Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 1

EstNbr EstName NR# Date Task Regs Description Status

P687 House of

Raeford

XRA262

205233

1N-1

05/31/2017 04C05 381.65(b) At approximately 0150 hours on the morning of

05/31/2017 while performing a Good Commercial

Practice (GCP) in the Live Hang Area I observed the

following Good Commercial Practice

noncompliance: Birds (32) that died from causes

other than slaughter.  The birds were hanging by

their feet in shackles while their heads were still

submerged in water inside the Stunner. As I

observed the birds there was no chest movement

or any signs indicating that they were still alive. I

took regulatory control by placing US RETAINED

TAGS # B33564115 and # B33564128 on the Kill

Line at the point where the birds entered and

exited the Stunner. I asked a plant employee to

locate his Supervisor and ask him to come to Live

Hang. When 

, arrived I showed him the birds in the

Stunner which were not breathing and informed

him a Good Commercial Practice noncompliance

with the above cited regulations existed due to

birds had died other than by slaughter.  Live Hang

employees removed the birds from the Stunner,

placed them in condemned barrel where they

were denatured and then transported to the Offal

Area. The Kill Line initially stopped at

approximately 0120 hours on 5/31/17 due to

mechanical breakdown. 

observed a second GCP noncompliance at

approximately 0230 hours on the morning of

5/31/17.  The Kill Line had stopped due to

another mechanical breakdown at 0215 hours.

Upon arrival  to Live Hang she

observed seventeen birds (17) which had died

other than by slaughter on the Kill Line in the

Stunner. She asked

 to remove the deceased birds

from the line. After the birds were removed from

the line they were placed in a condemn barrel;

denatured and taken to the Offal Area. She

notified 

 of her findings. This is a Other Consumer

CLOSED

(b) (6)

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

(b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 2

EstNbr EstName NR# Date Task Regs Description Status

Protection noncompliance due to establishment’s

failure to implement the process/procedure to

prevent birds from dying other than by slaughter. 

All noncompliance and noted potential

noncompliance are discussed with plant

management during weekly meetings between

USDA and plant management personnel. This NR

was submitted to plant management on

06/01/2017.
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 3

EstNbr EstName NR# Date Task Regs Description Status

P843 Pilgrims Pride PZA490

404361

0N-1

04/10/2017 04C05 381.65(b) On 04/09/2017, the following noncompliance was

observed.  As I was giving the USDA inspector

relief breaks starting at approximately 0430

hours, I condemned 3 birds as cadavers.  I notified

 that I was seeing increased

numbers of cadavers.  I continued to condemn

birds as cadavers after this notification.  The

inspectors at all stations were also condemning

birds as cadavers during this time.  After the relief

breaks were over, I proceeded to the scald tank

area.  There was a back-up killer located at the

bleed tank before the birds enter the scald tank. 

He constantly was having to cut the necks of live

birds that had missed the kill machine or had

miscuts so that they were still alive with eyes

blinking, and breathing as they were approaching

the scald tank.  While I was observing him at

approximately 0505 hours, I saw a bird that he

overlooked about to enter the scald tank.  This

bird was awake with its head up, looking around,

eyes blinking, and had rhythmic breathing.  The

back up killer was attending to other birds which

had been missed by the kill machine.  I took

regulatory control by stopping the line and

pointed out the missed bird.  He cut the neck and

I restarted the line.  In the period of about 3

minutes, I had to stop the line several times in

order for him to attend to birds about to enter the

scald tank alive.  At no time did he attempt to

stop the line on his own as he was trying to keep

up with the birds that were alive with

rhythmic breathing.  came

during the time I was stopping the line.  He

observed the situation and left.  Then the

establishment stopped the line.  I went to the kill

machine and saw that there were several people

looking at it.  I went back to the second back up

killer location.  Once the line started again, the

problem was not resolved and instead appeared

to be worse and I continued to stop the line

multiple times for uncut birds or birds with missed

CLOSED

(b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 4

EstNbr EstName NR# Date Task Regs Description Status

cuts that were not bleeding out completely and

were still alive, blinking, and breathing as they

were about to enter the scald tank.  

told me that I needed to speak with 

 and that he was on

his way.  I took regulatory control and stopped

the line and did not restart it again at this time

(approximately 0517 hours).  

came and we discussed the situation.  I informed

him of the lack of process control and the

resulting noncompliance with the above

regulation.  He stopped hanging birds and I

allowed the line to restart in order to move the

birds along that were already on the line.  As there

were still many uncut or miscut birds that needed

the attention of the second back up killer, I

continued to ensure the line was stopped

periodically so that no bird entered the scald tank

alive.  investigated the situation

during this time and reported that the bicycle

wheel was not working properly and the water

had been turned off.  Adjustments were made and

then I relinquished regulatory control and verified

that the process was back in control

(approximately 0529 hours).

P4734 New Lee's Live

Poultry Market

Inc.

XKD380

709180

9N-1

09/09/2017 04C05 381.65(b) On 9/09/17 at 0645 hours approximately, while

doing a routine GCP task, I observed one

employee throw into barrel one young chicken

without drained the bleeding in the metal cone.

The young chicken still moving into the barrel. I

stopped the operation and talk immediately with

plant manager Mr. John about this

non-compliance.  The plant failed to comply

with 9CFR 381.65(b) Poultry must be slaughtered

in a manner that will result in thorough bleeding

of the carcasses.  The young chicken was put into

de metal cone again to complete properly

bleeding and death process.  There was no

adulterated product associated with this

non-compliance and no adulterated product

entered commerce.

CLOSED

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 5

EstNbr EstName NR# Date Task Regs Description Status

P15724 Case Farms of

Ohio, Inc

EVC050

903161

4N-1

03/14/2017 04C05 381.65(b) On March 14, 2017 at approximately 0836 hours

 made the observation

described below while performing the review and

observation component of the routine poultry

good commercial practices task.  The floor behind

the hourly employees in the live hang department

was covered with dead on arrival birds.  The area

involved was approximately 10-12 feet long, 3-4

feet wide, and approximately 6-8 inches high.

While observing the DOA's in the previously

described area, observed two birds

that were alive being buried by the dead birds. 

One bird  had the front half of its body up to the

rib area buried by the dead birds and was trying

to escape the pile by moving its legs in an attempt

to pull itself out free.  Another bird was located in

the middle of the pile and was soaking wet with

spontaneous respirations and was approximately

half way buried as well.  got the

attention of one of the hourly employees working

in the area and told him she needed him to stop

and get , or 

.  The employee stated

 was driving the forklift and then

proceeded to return to work.  While 

was making the observations described the hourly

establishment employees continued to toss dead

birds on the living birds that were intermingled

with the dead.   left the area to locate

 so the observations could be

discussed with her. The observations described are

non-compliant with 9CFR381.65(b).

CLOSED

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

(b) 

(6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 6

EstNbr EstName NR# Date Task Regs Description Status

P15724 Case Farms of

Ohio, Inc

EVC381

203411

5N-1

03/15/2017 04C05 381.65(b) On March 15, 2017 at approximately 1150 hours

while performing the review and observation

component of the routine poultry good

commercial practices task; made the

following observation.  Upon observation of the

exit of the kill line from the stunner two birds

were in the water.  Upon further observation it

was observed the heads of the birds were under

the water in the stunner.  pointed

this observation out to 

 who directed 

to remove the birds.  The birds were dead.  Based

on the fact that the stunner is located at least 4

feet off the floor it is reasonable to conclude the

birds drowned in the stunner water.   The

observation described above is non compliant

with 9CFR381.65(b).  This NR is linked to the NR

issued on March 14, 2017.

CLOSED

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

(b) (6)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 7

EstNbr EstName NR# Date Task Regs Description Status

P17340 Pilgrim's UQB58

150753

26N-1

07/25/2017 04C05 381.65(b) On 07/25/2017 at approximately 1255 hours

while performing a good commercial practices

verification task IPP ( and 

) observed that the establishment lost

control of its process for handling birds resulting

in their dying from a means otherwise than

slaughter, and hence failed to slaughter poultry in

accordance with good commercial practices. 

Specifically, while performing verification

activities, and I observed that

the truck cooling shed bays (8) were at full

capacity and that three trucks (two full and one

partially filled) had been parked (immediately

adjacent to one another) on the asphalt parking

lot with no protection from the sun and without

any source of ventilation or other means of

cooling (water misters used in conjunction with

fans for evaporative cooling). Upon further

inspection, we observed another full trailer of

birds (with no source of

cooling/ventilation/misters) which had been

parked on the interior line-up of empty trailers

located on the asphalt trailer parking lot, and

noted that 80-90 percent of the birds contained in

that trailer were panting heavily.  Upon closer

inspection of the birds contained within the

interior trailer, we observed that 80-90 percent of

birds were showing significant heat stress, as

evidenced by heavy panting, secondary to the

high environmental temperature and humidity,

and negligible ventilation.  The aforementioned

environmental conditions could best be described

as stifling.  Upon inspection of the birds in the

trailer that were most exposed to direct sun, we

observed a significant increase in heat related

morbidity and mortality, as evidenced by gasping

and heavy panting in greater than 90% of all birds

on the trailer.  We observed many birds that were

staggering around and aimlessly jumping about in

the in the cages while others were violently

flapping their wings and gasping for air via an

CLOSED

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

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 8

EstNbr EstName NR# Date Task Regs Description Status

outstretched neck, in a final futile attempt to cool

them themselves (evaporative cooling from the

surface of the lungs).  We also observed that

numerous birds had had already succumbed to

heat stress, and that others were somnolent or

moribund.  At the time the aforementioned

observations were made the environmental

temperature was in excess of 90 degrees

Fahrenheit. Upon entering the hanging area (new

side), I observed that the floor immediately

behind the live hangers was littered (large

accumulation of carcasses) with the carcasses of

dead birds and that the live hangers were

throwing dead birds off the hanging belt and onto

the floor.  Upon further inspection, I observed that

the back side of the hanging conveyor belt was

similarly littered with the carcasses of dead birds. 

I also noted that the dead bin adjacent to the cage

dump area was full.  and I also

noted that trailers loaded with empty cages

(previously dumped) were present in the truck

unloading areas despite there being trailers

containing birds exhibiting heat stress parked on

the asphalt parking lot with no protection from

the sun.  Upon entering the evisceration floor, I

observed an increased amount of DOA birds which

had been retained by on-line IPP for veterinary

disposition, which I subsequently condemned post

inspection.  ,

was immediately notified (verbally) of the

aforementioned noncompliance.  She was advised

that the establishment had failed to appropriately

schedule the delivery of poultry to the

establishment in such a manner so as to

accommodate the volume of incoming trucks with

their facilities’ capability, and that the birds had

endured needless suffering as a result of a lack of

shelter/protection from the sun and lack of

ventilation or other means of cooling.  She was

also advised that FSIS personnel had notified her

regarding the above noted conditions when we

(b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 9

EstNbr EstName NR# Date Task Regs Description Status

observed that the establishment had failed to

implement any readily apparent corrective actions

in response to the aforementioned conditions.  

, was also notified of

the noncompliance. Based upon my

observations of the birds’ condition and the

establishment’s failure to implement any  readily

apparent corrective actions (prior to FSIS

notification regarding the  aforementioned) , I can

say that a large number of birds died by a means

other than by slaughter on the regulated premises

as a result of the demonstrable loss of process

control.

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 10

EstNbr EstName NR# Date Task Regs Description Status

P1249 George's

Chicken, LLC

UVG30

210157

30N-1

01/27/2017 04C05 381.65(b) At approximately 17:55 hours, while performing

the Poultry Good Commercial Practices

Verification Task, I, , observed a

cadaver bird on kill line 2 as it traveled through

the picking room.  I followed this bird to the

Evisceration Department and removed it at the

rehang station.  Immediately I went to the Live

Receiving Department and notified 

 and 

of my findings.  Thereafter, I went back to the

Evisceration Department and found 5 cadavers in

the inedible barrel.  This was confirmed by

 who

observed with me that there were five small birds

with the heads still attached and no kill cuts on

the necks.  The birds were also deep purple in

color due to not having bled out.  

notified and 

 of these findings.  At approximately 20:50

hours, I continued my verification task and once

again saw a cadaver on kill line 2 in the picking

room.  I followed this bird, removed it from the

line in the Evisceration Department and then

checked the inedible barrel.  In addition to the

bird taken directly off the line, there were 9 more

cadavers in the inedible barrel.  Immediately I

informed and he confirmed my

findings.  At approximately 21:12 hours, 

 was also notified.  The problem was

addressed when 

made adjustments to the kill blade and took over

the position of backup cutter.  This issue was

initially expressed as a concern on

1/25/17 however, subsequent actions taken did

not adequately address the problem.  (See MOI

#UVG10000151251.) This is a failure of 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.  Blood from the killing

CLOSED

(b) (6)

(b) (6)

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

(b) (6)

(b) (6)

(b) 

(6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 11

EstNbr EstName NR# Date Task Regs Description Status

operation must be confined to a relatively small

area."

