failed to meet the 

requirements of 9 CFR 313.30(a)(4) which states, in part, “The stunned animal shall remain 

in a state of surgical anesthesia through shackling, sticking, and bleeding.” This incident requires 

further enforcement actions because IPP observed the hog regain consciousness after being 

stunned. 
LAUREN IVERSON, MANAGING PARTNER Notice of Intended Enforcement 

HONEST MEATS, LLC, M7420+V7420 November 22, 2023 

As stated earlier, a review ofyom systematic approach to humane handling reveals documentation 

and activities consistent with the four components of a "robust" system as defined in FSIS 

Directive 6900.2, Revision 3. The decision to issue a Notice of Intended Enforcement (NOIE) in 

lieu of a Notice of Suspension is based on a review of FSIS records identifying your compliance 

with humane handling regulations; the historical absence and infrequent occmTence of humane 

handling violations at yom establishment; and the successful design and consistent implementation 

of a robust systematic approach to humane handling. Furthennore, the Raleigh District Office 

detennined that yom establishment is operating under an animal handling program that provides 

for how your establishment will respond ifan unforeseeable event of this type occurs; and there is 

no basis for concern that the planned response in yom animal handling program will not effectively 

address the problem. 

In conclusion, the suspension of yom slaughter process is wan anted as provided in 9 CFR 500.3 

(b) which states "FSIS also may impose a suspension without providing the establishment prior 

notification because the establishment is handling or slaughtering animals inhumanely". Before 

we proceed with the suspension enforcement action, we are affording you the oppo1tunity to 

demonstrate that the egregious act described above was an anomaly, and that your con ective and 

preventive measmes were thorough and implemented in a manner to prevent recunence of the 

incident 

Please provide this office with a written response concerning this NOIE within three (3) working 

days from the date ofyour receipt ofthis letter. We will detennine further action, if any, based on 

yom response. The con ective actions in yom response should address the following: 

1. Identify the specific reason( s) why the events described occmTed. 

2. Describe the specific action(s) that will be taken to eliminate the cause of the incident 

and prevent future recmrences. 

3. Describe specifically the future monitoring activity (ies) that yom establishment will use 

to ensme that the actions taken are effective. 

If you have any questions, please contact Todd Furey via telephone at 919-326-5281 or via 

electronic mail at todd.furey2@usda.gov. Additionally, you can contact Raleigh District Office 

at 919-844-8400 or by fax at 844-839-6359. 

Sincerely, 

MARK ROLING ~£~:sigmidbyMARK 

Dat9: 2023.11 .22 13:1 6:54 -05'00 

Todd Fmey 

District Manager 
LAUREN IVERSON, MANAGING PARTNER Notice of Intended Enforcement 

HONEST MEATS, LLC, M7420+V7420 November 22, 2023 

cc: S. Johnson, EARO/FO 

L Ho1ie11 RD/CID/OIEA 

, HHEC/FO 

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-R. Mmphy, DDM/RDO/FO 

M. Roling, DDM/RDO/FO 

~n, DDM/RDO/FO 

IIIIIIIIIIIIIJ)CS/RDO/FO 

DVMS/RDO/FO 

SEIAO/RDO/FO 

Program Manager/VDACS 

spection Manager/VDACS 

upervisor/VDACS 

tate Public Health Veterinarian/VDACS 

State Public Health Veterinarian/VDACS 

Quaiierly Enforcement Report 

Establishment File (Est. M7420)