P7903 Perdue Foods,

LLC

UYN471

008451

5N-1

08/15/2017 04C05 381.65(b) At about 1345, I was called downstairs because a

food inspector on line 2 had retained some birds

for veterinary disposition. The food inspector had

retained two cadavers. One cadaver still had the

head attached, and there was no neck cut. The

other cadaver was missing the head and had a

bloody neck. While I was examining the birds, the

food inspector pulled off a second cadaver that

still had the head attached and no neck cut. I

proceeded to the rehang table for line 2 and

looked through the large blue container that held

birds from line 2. In the container were five more

cadavers with the heads still attached and no neck

cuts and two cadavers with the heads missing and

bloody necks. I demonstrated the cadavers to N/S

 and 

. informed me the reason

for the cadavers was the N/S back up cutter on

line 2 had temporarily left his position to retrieve

equipment he needed for work. I informed 

 and this was a noncompliance

according to 9 CFR 381.65(b), and a NR would be

forthcoming.       The establishment is reminded

that NRs for noncompliance with 381.65(b) and

MOIs for GCPs when finalized are posted for

public review on the FSIS website and that the

information associated with NRs and GCPs can be

FOIA requested by individuals from the general

public.

CLOSED

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

(b) (6)

(b) 

(b) (6) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 12

EstNbr EstName NR# Date Task Regs Description Status

P1241 Tyson Foods,

Inc.

MGJ06

210102

04N-1

01/04/2017 04C05 381.65(b) At approximately 1555 hours, while I was

performing a Poultry Good Commercial Practices

task, I observed, within a 1 minute time frame, 2

chickens enter the scalding tank while fully

conscious and still breathing.  Neither of these

chickens were bleeding from the neck area, which

indicated that these chickens were not cut at all

by the kill machine or the back-up killer.  Upon

further investigation, I observed that the back-up

killer was an individual who was inexperienced at

that position.  This finding showed that process

control was lost for handling live birds and that

the establishment was not operating in

accordance with poultry good commercial

practices.  I notified of the

noncompliance and of the impending

noncompliance record.  (NR# 6)

CLOSED

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 13

EstNbr EstName NR# Date Task Regs Description Status

P1241 Tyson Foods,

Inc.

MGJ56

100354

01N-1

03/01/2017 04C05 On 3/1/17, while performing a good commercial

practices task at approximately 0950 hours, I

observed one cadaver bird past the pickers. I

immediately told 

. I immediately went to verify at a

location prior to the scald tank that no additional

live birds were entering the scald tank. At 0958

hours, I observed 2 birds with their heads lifted,

vocalizing and no kill cut enter the scald tank over

a 3 minute time period. On my second verification

at 1008 hours, I observed 3 birds enter the scald

tank with their head lifted, vocalizing and no kill

cut over a 2 minute 49 second time period. After

each verification and observation of live birds

entering the scald tank, I informed 

, and observed her pull a total

of 7 birds with either no kill cut or a small cut on

the back of the  head as they exited the final

picker, which corresponded in time to the live

birds I observed enter the scald tank. On my

third verification at 1016 hours, I observed a bird

enter the scald tank breathing with the head

lifted, vocalizing and no kill cut. I immediately

informed and 

, I was taking regulatory control

action over the line due to a lack of process

control and the birds were stopped from hanging.

Three (3) addition cadavers were pulled off the

line after the last picker, which corresponded in

time to the live bird I observed enter the scald

tank. I informed both and 

 I will write a NR due to

non-compliance with 9 CFR 381.65(b). A meeting

shortly followed with Shane Carpenter (Plant

manager), ,

, and

 and myself,

were I was given some immediate measures the

establishment would take to prevent live birds

from entering the scald tank including a different

person designated as the backup killer and a

CLOSED

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

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

(b) (6)(b) 

(6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 14

EstNbr EstName NR# Date Task Regs Description Status

member of management with the backup killer to

verify training. (NR#52)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 15

EstNbr EstName NR# Date Task Regs Description Status

P1241 Tyson Foods,

Inc.

MGJ56

100354

01N-2

03/01/2017 04C05 381.65(b) On 3/1/17, while performing a good commercial

practices task at approximately 0950 hours, I

observed one cadaver bird past the pickers. I

immediately told 

. I immediately went to verify at a

location prior to the scald tank that no additional

live birds were entering the scald tank. At 0958

hours, I observed 2 birds with their heads lifted,

vocalizing and no kill cut enter the scald tank over

a time period. On my second verification

at 1008 hours, I observed 3 birds enter the scald

tank with their head lifted, vocalizing and no kill

cut over a time period. After

each verification and observation of live birds

entering the scald tank, I informed 

, and observed her pull a total

of 7 birds with either no kill cut or a small cut on

the back of the head as they exited the final

picker, which corresponded in time to the live

birds I observed enter the scald tank. On my

third verification at 1016 hours, I observed a bird

enter the scald tank breathing with the head

lifted, vocalizing and no kill cut. I immediately

informed and 

, I was taking regulatory control

action over the line due to a lack of process

control and the birds were stopped from hanging.

Three (3) addition cadavers were pulled off the

line after the last picker, which corresponded in

time to the live bird I observed enter the scald

tank. I informed both and 

 I will write a NR due to

non-compliance with 9 CFR 381.65(b). A meeting

shortly followed with Shane Carpenter (Plant

manager), ,

, and

 and myself,

were I was given some immediate measures the

establishment would take to prevent live birds

from entering the scald tank including a different

person designated as the backup killer and a

CLOSED

(b) (6)

(b) (4) (b) (4)

(b) (6)

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

(b) (6)(b) 

(6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 16

EstNbr EstName NR# Date Task Regs Description Status

member of management with the backup killer to

verify training. (NR#52)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 17

EstNbr EstName NR# Date Task Regs Description Status

P727+V727 Simmons

Prepared

Foods, Inc.

VCF181

007272

7N-1

07/26/2017 04C05 381.65(b) On July 26, 2017, at approximately 06:30 hours,

IPP informed me that the establishment was going

to early break on Line and but was uncertain

of the reason. Since Kill line 2 was stopped, I went

to the live hang area to observe that the birds

were being slaughtered in accordance with good

commercial practices due to two different issues

related to maintenance break downs. I observed

four birds with no cut immediately prior to the

guide bar. As I was determining whether the birds

were alive or suffocated, entered

and shortly there after, they restarted Kill Line 2.

Both back-up killers for Kill Line 2 were

unprepared for the starting of the line. One

quickly grabbed his knife and began performing

kill cuts on those missed by the machine.  The

back-up killer was struggling to perform kill cuts

on the birds that had been missed by the kill

machine and the other back up killer was

retrieving his knife. Since I was unable to

determine how many carcasses had been missed

by the kill machine, I went to observe carcasses

exiting the scalders/pickers. I observed one

carcass in which the breast, neck, and head was

bright red to purple in color. I observed three

other carcasses that the head and neck were red

to purple in color. The first carcass in which nearly

the entire carcass was red to purple was disposed

of via a condemn barrel by an evisceration

supervisor.  The other three carcasses were also

disposed of via the condemn barrel.  At this point,

IPP requested assistance with an insanitary

condition. After completing providing assistance,

I returned to the office at approximately 07:05

hours. At 07:10 hours, ,

entered the office to discuss the insanitary

condition at the rehang table. After completing

that conversation, I notified that

allowing carcasses to enter the scalder without

ensuring that breathing has stopped prior to

scalding is not consistent with being slaughtered

CLOSED

(b) (6) (b) (6)(b) (6) (b) (4 (b) (4
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 18

EstNbr EstName NR# Date Task Regs Description Status

in accordance with good commercial practices. 

Since cadavers have been discussed previously as

documented in MOI (VCF1013040021E) and

based on my observations which indicate a loss of

process control, I informed that at least

an MOI if not a noncompliance would be

forthcoming. These observations indicate a loss of

process control and the establishment failed to

ensure that poultry are slaughtered in accordance

with good commercial practices to result in a

through bleeding and ensure that breathing has

stopped prior to scalding. This indicates

noncompliance with 381.65(b).

P165H OK

Foods

Processing

Plant

DAF332

205502

9N-1

05/29/2017 04C05 381.65(b) While conducting a GCP verification on the

evisceration/slaughter floor, I observed the

following non-compliance. At 2138 hours, I 

 observed that Evisceration line 1 and Kill

Line 1 had stopped for an unknown length of

time.  As I made my way back to the stunner at

approximately 2139 hours, I observed that the

stunner for Line 1 had not been lowered. 

Approximately 30 birds were submerged, limp,

and lifeless in the stunner. These birds had

drowned in the stunner.  At 2141, an employee

arrived to lower the stunner, which was too late.

These birds had already expired.  Line 1 started

back up at approximately 2142. I took a visual

regulatory control action and had the line

stopped. arrived

and he and an employee removed the

drowned/dead birds from line 1 in my presence.

After the birds were removed, I observed the

stunner, to ensure no other birds had died by

drowning. The kill line was released and restarted

at approximately 2145. I continued to observe the

slaughter process, to ensure no other

non-compliances. These birds died other than by

slaughter. The requirements of 9 CFR 381.65(b)

were not met.

OPEN

(b) (6)

(b) 

(6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 19

EstNbr EstName NR# Date Task Regs Description Status

P550 Simmons

Prepared

Foods, Inc.

XWN35

020253

10N-1

02/02/2017 04C05 381.65(b) On 2/2/2017, at approximately 2100 hours while

giving line inspector breaks on evisceration line 2 I

was being presented birds that were small in size

and had poor neck cuts, some only having the

tops of the heads cut off not the neck cut with

varying amounts of clotted blood pooling in the

neck region of carcasses.  During this time while

giving breaks on line 2 there was one carcass that

was condemned being a cadaver, there was a cut

on the back of the neck but the vessels of the neck

had not been severed.  

 was notified of the poor neck cuts and

informed me management had made adjustments

and the small birds were being missed by the

head puller.  At approximately 2136 hours, once I

completed line inspector breaks, as I entered the

live hang area of the establishment I observed

approximately 50 live chickens scattered on the

floor around the live hang conveyor belts in the

middle of the room. 

 was outside the door

to live hang and notified of the condition of the

live hang area.  Once he observed the birds

scattered on the floor he immediately instructed

the employees to go to break.  The department

supervisor and lead employee were not present at

the time.  I observed the kill line 2 backup kill

employee from the window in the room, the

backup killer was having to cut 4-6 birds in a row

with 2-3 birds in between before getting 4-6 birds

in a row again needing the necks cut after the kill

machine.  also observed this taking

place as the birds emptied on the line.  

was notified of the loss of process

control at the backup kill station and the

noncompliance with 9CFR 381.65(b) for not

maintaining control of the kill process.  Verbal

corrective actions given by were

the stunners were adjusted for the small bird size,

an additional backup kill employee was placed at

the station and the kill line speed slowed to

CLOSED

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

(b) (6)

(b) 

(6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 20

EstNbr EstName NR# Date Task Regs Description Status

bpm.  I verified these corrective actions prior

to production resuming in the area.  This

noncompliance is being associated to

NR#XWN2605122419/1N issued on 12/19/2016

for similar cause of loss of process control for the

kill process.

P550 Simmons

Prepared

Foods, Inc.

XWN34

050551

01N-1

04/28/2017 04C05 381.65(b) Friday, April 28, 2017 at approximately 1207

hours while observing the kill process as part of

the good commercial practices check, I observed

the back-up killer for kill line 2 step down off his

stand and leave his station. I observed a chicken

that did not get a neck cut by the kill machine go

past the back-up killer's station. I stopped the line

to prevent this bird from entering the scalder

alive. I notified of the

noncompliance. He had the lead replace the

back-up killer to take him to the office for

counseling. I then restarted the kill line at

approximately 1210 hours. The above described

event reflects a lack of process control in the kill

area. The establishment failed to meet the

requirements of 9 CFR 381.65(b) which requires

poultry to be slaughtered with good commercial

practices that will result in thorough bleeding of

the carcasses and ensure that breathing has

stopped prior to scalding.”

CLOSED

(b) (6) (b) (4) (b) (4)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 21

EstNbr EstName NR# Date Task Regs Description Status

P550 Simmons

Prepared

Foods, Inc.

XWN59

140651

14N-1

06/14/2017 04C05 381.65(b) On Wednesday, June 14 2017 at approximately

1350 hours while performing a good commercial

practices check, I observed that the back-up killer

was not on his stand on the kill line that feeds

evisceration lines and When I saw a bird not

killed by the machine, I stopped the line. The

back-up killer appeared from the blood tunnel.

The supervisor came and I talked to him about the

problem, then we restarted the line. I also

discussed it with the superintendent, then went to

the evisceration area. A supervisor told me an

inspector on line had just hung back two birds

for me. I went to look at them, and determined

that they were cadavers. I then went to the

picking room to look at the birds going to the

scalder on that kill line. I was accompanied by the

. I observed the

birds heading from the blood tunnel to the

scalder. I saw one that was alive with no neck cut

at all. I pointed it out to , who pulled it

from the line. The above described event reflects

a lack of process control in the kill area. The

establishment failed to meet the requirements of

9 CFR 381.65(b) which requires poultry to be

slaughtered with good commercial practices that

will result in thorough bleeding of the carcasses

and ensure that breathing has stopped prior to

scalding.” A similar finding in which the

same back-up killer left his station was

documented on an NR #XWN3405055101/1N on

04/28/2017. The further planned action given by

the establishment to that NR was "Employee was

terminated." This further planned action was not

implemented or was insufficient to prevent

today's finding. Associated noncompliances are

discussed in the weekly meeting with plant

management. The weekly meetings are

documented on an MOI and a copy of the MOI is

provided to plant management. Continued

repetitive noncompliance with regulatory

requirements could result in increased

CLOSED

(b) (6) (b) (6) (b) (4 (b) (4) (b) (
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 22

EstNbr EstName NR# Date Task Regs Description Status

administrative/regulatory actions as described in

9 CFR 500.4. You have the right to appeal this

decision as delineated by 9 CFR 381.35.

M13289+P

963

Cargill Meat

Solutions Corp.

NRD43

070626

24N-1

06/24/2017 04C05 381.65(b) Today at approximately 0700 hours while

performing a good commercial practices check to

ensure birds were being processed according to

regulation 9CFR 381.65(b), I observed a

non-compliance. A bin containing approximately

25-30 birds on the north end of the live hang area

appeared to be very red in color. The birds had

been picked but not opened. Upon further

inspection the birds exhibited the signs of having

died by means other than slaughter. The skin was

very red, severe congestion in the proximal neck

near the head and inadequate or no cuts for

bleeding were observed by me, and

. I then checked birds on the kill line and

observed several hens and shorter

toms improperly cut and still breathing but not

yet to the scalder. A bird had been pulled off of

the line at the scalder and was sitting in the floor

because it had not died on the line prior to the

scalder. A regulatory control action was taken by

stopping the kill line. was notified

of the non-compliance and shown the breathing

and improperly cut birds. He investigated the

situation and after approximately 15 minutes to

alleviate the concern placed another backup killer

downstream to catch any missed birds and

identify birds prior to the scalder to allow them

time to bleed before going into the scalder. It

appeared that all the cadavers seen in the

condemned bin in the live hang area had been

removed at the hock cutter area. The live bird on

the floor was removed and dispatched of properly

and the birds improperly killed on the line were

re-cut and allowed to bleed properly. The

establishment's process for ensuring birds meet

the regulatory requirements was not adequate as

evidenced by the cluster of cadaver's and the

other situations described above.

CLOSED

(b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 23

EstNbr EstName NR# Date Task Regs Description Status

P72 Tyson Foods,

Inc

JPJ1319

054904

N-1

05/03/2017 04C05 381.65(b) At approximately 0425 hours on the morning of

5/4/17 (Night shift for 5/3/17) I was completing a

GCP for Live Hang Area.  When I arrived and my

eyes were adjusting to the dark conditions I

noticed DOA birds piled down the left wall of the

hanging belt and a large pile at the end of the

belt.  After a few minutes I noticed movement

from the pile of DOA birds at the front end of the

belt (The end away from the dumper).  At this

point I turned my light on and observed

approximately 6 birds in different positions

struggling to breath with DOA carcasses piled on

top of them.  I also noticed several birds with feet

sticking out from under DOA carcasses that were

kicking; some vigorously at times.  It was very

apparent that the live birds buried under the

DOA’s were smothering from pressure and lack of

oxygen.  At this time I stopped both live hang lines

and requested get .  At

0437 hours arrived and began digging

thru the birds down the left wall; he found

approximately 3 to 5 live birds buried in this pile

as well.  There were approximately 100 – 150

DOA’s piled up with approximately 20 live birds

buried completely or partially.  At 0445 hours I

observed the DOA belt going outside; the

carcasses on the outside appeared to be disposed

of correctly and humanely.  At 0447 hours

maintenance arrived to work on the DOA belt. 

After speaking to management I learned that a

truck had turned over during the night and the

large amount of DOA’s were a result of this. 

Management was aware and 

stated that he had watched a couple of the

cages of birds being dumped.  Management failed

to notify USDA in any manner.  was

notified at approximately 0430 hours by 

 that numerous Cadavers were being

found on his line.  At approximately 0420 hours

on my way to the live hang area, I noticed several

Cadavers in the transfer area both on the belt and

CLOSED

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

(b) (6)

(b) (6)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 24

EstNbr EstName NR# Date Task Regs Description Status

in the floor.  The plant failed to meet 9CFR

381.65(b).  Production was shut down from 0425

hours until end of shift.

P468 Peco Foods,

Inc.

JVD062

205480

6N-1

05/06/2017 04C05 381.65(b) P468, Peco Foods; Regulation 381.65(b); On

Saturday May 6th 2017 at approximately 21:30

hours, I observed the

following noncompliance while performing a

Good Commercial Practice verification task, (3)

three birds within five minutes on line 2 entered

the scalder still breathing and multiple birds not

properly bled out. I immediately took regulatory

control action by slowing the line speed from 

birds per minute to . I

reported my observations to 

) who was the individual to slow the line

speed. I returned to observe line 2 for another 5

minutes and verified that the pattern of birds

dying other than by slaughter had discontinued. I

verified line 1's speed at birds per minute of

the same lot and observed birds being bled and

slaughtered in conjunction with agency statutes

and regulations. During the time of this regulatory

failure P468 was slaughtering heavier than

average birds (projected weight of

9.91-10.21/bird) then what they are normally

used to; lot AR origins. The process the

establishment is using to slaughter poultry on line

2 is not in a manner that ensures that breathing

has stopped before scalding, so that the birds do

not drown, and that slaughter results in thorough

bleeding of the poultry carcass (9 CFR 381.65(b)).

P468 failed to implement their Animal Welfare

Guidelines under the heading of slaughter. The

line speed remains at bpm for line 2 during

heavier than average bird weight slaughtering,

ensuring the slaughter process is under control,

birds do not enter the scalder breathing, and that

adequate bleed out times for these larger birds

are met was

notified of the forthcoming non-compliance

CLOSED

(b) (6)

(b) (6)

(b) (4) (b) (4) (b) (6) (b) (4) (b) (4)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 25

EstNbr EstName NR# Date Task Regs Description Status

M7100+P7

100+V7100

Tyson Foods,

Inc.

ZHB532

106202

8N-1

06/28/2017 04C05 381.65(b) On Wednesday, June 28, 2017, at approximately

1820 hours the following noncompliance was

observed: on

Line 1 station 4 stopped the line and rung the

buzzer for me . She informed

me that while inspecting she had condemned

several cadaver carcasses one behind the other.

She stated that after the third carcasses she

informed plant management but nothing was

done to correct the problem and the cadaver

continued to come down the production line and

were condemned. The evisceration line was

stopped and the inspectors were evacuated to the

office because of chemical spill in the

chemical room. The plant was notified of the

process out of control and the forth coming

noncompliance. 

 stated that the killing machine blade was

not working properly. Evisceration line was

started and verified that the stunner,

killing machine blade and back-up killer was

working properly and process was back in control.

   The plant was notified of the process out of

control and the forth coming noncompliance. 

, stated that the

killing machine blade was not working properly. 

The total numbers of cadavers condemned for the

shift were 24. This does not meet the regulatory

requirements of 9CFR381.65 (b).

CLOSED

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

(b) (6)

(b) (6) (b) (4)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 26

EstNbr EstName NR# Date Task Regs Description Status

M7100+P7

100+V7100

Tyson Foods,

Inc.

ZHB432

208470

8N-1

08/07/2017 04C05 381.65(b) On Monday, August 7, 2017 at approximately

22:25, while performing GCP Task, I observed the

following noncompliance: after the line 1second

head puller, 4 birds were flapping and breathing

as they headed to the scalder; at the same

location another 5 were  flapping and blinking and

breathing when the line 1 second head puller

pulled their head off; additionally, approximately

25% of the remaining birds had kill cuts to the

back and side of their neck instead of across the

front and both jugular veins. Some of these birds

had shallow cuts on the skin of the neck and into

the trachea but had clearly missed the major

vessels of the neck. I pointed the noncompliance

out to , who had

maintenance adjust the kill machine. 

 arrived and observed 3 more birds flapping as

they by-passed the line 1 second head puller

heading for the scalder. reported that

maintenance was making adjustments to the kill

machine. When I had not observed any further

conscious birds at that location for 3 minutes, and

continued on my task to complete Ante Mortem

inspection, before returning to verify the kill

machine adjustment on the slaughter line.

However, I returned to find three more birds

flapping and breathing and by-passing the line 1

second head puller heading for the scalder. I took

the regulatory control action of stopping the

slaughter line while I explained that continuing to

allow birds to die by other than slaughter is

egregious and asked how the issue would be

corrected. again instructed maintenance

to adjust the kill machine. He accompanied me to

verify the effectiveness of the corrective

adjustments of the kill machines. We observed

three more birds, two of which had no throat cuts

at all, at the same location. I also pointed out that

the line 1 first neck puller was not set correctly, as

it was hitting the birds exiting the blood tunnel at

the level of the shoulder and the jouncing of the

OPEN

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 27

EstNbr EstName NR# Date Task Regs Description Status

carcass bodies against each other prevented many

heads from being pulled at that station and had

the added benefit of stimulating any of the birds

that had not been properly cut by the kill

machine. By approximately 23:20, the kill

machine adjustments had brought the process

back into control. If the noncompliance had not

been found by USDA, birds would have continued

to die by other than slaughter and not being

appropriately bled out as the process remained

out of control while not operating in accordance

with good commercial practices and adulterated

product could have been produced. This does

not meet the regulatory requirements of 9 CFR

381.65 (b).
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 28

EstNbr EstName NR# Date Task Regs Description Status

M7100+P7

100+V7100

Tyson Foods,

Inc.

ZHB382

308572

1N-1

08/21/2017 04C05 381.65(b) On Monday, August 21, 2017 at approximately

21:35, while performing GCP Task, I observed the

following noncompliance: before the line 1second

head puller, 2 uncut and conscious birds were

headed to the scalder. I immediately stopped the

kill line 1as a regulatory control action. Upon

returning to the line 1 second head puller station,

I was able to count 6 uncut and conscious birds.

observed the noncompliance and asked if he

could re-start the kill line. I explained that

continuing to allow birds to die by other than

slaughter is egregious and asked how the issue

would be corrected. I asked what he would do for

the live birds on the line heading for the scalder.

He did not answer. Next, 

, and ,

arrived and observed the noncompliance. When

asked how he would rectify the situation, 

stated he would remove the live birds and

adjust the kill machine and replace the relief

back-up killer. The live birds, totaling 21, were

removed from the line as the adjustments were

made. By approximately 22:20, the kill process

had been brought back into control. When I had

not observed any uncut birds or birds showing any

signs of consciousness for ten minutes, I requested

a meeting with APM Josh King and 

. When asked what measures

were taken to bring the process back into control

and compliance, stated that the kill

machine blade was raised to better cut the

smaller framed birds and the normal back-up

killer was back in place. I asked how they

intended to prevent similar incidents from

happening again. Mr. King stated that the

establishment policy of stopping the kill line to

prevent uncut birds from continuing down the line

to the scalders was in place. I pointed out that it

had not prevented a large number of uncut and

conscious birds long past the back-up killer station

OPEN

(b) (6)

(b) (6)

(b) (6)

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

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 29

EstNbr EstName NR# Date Task Regs Description Status

and heading toward the scalders. Mr. King

re-stated that the policy is in place to prevent

death by other than slaughter. He also stated that

the relief back-up killer from this incident would

not be allowed to perform that job again. I asked

how would they insure that the kill machine was

also adjusted per lot of chickens. Mr. King stated

that it was not always possible to adjust the kill

machine to kill birds of greatly varying sizes within

a lot. I pointed out that adjustments had reduced

the number of conscious birds along with the

placement of a competent and conscientious

back-up killer. , was notified of the

forthcoming NR and linkage. NR

ZHB4322084708N/1 dated 8/7/2017, describes a

similar occurrence where the establishment failed

to death of birds by other than slaughter. The

establishment has not answered that NR as yet. If

the noncompliance had not been found by USDA,

conscious birds would have continued to die by

other than slaughter and not being appropriately

bled out as the process remained out of control

while not operating in accordance with good

commercial practices and adulterated product

could have been produced. This does not meet

the regulatory requirements of 9 CFR 381.65 (b);

nor does it meet the establishment humane

handling training policy.

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 30

EstNbr EstName NR# Date Task Regs Description Status

M13456+P

13456+V13

456

Tyson Foods,

Inc.

BQB060

808472

5N-1

08/25/2017 04C05 381.65(b) August 25, 2017 at 0530 hours, I saw a plant

employee retrieving a cadaver from Line 2 near

the rehang table and throwing it into a condemn

barrel.  The condemn barrel contained seven

cadavers.  I was told that there were problems

with the stunner.  I went to the kill area and

noticed that both back up killers were in place. At

0630 hours, I observed a cadaver on each line,

heads still on.  I pulled one from the line,

requested reduction in line speed for both  kill

lines.  The request was not granted.  I requested

for the kill to be stopped, all birds on line at that

time pass through for inspection for I was going to

pull inspectors from the line.  The request was

refused.  The inspectors and myself walked to the

USDA office.  The cadaver was presented to the

complex manager.  Complex manager made sure

that both kill lines were reduced to slower speeds

than both evis lines.  I observed process to make

sure that it remained in control.

OPEN
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 31

EstNbr EstName NR# Date Task Regs Description Status

P206+V206 Pilgrim's Pride

Corporation

KCC552

302381

5N-1

02/15/2017 04C05 381.65(b) At approximately 2130 hours, while walking

through the picking room, I observed a cadaver on

the east picking line.  The cadaver was removed

by the pinner/sorter and I requested it be hung

back on the rack.  

 was shown the cadaver.  He stated

that he would take care of it.  At this time, the

 from the Cabinets was strong, so I

elected to have QA check the concentration. 

While performing this check, an additional 2

cadavers were removed by the pinner/sorter from

the east picking line.  After the check was

completed, at 2145 hours, I elected to observe the

birds at the pinner/sorter stands on the east

picking line.  In approximately 3 minutes, there

were 4 more cadavers observed.  Three of the four

carcasses were not cut on their necks.  

 was again shown the cadavers and

informed of the noncompliance.  Immediately,

after informing him of the noncompliance, two

more cadavers were observed on the east picking

line.  The cadavers observed were bright red

carcasses.  The cutaneous ulnar vein on the wing

was distended on several of the carcasses,

indicative that the birds were not bled out

properly.  Three of the carcasses had no cut on

their neck to allow proper bleeding and two

carcasses were cut extremely high on the neck,

near the beak, not allowing them to be properly

bled out.  Their were a total of nine cadavers

observed in this given time frame. The

establishment has failed to comply with 9 CFR

381.65(b) as poultry must be slaughtered in

accordance with good commercial practices in a

manner that will result in thorough bleeding of

the carcasses.  The number of cadavers observed

indicates a loss of process for handling birds and

therefore the establishment is not operating in

accordance with Good Commercial Practices,

allowing poultry to enter the scald tanks alive. 

Poultry that are not slaughtered in accordance

CLOSED

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

(b) (4) (b) (4)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 32

EstNbr EstName NR# Date Task Regs Description Status

with GCPs are considered adulterated and must

be condemned according to the Poultry Products

Inspection Act (PPIA).  This noncompliance will

be forwarded to the Front Line Supervisor, District

Office, and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.  This document serves as written

notice that continued failure to meet regulatory

requirements can lead to enforcement actions

described in 9 CFR 500.4.  

 P206

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 33

EstNbr EstName NR# Date Task Regs Description Status

P206+V206 Pilgrim's Pride

Corporation

KCC201

604452

5N-1

04/24/2017 04C05 381.65(b) At 1530 hours I was informed by 

that there was a Dead on Arrival truck full of live

and DOA birds. accompanied me to

observe the truck in live hang truck unloading

area. Once I entered live hang I notice DOA birds

piled 4 feet high on the floor and more DOA birds

being dumped onto the conveyor belt. I

proceeded to go outside to observe the DOA

truck. I witnessed an entire truck with 90% of the

birds DOA. Two cages were completely dented in

as if rammed by something large. I proceeded to

ask 

 what was the procedure for handling

the live birds. stated that they

would sort the live birds from the DOA birds. At

1645 hours I returned to check the progress of the

DOA sorting and didn’t see the truck. 

 stated that the truck was moved to the

holding barn to be sorted at the end of the shift. I

requested escort me to where the

birds were being held. Upon arrival to the holding

barn I witnessed live birds among the DOA birds.

Some live birds were still on top of the cages. At

1918 hours I was instructed by to

stop live hang. I applied U.S. Rejected Tag NO.

B38087084 at 1928 hours and informed 

 that the live birds are not allowed to be

held with DOA birds until the end of the night. At

1936 hours the plant brought the DOA truck back

up to live hang and began dumping the DOA birds

onto the conveyor belt to begin sorting again. I

released the tag at 1937 hours. At 2022 hours I

informed that the plant began

the sorting process but the birds were still alive

with the DOA birds stacked on the side of the live

hang dumper with live birds still in the cages with

the DOA birds.  I spoke with 

 and 

 whom stated the birds will be put to the

side to be hand sorted. stated all live

birds would be euthanized. I then witness only

(b) (6)

CLOSED

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

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

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

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

(b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 34

EstNbr EstName NR# Date Task Regs Description Status

two people sorting the entire truck of DOA birds. 

At 2107 hours I applied U.S. Rejected Tag NO.

B38087081 to live hang and instructed 

 that the tag would not be removed

until all live birds had been sorted from DOA

birds.  At 2147 I observed that all DOA birds had

been sorted and proceeded to remove the tag

from live hang. Live birds in cages with Dead on

Arrival birds will result in birds dying by crushing

and is not consistent with Good Commercial

Practices. It is important to treat poultry in a way

that ensures they do not die by means other than

slaughter. Employing methods of handling

consistent with Good Commercial Practices and 9

CFR 381.65(b) can help produce and

unadulterated product. As preventive measures

 told me he would document a

standard procedure for the proper sorting of DOA

birds.

(b) (6)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 35

EstNbr EstName NR# Date Task Regs Description Status

P206+V206 Pilgrim's Pride

Corporation

KCC121

105503

0N-1

05/30/2017 04C05 381.65(b) P206, Pilgrim’s Pride; Regulation 381.65(b); On

Tuesday, May 30, 2017 at approximately 0815

hours, I, , observed the

following noncompliance of regulation 381.65(b). 

While performing Operational SSOP Review and

Observation task, approximately 12 cadaver birds

were observed at the Pinning/Sorting station in

the Picking Room. The birds were bright cherry

red in color.  Some did not have a cut on the neck

to indicate that they had gone through the kill

machine properly.  On the others, it was difficult

to discern if there were cuts because the carcasses

had gone through two head pullers prior to

getting to the stations. I notified 

 who in turn

notified the Live Hang Supervisor.  In the

meantime, cadavers continued to intermittently

arrive at the Pinning/Sorting station.  The Live

Hang supervisor stated that she had a new person

backing up the kill machine.  Since the plant had

stopped hanging for the 0830 company break, I

instructed that when they started up

after break, they were to decrease the linespeed

in evisceration from birds per minute to 

bpm to assure that the employees performing

backup killing duties could adequately back up

the equipment to prevent birds from getting by

and entering the scalder still breathing.  I

proceeded to inform 

 and Ms. Tonja Byers, Plant Manager of

the increased incidence of cadavers.  The

establishment investigated the incident and found

that the back up killers did not have sufficient

training to prevent birds from getting by the kill

blade and into the scalder.  Also, the blade on the

kill machine was not the appropriate size for the

birds that were being slaughtered at the time. 

The appropriate sized blade was put onto the kill

machine.  The establishment also adjusted to

stunners to get a more complete stun so that

birds would enter the kill machine more

CLOSED

(b) (6)

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

(b) (6)

(b) (4) (b) (4)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 36

EstNbr EstName NR# Date Task Regs Description Status

uniformly. An extra back up killer was added to

the line.  At startup after break, the there were no

incidences of cadavers reaching the Pinner/Sorter

station.  The plant was allowed to slowly increase

the linespeed after demonstrating with each

increase that the problem had been taken care of. 

There were a total of 27 cadavers that reached the

station and all were condemned. 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. Pleaser

refer to NR# KCC2016044525, dated 4/24/17 for a

similar noncompliance of the establishment's

failure to adhere to performance of Good

Commercial Practices. You are hereby advised of

your right to appeal this decision as delineated by

381.35 of 9 CFR.
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 37

EstNbr EstName NR# Date Task Regs Description Status

P7044 Tyson Foods,

Inc.

GJJ222

201022

6N-1

01/26/2017 04C05 381.65(b) While in the picking room verifying conditions a

cadaver was observed on line one at

approximately 7:55pm.  The carcass had the head

attached with no neck cut, the body was red in

color and the head was dark red to purplish.  A

second cadaver was observed on line one at

approximately 8 pm.  The carcass had the same

appearance as the first cadaver without a neck

cut.  A third cadaver was observed on line one at

approximately 8:08 pm.  This carcass had the

same appearance as the first two cadavers but

had a cut on the back of the head with no neck

cut.  was notified

and shown the cadavers.  All three birds were

condemned.  Line speed on line one was reduced

10% from birds per minute to birds per

minute.  added an additional back up

cutter for the remainder of the evening.  This is

noncompliance with 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”.     

CLOSED

(b) (6) (b) (6) (b) (6) (b) (4) (b) (4)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 38

EstNbr EstName NR# Date Task Regs Description Status

P7044 Tyson Foods,

Inc.

GJJ442

201453

1N-1

01/31/2017 04C05 381.65(b) While in the picking room performing a Good

Commercial Practice Task a cadaver was observed

on the floor next to the drain.  The carcass had the

head attached, the body was red in color and the

head was dark red to purplish in color.  At

approximately 5:56pm a second cadaver was

observed on line two.  The carcass had the head

attached, the body was red in color and the head

was dark red to purplish.  A third cadaver was

observed on line one at approximately 5:57pm. 

The carcass had the same appearance as the first

cadaver.  A forth cadaver was observed on line

one at approximately 6:01pm.  This carcass had

the same dark red color to the body with a dark

red flaccid neck but no longer had a head

attached.  A fifth cadaver was observed on line

one at approximately 6:01pm.  The carcass had

the head attached, the body was red in color and

the head was dark red to purplish.  A sixth cadaver

was observed on line two at approximately

6:17pm.  This carcass had the same appearance

with the head attached and dark red to purplish in

color and the body red in color.  

 was notified and

shown the first five cadavers while 

 was notified and shown the

sixth cadaver.  All six birds were condemned.  Line

speed was reduced 10% from birds per

minute to birds per minute on both lines.  

 had maintenance adjust the blade on the

automatic knifes due to a change in bird size and

added an additional back up cutter for the

remainder of the evening.  This is noncompliance

with 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”. 

Regulatory control was released at 7:53 pm and

line speed increased back to birds per minute.

    

CLOSED

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

(b) (4) (b) (4) (b) (4) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 39

EstNbr EstName NR# Date Task Regs Description Status

P7044 Tyson Foods,

Inc.

GJJ230

006171

7N-1

06/16/2017 04C05 381.65(b) On 6-16-17 at approximately 5:20pm while in the

picking room verifying conditions 17 cadavers

were observed on the floor next to the drain.  The

carcasses had the heads attached, the body was

red in color and the heads were dark red to

purplish in color.  There was also a cadaver with

the head attached on the floor next to the hock

cutter on line two.  At approximately 5:27pm two

more cadavers were observed on the picking lines

and removed.  The carcasses had the heads

attached, the body was red in color and the heads

were dark red to purplish.  Another cadaver with

head attached was in the catch bin below the

hock cutter on line two.  

was notified and shown all 21 cadavers. 

All 21 birds were condemned.  had

maintenance adjust the blade on the automatic

knifes and adjusted the stunners.  This is

noncompliance with 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”.    

CLOSED

(b) (6)

(b) (6)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 40

EstNbr EstName NR# Date Task Regs Description Status

P7091 Pilgrim's Pride

Corporation

SBF091

902332

1N-1

02/20/2017 04C05 381.65(b) On February 20 , 2017 at approximately 2000

hours, while performing a Good Commercial

Practices verification, one cadaver bird was

observed in shackles exiting the final picker on the

picking line before reaching the rehang table. The

carcass was deep red to purple in color with a very

large, engorged head and did not have a single

bleeding cut on the neck. 

 was notified and shown

the carcass.

 was also notified.  

provided the corrective actions of

immediate disciplinary actions issued for the back

up cutter employee and preventative measures of

GCP training was scheduled for the end of the

shift for all team members that back up kill

including the supervisors. The back up kill

personnel will also be issued a different type of

eye protection to help the team member to

visualize the birds for the task at hand. Measures

to prevent the needless suffering, discomfort or

death of poultry throughout the entire slaughter

process failed to do so in this incident. In this

incidence, poultry were not slaughtered in a

manner that resulted in thorough bleeding of the

poultry carcass and did not prevent the needless

suffering and discomfort of poultry to ensure

breathing has stopped before scalding. This is a

noncompliance with 9 CFR 381.65(b) which states

in part: " 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. "  and  9CFR 416.4 (d)

which states “product must be protected from

adulteration during processing, handling, storage,

loading and unloading at and during

transportation from official establishments." 

Documented by 

CLOSED

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 41

EstNbr EstName NR# Date Task Regs Description Status

P7091 Pilgrim's Pride

Corporation

SBF121

102242

5N-1

02/25/2017 04C05 381.65(b) On February 25, 2017, at approximately 0815, I

examined a carcass that was hung back for the

PHV disposition.  I observed a carcass that was

erythematous in the neck area, the viscera pack

was congested with blood and the intestinal

vessels were injected with blood.  I notified

of

the cadaver.  At approximately 0930 the same

day, I observed another carcass hung back for the

PHV disposition.  This carcass exhibited the same

characteristics but was even more erythematous

in the cervical neck region, the trunk of the

carcass, and the vent area.  Upon observation of

the viscera pack, the intestinal blood vessels

appeared to be distended, the pack was

congested.  I notified again of the

disposition, cadaver.  The evisceration line was

slowed to birds per minute.  This is a

noncompliance with 9CFR 381.65(b) which states

in part:  “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.” Refer to a similar

noncompliance written on 2/21/2017,

SBF0919023321N/1. -

CLOSED

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

(b) (6)

(b) b) (4)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 42

EstNbr EstName NR# Date Task Regs Description Status

P7091 Pilgrim's Pride

Corporation

SBF312

103472

4N-1

03/24/2017 04C05 On 03 24 2017 at approximately 2020 hours

while performing the weekly record keeping

portion of the Good Commercial Practice for

Poultry Slaughter Task, 

observed the following noncompliance: Upon

review of the Slaughter Area Animal Welfare

sheets, in the upstairs QA Office above Cut Up and

Cold Rehang, first shift has been incorrectly

recording the amount of birds checked for each

column criteria ( for example: Proper Stun

Check - recorded number = 1/10 in opposition to

recording out of the 500 bird check as the

procedure is written). All of the records have been

reviewed from 03 01 2017 to 03 24 2017, with

every first shift document being recorded in the

same manner save one that only recorded the

number of birds observed with the specified

column's check criteria (for example: Proper Stun

Check - recorded number = 5). Each column has

an action number specified with which it appears

the first shift has been using as the base number

for each check (for example action number .

CLOSED

(b) (6) (b) (4)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 43

EstNbr EstName NR# Date Task Regs Description Status

P7091 Pilgrim's Pride

Corporation

SBF312

103472

4N-2

03/24/2017 04C05 On 03 24 2017 at approximately 2020 hours

while performing the weekly record keeping

portion of the Good Commercial Practice for

Poultry Slaughter Task, 

observed the following noncompliance: Upon

review of the Slaughter Area Animal Welfare

sheets, in the upstairs QA Office above Cut Up and

Cold Rehang, first shift has been incorrectly

recording the amount of birds checked for each

column criteria ( for example: Proper Stun

Check - recorded number = 1/10 in opposition to

recording out of the 500 bird check as the

procedure is written). All of the records have been

reviewed from 03 01 2017 to 03 24 2017, with

every first shift document being recorded in the

same manner save one that only recorded the

number of birds observed with the specified

column's check criteria (for example: Proper Stun

Check - recorded number = 5). Each column has

an action number specified with which it appears

the first shift has been using as the base number

for each check (for example action number ).

Though this record is not a CCP in the Hazard

Analysis, it is a part of the GCP monitoring that is

included in the HACCP plan. This is a failure to

comply with 9 CFR 417.4(a) 2 (iii) which states in

part "Ongoing verification activities. Ongoing

verification activities include, but are not limited

to:...(iii) The review of records generated and

maintained in accordance with § 417.5(a)(3) of

this part." and 9 CFR 417.5 (a) 3 which states in

part "(a) The establishment shall maintain the

following records documenting the

establishment's HACCP plan:

CLOSED

(b) (6) (b) (4)

(b) (4)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 44

EstNbr EstName NR# Date Task Regs Description Status

 and 9 CFR 381.65 (h) "Operations and

procedures, generally. (h) Recordkeeping

requirements. Official poultry slaughter

establishments must maintain daily records

sufficient to document the implementation and

monitoring of the procedures required under

paragraph (g) of this section. Records required by

this section may be maintained on computers if

the establishment implements appropriate

controls to ensure the integrity of the electronic

data. Records required by this section must be

maintained for at least one year and must be

accessible to FSIS." Documented by 

M17250+P

6+V6

Tyson Foods,

Inc.

UQI151

107432

9N-1

07/29/2017 04C05 381.65(b) July 29, 2017 at approximately 10:44 am, while

performing verification of GCP, I observed a

chicken that was trapped between the floor of the

cage and the frame of the cage battery. the door

of the bottom left cage was bent at the corner and

another chicken was caught in it. When the

battery didn't completely empty, the battery was

lifted back to allow the cage dump operator to

remove the bird stuck in the door and put it on

the live hang transfer belt. The operator continued

to attempt to empty the cage, dumping it forward

and lifting it back to dislodge the remaining

chickens. Unfortunately, he could not see that the

chicken trapped between the floor and the

bottom frame was working in conjunction with

the bent door to both crush the chicken and jam

the door. Once he was able to move the cage to

the return belt, he could understand the problem.

He was able to remove the stuck chicken but it

was already dead. The battery had to be removed

from the dump and placed on the tarmac for the

chickens to be extracted. This is documentation of

noncompliance with regulation 381.65(b), due to

failure to maintain cages in good repair.

CLOSED

(b) (4)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 45

EstNbr EstName NR# Date Task Regs Description Status

P522 Sanderson

Farms, Inc.

(Processing

Div)

IKB351

001203

0N-1

01/27/2017 04C05 381.65(b) On Friday, January 27, 2017 at approximately

1226 hours, and I observed

the following loss of process control on the

regulated premises at Sanderson Farms, Inc. P-522

when an attempt to salvage birds from a chicken

truck which had overturned was observed.  While

performing a Good Commercial Practice

verification check at the back corner of the

establishment premise the following observations

were made. Crew personnel were grabbing birds

from damaged cages and throwing the birds to

the ground.  Many times 2-3 birds were grabbed

at one time per hand.  A pile of birds was created

on the ground, several layers high, of birds on top

of birds.  Birds identified in this pile included live

birds, moribund birds, dead birds and birds with

traumatic injuries such as broken legs, broken

wings, head injuries, and birds with torn flesh

revealing muscle.  Birds that appeared to be

salvageable were grabbed from this pile of birds

and put into cages on a second trailer in order to

be taken to slaughter.  Birds that were determined

to be unsalvageable were thrown into the back of

a pickup truck to be disposed of at Rendering.  

 and I examined this truck bed filled with

birds.  We observed live and moribund birds in the

pile of carcasses.  No attempt to euthanize

breathing birds prior to throwing birds into the

bed of the pickup truck was made.  I stopped the

practice of throwing birds from the cages to the

ground. I requested the Plant Manager come to

the scene.  I detailed to the Plant Manager the

treatment of the birds that and I had

witnessed.  At this point, crew personnel were

instructed to euthanize breathing unsalvageable

birds.  AVMA guidelines for the euthanasia of

poultry were not followed.  I observed birds

grabbed and held by their heads as their bodies

were swirled in a circle.  I observed personnel grab

birds by the head and force the head down

towards the breast of the bird in an attempt of

CLOSED

(b) (6)

(b) (6)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 46

EstNbr EstName NR# Date Task Regs Description Status

cervical disarticulation.  and I observed

crew members poking and jabbing live and dead

birds with rods in attempts to shove birds to the

front of the cages for easy retrieval by other crew

members.  One rod utilized appeared to be

constructed from metal while the other rod

looked as if it was made from a one inch diameter

PVC pipe.   Gary Delancey, Plant Manager, was

notified of this noncompliance verbally and in

writing with the noncompliance record.

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 47

EstNbr EstName NR# Date Task Regs Description Status

P522 Sanderson

Farms, Inc.

(Processing

Div)

IKB321

907262

5N-1

07/25/2017 04C05 381.65(b) Today, July 25th, 2017, the following

noncompliance was observed by me, 

 at

P-522, Sanderson Farms, Inc: While returning

from giving breaks on the evisceration line, I

observed that one of the picking lines was

stopped. I proceeded to the live hang area and

observed that most of the live birds had been

removed from the stopped picking line. There

were still birds on the line in the stunner and

continuing on through the neck cutter and into

the blood tunnel. Most of these birds were dead

and their necks were cut. Live birds were observed

in the following locations: There were four (4)

live birds at the entrance to the stunner. The birds

were blinking, moving their heads and wings, and

breathing rhythmically. There was water spraying

onto the legs of the birds and running down their

bodies to their heads and faces. Some of the birds

had their eyes closed. There were two (2) live

birds at the exit of the stunner. I looked into the

stunner exit from above and observed two  birds

who were breathing as evidenced by the rhythmic

movement of their vents. I set my stopwatch to

begin recording the amount of time that the birds

were left hanging on the line. I then alerted 

 Mr.

Barry Sparks, Plant Manager, and 

 of my findings. 

stated that the stunner had been drained. All

three members of management stated that the

live birds could not be removed from the stunner

because it was still on. I asked if it was possible to

turn the stunner off and was told that it was not

possible to do so without turning off both

stunners. I asked if the live birds could be removed

from the line somehow. I was told that the live

birds would not be removed from the line. At

approximately 1816 hours, employees left the

area as this was the company lunch break. I

continued to observe the live birds in the stunner

CLOSED

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

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 48

EstNbr EstName NR# Date Task Regs Description Status

and did not leave the area myself. After the birds

had been hanging on the line for 23 minutes, the

line began to move forwards. I as birds from the

stunner passed through the automatic

neck-cutting machine. I observed as two of the

last birds on the line missed the automatic neck

cutting machine’s blade. The birds had flexed

necks and were not stunned, and no part of their

body entered the neck cutter. The employee who

works in this area as a backup cutter was not

present. I quickly proceeded to the scalder

entrance and observed as a total of four (4) live

birds entered the scalder. The first two live birds

that entered the scalder were located earlier in

the line than the two I’d seen skip over the neck

cutter. Subsequently, I saw two more live birds

enter the scalder alive; these two were in the very

last group of birds on the line. The above

observations represent a loss of process control.

The slaughter system was not adequately staffed

and the stunning equipment was not fully

operational. As a result, four live birds entered the

scalder and drowned.
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 49

EstNbr EstName NR# Date Task Regs Description Status

P6651 Tyson Foods

Inc.

MSO23

180955

08N-1

09/08/2017 04C05 381.65(b) On Friday September 8, 2017 at approximately

1149 the following Good Commercial Practice

noncompliance was observed by 

.  At the entrance to the scald tank

that feeds evisceration line two (B line) the first

live bird was observed entering the scald tank. 

There was a superficial cut across the trachea that

did not penetrate the trachea or any major

vasculature.  The bird was blinking, had pupillary

reflexes, rhythmic breathing and was flapping its

wings.  was immediately

notified and informed that this would be officially

documented.  Over the next several minutes

additional birds (three total) were seen

approaching the scald tank that were rhythmically

breathing with superficial cuts to the right side of

the neck that the Supervisor manually removed

the head just prior to entering the scald tank.  Line

two was stopped momentarily and the Supervisor

stepped away.  At this time there was a bird just

prior to the scald tank with an uplifted head, no

cut to the neck, blinking, rhythmically breathing

and pupillary reflexes.  immediately

informed the supervisor of this bird and he was

able to remove it from the line prior to it entering

the scald tank.  Without USDA intervention this

bird would have entered the scald tank alive as

well.  At 1159 hour two additional birds were

observed entering the same scald tank with

superficial nicks just causing abrasions to the right

side of the neck not cutting any vasculature that

were blinking, with pupillary reflexes, rhythmic

blinking and flapping.  Another bird was seen in

the same exact manner entering at 1206 hour.  At

this time was informed

that this would be documented as a

noncompliance and due to the numerous birds

seen entering the scald tank alive in a short period

of time and that it was advised to stop hanging

birds until adjustments could be made.  The above

incidents were discussed with 

OPEN

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 50

EstNbr EstName NR# Date Task Regs Description Status

 as well.  The establishment elected

to stop hanging birds and make appropriate

adjustments to the kill blade as well as manually

decapitate birds approaching the scald tank that

still had their head attached. This is a violation of

9 CFR 381.65(b) which states in part, “poultry

must be slaughtered in accordance with good

commercial practices.  Live bird(s) entering the

scald system live is a less than Good Commercial

Practices and results in adulterated product. The

establishment is responsible for ensuring that

birds under their control on the official premises

are treated in a humane manner that will

minimize excitement, discomfort, injury and/or

death by means other than slaughter. Past

similar Good Commercial Practice MOI

MSO5921094601I dated September 1, 2017 for

live birds entering the scald tank on the same

evisceration line in which previous preventative

actions either weren’t implemented or were

ineffective.

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 51

EstNbr EstName NR# Date Task Regs Description Status

P192 Pilgrims Pride

Corporation

OOB01

190233

28N-1

02/28/2017 04C05 381.65(b) On Tuesday February 28, 2017 at approximately

1456 the following Good Commercial Practice

noncompliance was observed.  The kill wheel on

line two was cutting birds just caudal to the beak,

very close to the head, in a much more distal than

typical location.  The back-up killer was cutting

numerous birds and appeared to have difficulties

keeping up with the number of birds that required

an additional cut as many birds were missed and

still flapping / minimally bled further down the

line.  Several maintenance employees were

observing the kill wheel at this time.  I then went

to observe where birds enter the scalder and saw

two birds enter that were rhythmically breathing

and flapping their wings.  I was able to observe

these birds closely as the line was paused at this

time.  I immediately notified 

 of the situation and she informed me that

the wheel was cutting birds low and would get an

additional back-up kill person to help keep up. 

While waiting on the additional employee I went

to further observe for live birds entering the

scalder.  At 1500 an additional live, rhythmically

breathing, flapping and actively moving bird

entered the scalder.  At this point an additional

back-up killer had still not arrived to correct the

issue.  I informed that the process

was out of control at this point and to not hang

any more birds until further corrective actions

could be taken.  U.S. rejected tag No. B38027079

was applied to the line.  This is a violation of 9 CFR

381.65(b) which states in part, “poultry must be

slaughtered in accordance with good commercial

practices”.

CLOSED

(b) (6)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 52

EstNbr EstName NR# Date Task Regs Description Status

P320 Sanderson

Farms, Inc.

MRA08

050215

08N-1

02/03/2017 04C05 381.65(b) At approximately 0620, while performing ante

mortem and GCP verification, the live hang area

was observed in an out of control process.

Numerous (over 100) birds were observed piled

on the floor at the East end of the live hang

conveyor, at least three feet high (the height of

the conveyor).  Also observed, along the North

wall behind the hangers, was a pile of birds

approximately two feet high. While most of the

birds were dead, some where not and left to

suffocate in the piles. Also observed were several

dead birds on the West end of the conveyor and

approximately 75 live birds in paw operations, an

area outside of the live hang area. 

 was present and

regulatory control was taken by instructing

management to stop hanging. While disposing

the dead birds, employees were observed not

following the proper procedure for disposal which

requires the removal of the heads of the dead

birds. Plant manager Dusty Evans was informed

and shown this noncompliance. Poultry must be

slaughtered in accordance with good commercial

practices, in a manner that results in thorough

bleeding of the poultry carcass and ensures that

breathing has stopped before scalding, so that the

birds do not drown (9 CFR 381.65(b)). This

noncompliance will be discussed in the next

weekly establishment awareness meeting.

CLOSED

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 53

EstNbr EstName NR# Date Task Regs Description Status

P1307 Mar-Jac

Poultry-AL

KIL1114

035106

N-1

03/06/2017 04C05 381.65(b) At approximately 13:45, while monitoring

operations in the rehang area of 1st Processing, I

observed the rehang employees condemn three

cadavers within approximately a  minute time

frame.  I checked the plant's record for

condemnations at the rehang and observed that

there had already been four cadavers condemned

at 13:40.  I also noted that between 11:30 and

13:40, there were approximately 15 cadavers

condemned.  I looked inside the kill room, and

observed that the kill machine backup person was

working continuously to cut the necks of birds

that were missed by the kill machine.   I

proceeded to the scalder area to observe birds

entering the scalder.  During a two minute

observation period, I observed three birds enter

the scalder which had their eyes open and

appeared to be alive.  Two of the birds had small

superficial neck cuts, but the third had no neck

cut at all.  I concluded that the establishment's

process was out of control.  I proceeded to the live

hang area to tag the hanging pen, but discovered

that live hang operations had already finished.  I

notified of my  findings,

and informed him that this warranted a

noncompliance record (NR). I asked 

what the plant's preventive measures were, and

he responded that maintenance would work on

the stunner after the shift ended.

CLOSED

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

Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 55

EstNbr EstName NR# Date Task Regs Description Status

P6137A Foster Farms NJN420

403283

1N-1

03/30/2017 04C05 381.65(b) On the night of 3/30/17, hang back

one carcass on line A, station #1 at 2320 for PHV

disposition. I observed the organs were

hyperemic, the back and part of breast areas were

reddish and the neck was limp. I determined it

was a DOA and communicated my finding to

.

Twenty minutes later, at 2340 hours, 

called me to make another disposition on a

suspect carcass. This one also had congestion of

the organs, floppy neck, foul odor and the liver

was friable. These are signs pertaining to DOA

carcasses and I made the determination that it

was a DOA. I informed 

 of the forthcoming NR. A DOA carcass

is considered to create insanitary conditions in

that it is adulterated and not intended for human

food. DOA carcasses are to be condemned at

ante-mortem inspection and should not be

dressed or conveyed into any department of the

official establishment where poultry products are

prepared or held [9 CFR 381.71(a)].

(b) (6)

CLOSED

(b) (6)

(b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 56

EstNbr EstName NR# Date Task Regs Description Status

P9897 New Stockton

Poultry

ZQE130

902191

3N-1

02/13/2017 04C05 381.65(b) On Monday, February 13, 2017, at approximately

0507 hours, observed

the following noncompliance of regulation

381.1(b)(v) and 381.65 (b) while observing the

killing procedures of Silky Chickens. The following

observation was observed and noted: 

  was using a knife to make

cuts in the necks of birds at a position next to the

scalder entrance, apparently making cuts to

correct inappropriate cuts performed by the

employee making cuts near the stunner. I asked

, while the line was still running,

why the line was still running when there was a

problem with making appropriate cuts. 

 stated to me that he could not stop the kill

or the line. I then observed 5 birds entering the

scalder that had reacted to the hot scald water by

attempting to lift their heads out of the water and

flapping their wings vigorously. I took immediate

regulatory control action by stopping the line and

kill operation and applied U.S. Reject tag

B21581214 to the live hang line, and also applied

US Reject tag B42127000 to the evisceration line. I

immediately contacted at

approximately 0511 hours and explained the

occurrence, and notified P9897 plant owner Mr.

Minh Luu of the regulatory control action. There

were approximately 50 birds that were on the

shackles inside the scalder tank and

approximately 50 birds on the post-picker

conveyor (there were no birds that were rehanged

onto the evisceration line shackles).  

inspected the birds on the post-picker conveyer,

and inspected approximately 20 birds; 10 of those

birds had very shallow cuts in the necks, and one

bird with no neck cut. Management failed to meet

9 CFR 381.1 (b), (v) and 381.65 (b)  and PPIA

Section 4 (g) (5) to prevent birds still breathing

from entering scalding tank. After the regulatory

control action was taken and after operations

were stopped, the establishment removed all of

CLOSED

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 57

EstNbr EstName NR# Date Task Regs Description Status

the birds from the scalder and removed all the

birds from the post-picker conveyor and

condemned and denatured the birds. The

establishment stated that their corrective action

and preventive measure will be to remove the

employee who had made improper neck cuts, and

place an employee who is experienced with

making proper neck cuts. They will also create a

monitoring and record keeping program for

ensuring appropriate neck cuts and thorough

bleeding of carcasses prior to entering the scalder,

and provide training to personnel on

observing/documenting the neck cuts and how to

take immediate corrective action. On February 13,

2017, at 1200 hours, following the

establishment's submittal of appropriate

corrective actions and preventive measures, U.S.

Reject tags B21581214 and B42127000 were

removed from the evisceration line and live hang

line by

(b) (6) .
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 58

EstNbr EstName NR# Date Task Regs Description Status

P533 Hain Pure

Protein

Corporation -

FreeBird East

AKB071

205321

6N-1

05/16/2017 04C05 381.65(b) P533; Hain Pure Protein; Regulation 381.65b; On

May 16, 2017 at approximately 0715 hours there

was the following noncompliance of regulation

381.65(b).   noted a large number

of empty shackles at the conclusion of giving

online inspection breaks.  went to live

receiving where he found plant management

removing dead birds from the live receiving belt. 

He was informed that there was a mechanical

issue with the dumper to hang room transfer belt

and live birds had smothered due to the dumper

belt continuing to dump live birds on top of each

other.  At this point no more birds were being

added and plant management was fixing the

equipment.  verified that condemned

birds were dead.  then notified me, 

   I traveled from another establishment

and by the time I arrived to live receiving all dead

birds had been removed, condemned, and

operations were operating normally.  I met with

.  He stated

that 198 birds had died by means other than

slaughter and that it was due to the transfer belt

‘slipping’ and not operating as intended.  The belt

had been tightened and the plant wants to install

an independent turn off switch for the dump belt

that allows the transfer and hang room belts to be

run to clear without that dumper belt continuing

to run.  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.

OPEN

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

(b) (6)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 59

EstNbr EstName NR# Date Task Regs Description Status

P533 Hain Pure

Protein

Corporation -

FreeBird East

AKB350

907161

8N-1

07/12/2017 04C05 381.65(b) P533; Hain Pure Protein; Regulation 381.65b; On

July 12, 2017 at approximately 1130 hours there

was the following noncompliance of regulation

381.65(b). noted a large number

of empty shackles while on the evisceration floor. 

 went to live receiving where he found

plant management removing a couple of dead

birds from the live receiving belt. He was informed

that there was an issue with moving birds from

the dumper to the live hang room transfer belt. 

At this point everything had been resolved and

operations were normal.  I was informed of the

incident.  In total 58 birds had died by means

other than slaughter.  Plant management cited

personnel error in dumping too many birds onto

the belt.  A camera has been installed as a

corrective action. 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.

OPEN

(b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 60

EstNbr EstName NR# Date Task Regs Description Status

P533 Hain Pure

Protein

Corporation -

FreeBird East

AKB080

909522

2N-1

09/21/2017 04C05 381.65(b) At P533; Hain Pure Protein on September 21,

2017, at approximately 1100 hours there was the

following noncompliance. On 9/21/2017, at

1130 hours, contacted me, 

 and told me of the following

incident.  On September 21, 2017, at

approximately 1100  hours, he  noted empty

shackles while on the evisceration floor. 

went to live receiving where he found a large pile

of dead birds on the floor. There were a total of

335 dead birds. This is consistent with the

malfunction of the belts that transport the birds

from the unloading area to the shackling area. 

Previous preventive measures have failed in

preventing the reoccurrence of these similar

circumstances as documented in the previous

noncompliance reports on 7/18/2017 NR

AKB3509071618N and on 5/16/2017 NR

AKB0712053216N.  informed  

, of his observations that he

was going to contact the SPHV. This large number

of dead birds at the end of the belts from the

unloading area to the shackling area is evidence of

a process out of control and is a Noncompliance

with 9 CFR 381.65(b).

OPEN

(b) (6)

(b) (6)

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

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 61

EstNbr EstName NR# Date Task Regs Description Status

M7559+P1

34

David Elliot

Poultry Farm

Inc.

SNA331

106011

9N-1

06/16/2017 04C05 381.65(b) On 06-16-17 10000 Cornish chickens arrived for

slaughter at P134, after the conclusion of the

day’s slaughter it was determined that there were

525 Dead On Arrival (DOA) chickens. The increase

in DOAs is likely consistent with the effects from

heat, as the temperature on this day was 75oF.

The Poultry Products Inspection Act (PPIA) (21

U.S.C. 453(g)(5)), 9 CFR 381.65(b), 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. The regulations also require that

poultry be slaughtered in accordance with GCP,

which means treated humanely.  It appears that

the Est. has lost control of its process for handling

birds and thus is not operating in accordance with

Good Commercial Practices for Poultry. On 06-13

-17 1337 DOA were noted at this Est. The

increased number of DOAs today is a

noncompliance with 9 CFR 381.65(b) which states

in part that Poultry must be slaughtered in

accordance with GCP.  I informed Mr. Moshe Fink,

establishment owner, of this noncompliance.

CLOSED
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 62

EstNbr EstName NR# Date Task Regs Description Status

M7559+P1

34

David Elliot

Poultry Farm

Inc.

SNA270

709502

7N-1

09/25/2017 04C05 381.65(b) On September 25, 2017 while performing a Good

Commercial Practices task at approximately

11:30am, I observed several crates of chickens

unloaded from the truck each containing

approximately 10-15 birds that were all dead on

arrival (DOA). At the conclusion of the day, it was

determined that there were 435 DOAs out of the

 that arrived at the establishment for

slaughter. The increase in DOAs on this day was

likely due to the effects of heat, as the

temperature on this day reached at high of 92F. 

The Poultry Products Inspection Act (PPIA) (21

U.S.C. 453(g)(5)), 9 CFR 381.65(b), 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.  The regulations also require that

poultry be slaughtered in accordance with Good

Commercial Practices, which means that they are

handled in a way that prevents needless injury

and suffering.  Based on today’s findings, it

appears that the Est. has lost control of its process

for handling birds and thus is not operating in

accordance with Good Commercial Practices for

Poultry. The increased number of DOAs today is a

noncompliance with 9 CFR 381.65(b) which states

in part that Poultry must be slaughtered in

accordance with Good Commercial Practices.  Mr.

Moshe Fink, establishment owner, was notified of

this noncompliance.

CLOSED

(b) (4)

Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 64

EstNbr EstName NR# Date Task Regs Description Status

P34508 Kam Fung

Wong

LRR300

607340

8N-1

07/07/2017 04C05 381.65(b) Today July 7th 2017, at approximately 0615 hours

while during my pre-operational  procedure in

poultry receiving area I observed the live birds

which were left over night was not fed and

watered. Immediately I asked he did not

response. I called and ask

him the same but no response. Immediately I

applied a USDA retain tag no B37056148. When

the corrective action was taken I removed the

USDA retain tag and allow them to start killing. 

This was a noncompliance regulation

381.65(b) ( OPERATIONS and PROCEDURES

GENERALLY) poultry must be slaughtered in

accordance with good commercial practices in a

manners. Continued failure to meet regulatory

requirements would lead to further enforcement

actions.

CLOSED

P44826 Case Farms

Processing, Inc

000140

703391

6N-1

03/16/2017 04C05 381.65(b) On 3-15-2017 at approximately 1500 hrs while

verifying GCPs in the unloading area I observed

two live birds in the combo used to store DOAs.  I

informed of my findings who in turn

notified the live hang supervisor.  I continued to

search through the rest of the DOA combo and

located two additional live birds underneath

numerous carcasses.  This document serves as

notice of the establishment's failure to comply

with 9CFR 381.65(b).

CLOSED

P44826 Case Farms

Processing, Inc

000390

304392

6N-1

04/25/2017 04C05 381.65(b) At approximately 4:31 AM while performing

Poultry good commercial practices for poultry

slaughter task at the chicken dumper in the live

hang station I observed the employee who

operates the dumper, dumped a cage full of birds

on top of  birds which were on the conveyor

belt. He should have waited till the conveyor get

cleared and there were no more birds on the

conveyor. This is incompatible with 9 CFR 381.

65(b). was

notified of the noncompliance.

CLOSED

(b) (6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 65

EstNbr EstName NR# Date Task Regs Description Status

P45045 Bee Bee Farms,

LLC

000391

604500

4N-1

04/04/2017 04C05 381.65(b) I on 4-4-2017 was assigned to

establishment 45045 Bee Bee Farms. At

approximately 1425hrs just prior to going to

break I noticed and employee in the doorway

between the  processing room and kill area. The

plant was getting ready to go on break and the

end of the birds hanging on the line were in the

processing room. That is when I notice the

employee in a yellow rain suit grabbing birds from

the inedible barrel and hanging them on the line

for inspection. At this time was

standing next to me working with the trimmer. I

stopped the line and asked her to walk over with

me. I noticed 

and had him meet us. I informed both of them of

the employee taking the birds out of the inedible

and hanging them on the line talked

to another employee standing there in Spanish

and asked him how many he had put on the line.

The employee said 10. At that time all the birds

from the corner to the inspection station were

condemned. The company had mechanical

problems and didn't run the rest of the day.

OPEN

P45068 NY Livestock

Market Inc.

000460

807252

9N-1

07/29/2017 04C05 381.65(b) At approximately 8:00 am while performing

operational inspection noticed that the

slaughterers are slitting the throats of the

chickens and putting them directly into barrels

with other chickens rather than allowing the

chickens to bleed out in cones.  This practice is

not in accordance with good commercial practices

and is noncompliant with regulation 381.65 (b). 

The slaughterers were told to immediately cease

slaughtering.  The establishment manager Winnie 

Wu was notified.

CLOSED

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 66

EstNbr EstName NR# Date Task Regs Description Status

P45131 Farbest Foods,

Inc.

000420

504512

8N-1

04/26/2017 04C05 381.65(b) 04/26/2017 at approximately 1100hrs., while

performing CI duties, I observed a bird with a

substantial amount of airsacculitis in the cavity.

This was an unmarked bird. Upon closer

examination I saw another bird with airsacculitis

in the cavity. I notified . I looked at

more unmarked birds and they were also infected

with airsacculitis. After viewing marked birds and

unmarked birds there were approximately 40+

birds that had airsacculitis in the cavity that

wasn’t removed was also notified. I

continued observing both marked and unmarked

airsacculitis birds with airsacculitis in the cavities

until approximately 1230hrs., when the lot

change occurred. Reg. 381.84 Carcasses of

poultry with evidence of extensive involvement of

the air sacs with airsacculitis or those showing

airsacculitis along with systemic changes shall be

condemned. Less affected carcasses may be

passed for food after complete removal and

condemnation of all affected tissues including the

exudate.

CLOSED

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

Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 68

EstNbr EstName NR# Date Task Regs Description Status

person at scalder to prevent  breathing birds enter

scalder and adjustment of kill machine.  At the

end of shift from Poultry Condemnation

Certificate (FSIS Form9061-2) I calculated that

there 218 cadavers.  Out of 677 condemned

carcasses 218 cadavers were 32.2 % of

condemned birds.
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 69

EstNbr EstName NR# Date Task Regs Description Status

P51165 Summit

Poultry, Inc.

FIY5513

081721

N-1

08/18/2017 04C05 381.65(b) On 08-18-2017 after my report to 

, both of us visited Summit Poultry

to evaluate the corrective actions/ preventive

measures adopted by establishment and following

was observed:  Earlier also

took regulatory control rejecting kill machine and

scalder under us tag# B42-145895 and

B41-861010. He notified plant manager Jack

Walton, and part

owner Rory Botto for corrective preventive

measures at 12:15 hours.     At 12:35  hours on

inspecting the birds leading for PM disposition

process out of control carcasseshad irregularly

slaughter marks on their necks, side of heads, on

back of necks, extensive mutilation of necks and

heads, slit open jaws and entire skins of neck.

Some decapitated and several with small nick on

side of neck no blood vessels or tracheas cuts

showing corrective action adopted by

establishment were not effective and not

sufficient enough to control GCPHP violation and

bring process under control.   I stopped the

evisceration line, took regulatory control rejected

the production line under tag# B41-8610110  and

notified the establishment Manager Mr. Jack

Walton, Roray Botto part owner and 

. In exit meeting with

above mentioned establishment designees

management were  informed that evisceration

process is out on control, there is regulatory

violation of 9CFR 381.65(b), establishment

slaughtering adulterated product per [9CFR

381.1(b) (v) and PPIA Sec.4 (g)(5)] and per 9CFR

500.2(a)(2& (3) regulatory control action is taken

by placing reject tag.    On further investigation I

observed one plant employee removing cadaver

birds coming out of pickers preventing to reach

rehang table and throwing on floor, these were 17

cadaver birds were counted. FLS noticed one live

bird running inside stunner to get out and

removed by plant employee. A cage rack next to

CLOSED

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 70

EstNbr EstName NR# Date Task Regs Description Status

scalder had three birds with partially cut necks,

slowly bleeding. was asked

to follow GCPHP to kill those birds to end

suffering. This NR is linked to # FI3122083728N

dated 08-17-2017     There was no significant

improvement from Corrective action / preventive

measures submitted by establishment on

08-17-2017 and adopted on 08-18-2017 were

either not sufficient or not fully implemented by

the establishment to control re-occurrence.  On

checking the manual slaughter at kill unit, three

plant designated employees were not trained

enough to perform humane slaughter. 

 was asked to demonstrate and

conduct training.  At the end of shift from Poultry

Condemnation Certificate (FSIS Form9061-2), I

calculated that there were 59 cadavers. Out of

949 condemned carcasses 59 were cadavers’

amount to 6.2 % of condemned birds. There is no

count available on birds coming out of pickers and

thrown into drains.

(b) (6)

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 71

EstNbr EstName NR# Date Task Regs Description Status

P51165 Summit

Poultry, Inc.

FIY2618

084928

N-1

08/21/2017 04C05 381.65(b) On 08-21-2017after my two reports to 

 in SDO,

at 10:30 am I was called in for correlation on

excessive number of cadavers by on line food

inspectors at Summit poultry. I visited Summit

Poultry to evaluate past two corrective actions/

preventive measures submitted by establishment

to control reoccurrence of cadavers and keeping

process under control and following was

observed: On inspecting the birds reaching for PM

disposition had had irregularly slaughter marks on

birds necks, back of necks and heads side,

extensive mutilation of necks and heads and

decapitated but  trachea not cut. Some with small

nick on sides of neck no blood vessels or tracheas

cuts showing corrective action adopted by

establishment were not effective and not

sufficient enough to control GCPHP violation.

Overall there was no significant improvement

from Corrective action / preventive measures

submitted by establishment on 08-17-2017 and

adopted on 08-18-2017.  On further investigation

I observed one plant employee removing cadaver

birds coming out of pickers preventing to reach

rehang table and throwing on floor. On checking

FSIS Form 6000-16 Poultry Inspection –Lot Tally

sheet showed 99 carcasses out of 394 were

condemned in cadaver category this amount to be

25.1% of condemned birds during inspection.  This

reflected that birds were still breathing on

entering the scalder die from drowning not from

slaughter and are, therefore, considered

adulterated and unfit for human food. These

cadavers were condemned on postmortem

inspection per 9 CFR 381.90.On checking the

manual slaughter at kill unit, three plant

designated employees were not trained enough to

perform humane slaughter.  I stopped the

evisceration line, took regulatory control rejected

the production line under tag# B41-861011  and

notified the establishment Manager Mr. Jack

(b) (6)

CLOSED
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 72

EstNbr EstName NR# Date Task Regs Description Status

Walton, Roray Botto part owner and 

. In exit meeting with

above mentioned establishment designees

management were  informed that evisceration

process is out on control, there is regulatory

violation of 9CFR 381.65(b), establishment

slaughtering adulterated product per [9CFR

381.1(b) (v) and PPIA Sec.4 (g)(5)] and per 9CFR

500.2(a)(2& (3) regulatory control action is taken

by placing reject tag.   This is third NR is linked

to NR # FIY5513081721N/1 dated 08-18-2017 On

reviewing past corrective preventive measures

There was no significant improvement from

Corrective action / preventive measures submitted

by establishment on 08-17-2017 and adopted on

08-18-2017 were either not sufficient or not fully

implemented by the establishment to control

re-occurrence.

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 73

EstNbr EstName NR# Date Task Regs Description Status

P51179+V5

1179

Sanderson

Farms, Inc.

000420

803082

0N-1

03/20/2017 04C05 381.65(b) On March 20, 2017 at 0815 hours while

performing a PHIS Good Commercial Practices

task at the beginning of the live bird dumper. I

observed the dump operator remove one live bird

from the dumper tracks outside the cages while

leaving one remaining live bird alongside it. The

remaining bird was crushed alive, slide forward

and crushed again by the establishment employee

operating the bird dumper. I approached the

establishment employee and informed him I

observed that there was a live bird that was

crushed by the dumper.  The dump operator

stated that “he knew”. This statement leads me to

assume the dump operator intentionally and

knowingly left the bird to die the way it did,

instead of removing it along with the other live

bird next to it. I immediately notified 

of my observation. 

stated that the employee will be written up

for the incident. Live birds in the dumper outside

of the cages will result in birds dying by crushing

and is not consistent with Good Commercial

Practices. It is important to treat poultry in a way

that ensures they do not die by means other than

slaughter. Employing methods of handling

consistent with Good Commercial Practices and 9

CFR 381.65(b) can help produce and

unadulterated product. As preventive measures

 told me he would take disciplinary

action against employee.

CLOSED

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

(b) (6)
Table: Noncompliance Reports in Response to foia2018-062 08:44 Wednesday, November 8, 2017 74

EstNbr EstName NR# Date Task Regs Description Status

P45939+V4

5939

Petersburg

Poultry

Processing

000370

608271

0N-1

08/09/2017 04C05 381.65(b) During todays Slaughter operations 8/9/2017 at

approximately 7:30am, 8:15am and 8:20am one

of the plant managers came into the processing

room with NO head cover or NO apron on while

the production line was running and birds where

hanging on the shackles. The manager had blood

from the kill floor on his outer clothing and NO

apron on. 9 CFR 416.5(b) clearly states Clothing,

Aprons, frocks, and other outer clothing worn by

persons who handle product must be of material

that is disposable or readily cleaned. Clean

garments must be worn at the start of each

working day and garments must be changed

during the day as often as necessary to prevent

adulteration of product and the creation of

insanitary conditions. Not only is this a federal

regulation but in the plants Food Safety System it

states; Food Safety System Section 4 Employee

Hygiene & Facility Information Page 2of3 

Facility Information 1. Clothing color code a.

Slaughter-Blue Apron This is a Non-Compliant

issue. 9CFR416.5(b)

CLOSED
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 1

EstNbr EstName Task_Code MOI# Date Description

M1328

9

Cargill Meat

Solutions Corp.

04C05 NRD43150

20122G

2017-02-22 Verified GCP and AM on lot # 1 at 1445 hours. Birds appeared

healthy, but hot. Birds in cages were panting, due to it being 76

degrees, sideboards up on cages, no fans on. Notified 

, fans were turned on for better air circulation. 

stated that with it being February, the establishment had not

anticipated warmer weather.

M1725

0

Tyson Foods,

Inc.

04C05 UQI050701

3012G

2017-01-12 , the District Veterinary Medical Specialist from the

Dallas District visited P6 on an unannounced review of Good

Commercial Practices. His entrance meeting with the IIC and

plant management started at approximately 11:00 am on

January 9, 2017. He outlined his intention to perform an audit

of slaughter operations on both shifts; including a review of the

holding sheds, cage dump, live hang, kill room operations and

bird condition before and after the pickers. was

accompanied on his audit by the plant manager Hunter Wray,

the and one of the three

area supervisors in the department. He observed the holding

shed and the unloading area (where cages are unloaded from

trailers, staged under partially-covered staging bays) and by

Hyster, are placed onto the cage dump’s transfer belt. He

observed the cage dump and the live hang operations. Then

entered the kill room and performed observations and

collected counts on animal welfare indices like, stunning and

kill-knife efficiencies, the activity of the backup killers, number

of broken/bruised legs and wings, and sensibility entering the

scald vat. When he completed is site visit, he had an exit

meeting of sorts with the IIC. He said that his observations

reflected his review of tasks and records in PHIS, that the

establishment was compliant with regulations. He suggested a

screen to protect staged trailers from direct sunlight and

suggested the establishment choose random times to perform

daily monitoring activities, instead of within the first two hours

of operations. He stayed to repeat his review of second shift

operations.

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

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 2

EstNbr EstName Task_Code MOI# Date Description

M1725

0

Tyson Foods,

Inc.

04C05 UQI222103

3122G

2017-03-22 On Monday, March, 20, 2017 at approximately 2105 hours I

performed a good commercial practice verification in the

picking room. I positioned myself at a point where I can directly

view both lines entering the scald vats. On picking line 2 I

observed one small bird, still breathing with no visible neck cuts,

entering the scald vat. The bird was hanging limply so it

appeared to be properly stunned but its head was tucked; thus

allowing it to miss the kill blade. While waiting for the cadaver

to exit the pickers, I continued to monitor both lines further in

addition to the backup killers. I retrieved the bird from the line

once it exited the pickers and then shared my findings with

. We briefly discussed

the drastic difference in bird size with the cadaver vs. other birds

on the line and he stated he would address this issue with the

backup killers and implement increased monitoring in the area. 

I returned to the same vantage point approximately 20 minutes

later and observed line 2 for 15 minutes and observed no

deficiencies as described above. This incident appears to be

isolated; no regulatory action was taken and a noncompliance

record was not written. FSIS encourages establishments to

abide by good commercial practices in the production of poultry

to ensure a wholesome product is being produced. The PPIA and

FSIS regulations require that poultry be handled in a manner

that is consistent with good commercial practices (GCPs), and

they not die by means other than slaughter. Management can

find useful information in the Federal Register on “Treatment of

Live Poultry before Slaughter”, published September 2005; it

contains FSIS recommendations concerning treatment of live

poultry before slaughter. Sincerely, 

 cc 

 David Thompson, DVM – Deputy

District Manager

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 3

EstNbr EstName Task_Code MOI# Date Description

M1798

0

Pilgrim's Pride

Corporation

04C05 ZBB271102

2623G

2017-02-23 While observing slaughter operations during a Good

Commercial Practices verification task, I observed the following

which resulted in the mistreatment of poultry: At

approximately 1230 hours on 2/22/2017, I observed two birds

hung up on the live hang transfer belt after the cage dumper.  I

notified and he

stopped the dumping after the cage dumper to release the

birds.  There was one dead bird (cause of death undetermined)

and one live bird that were hung up in the gap between the

junction of two transfer belts and the teflon bar placed along

the edge of the belts.  The establishment took corrective actions

and resumed operations.  I showed 

my observations where the birds got

hung up and he stated that to prevent a recurrence it would be

fixed after slaughter operations ended during the down shift.  At

approximately 1045 hours on 2/23/2017, I verified that the gap

between the two transfer belts was closed using a durable

flexible plastic so that birds could no longer get hung up in this

area.  I notified and 

 of this MOI.

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 4

EstNbr EstName Task_Code MOI# Date Description

M1886

6

Jennie-O Turkey

Store Sales, LLC

04C05 WJL33120

44705G

2017-04-05 To: Mr. Nate Weber, plant manager, p551, Jennie-O Turkey

Store        p551, Jennie-O Turkey

Store             This Memorandum of Interview will discuss the

finding of multiple cadavers at establishment p551, Jennie-O

Turkey Store, 2505 Willmar Av. SW, Willmar, MN 56201.  The

total number of cadavers for the month of March 2017 is well

above average and there are some shifts with numerous,

multiple cadavers.             On the day shift at p551, there were

43 cadavers for the month of March 2017.  There were also

some shifts with multiple cadavers.  For example, there were 17

cadavers on March 16, 2017; 11 cadavers on March 30, 2017, 4

cadavers on March 15, 2017, and 4 cadavers on March 27,

2017.  There are other shifts with more than one cadaver. 

            The noticeable increase in cadavers has been discussed

many times with plant management, both in weekly meetings

and in individual meetings with establishment supervisors. 

            Cadavers were discussed in the following weekly

meetings:                          2/24/17, MOI dated 3/3/17 

                        3/17/17, MOI dated 3/17/17                        

3/31/17, MOI dated 4/5/17             Various causes have been

offered by the establishment management and observations

and potential causes proffered by FSIS. As taken from the

weekly meeting notes:             “On Monday (2/27) and Tuesday

(2/28) there were at least 8 carcasses held back for PHV

inspection with the knife cut across the jaw or face. The cut

needs to be accurate to ensure complete bleed out. The

establishment adjusted the auto-knife up which resolved the

issue.”                         , Weekly Meeting MOI

dated 3/3/17             “On Thursday (3/16/17) there were 17

cadavers in 2 lots (4 in lot 5278 and 13 in lot 5279).  These

cadavers were the result of improper cuts.  Some hens were cut

across the beak, some toms were cut too shallow.  

discussed this with and   Some of the

miscuts occurred when the backup killer employee was the

regular person and when it was another employee.  Some of

these cadavers were miscut by the auto killer, where the blade

was not set properly resulting in cuts in the wrong location or of

inadequate depth.”                         , Weekly

Meeting MOI dated 3/17/17             “Many of the cadavers

appear to be miscut; the major blood vessels of the neck are not

cut.  has discussed this with the various supervisors,

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 5

EstNbr EstName Task_Code MOI# Date Description

including , and . 

This has also been discussed in previous weekly meetings.  The

various causes as told to me by the supervisors include the

automatic killer blade set too high or too low, on 3/30/17 the

CO2 concentration was a bit higher than usual, and on 3/30/17

it was Halal slaughter so the back up person to the automatic

killer blade was not the usual back up person.  

mentioned that there was a supervisor change in hang and kill

around the beginning of March.  The supervisor who was in

hang and kill for many years transferred to the night shift. 

            stressed this needs to be corrected.  

also said he would be discussing this with next

Monday, 4/3/17.”                         , Weekly Meeting

MOI dated 4/5/17             Discussions have occurred with

individual supervisors as well, including 

 and .  Various causes as offered by

establishment management include: the automatic killer blade

is set too low or too high, the blade does not cut deep enough,

or the normal back up person for the automatic killer  is not

there but rather someone with less experience.  There were 7

cadavers on 4/4/17.  Discussions occurred with 

 and on 4/4/17.  

indicated that he learned today there are additional

adjustments to the automatic killer blade that he was not

previously aware of.  He as been adjusting the automatic killer

blade vertically (up and down), but learned today the blade can

also be adjusted horizontally (make the cut deeper or

shallower).  told me today that 

 and until about one month ago, will

review the set up of the automatic killer tomorrow morning. 

Also, there are now two people to back up the automatic killer

instead of the usual one person.  and 

had a discussion regarding cadavers on the morning of 4/5/17. 

 informed that he had met with 

the previous supervisor of hang and kill, on the morning of

4/5/17; and had reviewed with how to set

up the automatic killer blade.  In summary, the majority of the

cadavers have been caused by miscuts; either the cut was too

low, too high, too shallow, or in the wrong location, relative to a

given carcass, and the major blood vessels were not cut at all or

only partially cut.

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 6

EstNbr EstName Task_Code MOI# Date Description

M1886

6

Jennie-O Turkey

Store Sales, LLC

04C05 WJL18070

93512G

2017-09-12 In attendance: Nate Weber, Plant Manager; 

 On Wednesday

morning at 12:46 AM, I observed a turkey crushed between the

truck hoist and wall in the live receiving area.  The bird had

fallen down from the walkway where plant employees remove

turkeys from the trailers and place them into the conveyor

system to the CO2 stunner.  This turkey became wedged

between the hoist and the wall, and when the hoist was moved,

the bird was crushed to death.  I did not see the turkey fall, but

I arrived after it was already wedged and crushed.  I have

occasionally seen turkeys on the ground that have fallen from

the walkway.  I also regularly observe plant personnel checking

under the truck and trailer as the hoist is lowered after

unloading is complete.  This incident was discussed at the

time with the supervisor of this area,  , who had an

idea for a barrier to prevent turkeys from being wedged and

crushed in this way.  This incident was discussed with plant

management at the weekly establishment meeting held on

9/8/2017.  At the weekly meeting, , the plant

engineer, said he will investigate possible solutions. I notified

 that this MOI will be forwarded to the District Office

and the District Veterinary Medical Specialists in case additional

follow-up is recommended.  Respectfully,

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 7

EstNbr EstName Task_Code MOI# Date Description

M1963

6

Tyson Foods Inc 04C05 MLG42130

12023G

2017-01-23 Establishment P19636, Tyson Foods On 01/23/2017 at

approximately 0925 hours while performing a good commercial

practices verification task, I noted a live chicken in the

establishment’s dead bin which was almost completely

entombed by a heavy accumulation of feathers, fecal material,

and dead birds.  Initially, I observed a pair of yellow legs/feet

sticking straight up out of the aforementioned detritus, and

upon further observation noted that they were moving. I

immediately pulled the bird out and noted that it was conscious

and alert.    , was

notified of the aforementioned incident.  emptied

the dead bin to ensure that all other birds in the bin were dead.

, was also notified of the

aforementioned soon after the incident of poultry mistreatment

occurred.  In discussion with later that afternoon

(1345 hours), he stated that a written response from the

establishment would be forthcoming.  Federal Register Notice

Docket No. #04-037N dated September 28, 2005, "Treatment of

Live Poultry Before Slaughter," encourages those involved in the

slaughter of poultry to abide by Good Commercial Practices.   I

advised and  that a copy of this MOI

would be forwarded to the Jackson District Office and the

.  Respectfully, 

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 8

EstNbr EstName Task_Code MOI# Date Description

M2032

2

Equity Group

Eufaula Div LLC

04C05 ATF170103

2222G

2017-03-22 On March 22, 2017, at approximately 0100 hours, I, 

was conducting an observation of Good

Commercial Practices in the live hang area. I observed over 30

live birds on the floor, 4 of which were under the wide

(dumping) belt, covered with very wet fecal matter. At the end

of the live hang belt, there was a pile of dead birds, numbering

more than 20. Upon moving several dead birds, I uncovered two

live birds. The , came over to

this pile of dead birds just as I was starting to unbury the live

birds. He then picked them up and placed them on the live hang

belt. It is a logical to conclude that these birds I had uncovered,

would have died from asphyxiation, without USDA intervention.

This would have been death by other means than slaughter. At

approximately 0105 hours, ,

was notified of my findings and subsequent issuance of this GCP

MOI. Per Federal Register Docket #04-37N, the establishment is

to treat poultry in a manner consistent with good commercial

practices and take steps to prevent the mistreatment, harm, and

injury by means other than slaughter. Also, such abuse of

poultry and the treatment in a manner not consistent with good

commercial practices, and death by means other than

slaughter, will render the poultry  adulterated.

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 9

EstNbr EstName Task_Code MOI# Date Description

M248B Butterfield

Foods Company

04C05 GXN30170

33113G

2017-03-13 Est. P215, Butterfield Foods Company, March 13, 2017, 1630

hours.  In attendance: 

 At 1540 hours on 03/13/2017,

while performing a Good Commercial Practices Task in the

pinning room, I observed an establishment employee holding a

cadaver bird with no neck cut.  I notified 

 and immediately presented him with the bird which

he proceeded to show the employees at the kill machine.  He

suggested that there may have been two birds on one shackle

causing the bird to not get cut.  At approximately 1543, I

observed an additional cadaver bird exit the feather pickers.  I

confirmed that this bird also had no neck cut.  I immediately

presented the second cadaver bird to who made

adjustments to the kill machine.  I did not observe any live birds

enter the scald tank.  At 1630, I discussed my findings with

.  At this time a definitive

cause could not be identified by the establishment for

the cadavers with no neck cut.  It is required that establishments

slaughter poultry in accordance with Good Commerical

Practices and  that all birds are bled out to ensure breathing has

stopped prior to entering the scalder.

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 10

EstNbr EstName Task_Code MOI# Date Description

M2738

9

Pitman Farms 04C05 NCO02070

71721G

2017-07-21 On July 20, 2017 At approximately 03:47 hours while

performing a Poultry Good Commercial Practice task, I 

) walked into the new duck line Wax Room. I then

headed toward the Live Hang area from the East end of the

establishment. At that distance I was able to view a section of

the module and one employee grabbing a duck from the cage

on the module. This employee did an over-hand tossing motion

with a bird to the opposite end of the module. He then pushed

the cage in the module and pulled another cage out to remove

ducks from the cages. At this point I was able to view the entire

module and the employees on the opposite side of the module

which was hanging birds on the shackles going into the

Stunning/Wax Room. At this point I observed the same

employee grab two ducks with one hand and repeated the same

over-hand motion he was previously doing to get the ducks to

the opposite side of the module. He released both ducks while

still in the passing motion. I clearly observed one bird land on its

back and the other landed on its side. I observed this

unacceptable behavior deeming the process out of control. The

employee was unaware that I was approaching and continued

to individually pass five more ducks from the cage and on to the

module. At this point I was at a close enough distance to ask

them to stop hanging birds and to locate a 

 arrived and I informed him of what I had

witnessed. I then informed that live hang was

stopped for the time being and that I would discuss this

occurrence with the . During my walk toward the

USDA Office I informed 

and 

 of my findings. After informing 

 of the occurrence, she instructed that both evisceration

lines be stopped until further instruction from .

US reject tag (NO.B41201075) was applied to the live hang

equipment. went to Live Hang, confirmed that no

birds were being harmed and informed the supervisors of the

forthcoming GCP Memorandum of Interview. Both lines were

released per instructions and 

confirmed that the process was back to an acceptable level of

Good Commercial Practices.

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

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

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

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 11

EstNbr EstName Task_Code MOI# Date Description

M2738

9

Pitman Farms 04C05 NCO56060

95405G

2017-09-05 At approximately 2345 hours while performing a Poultry Good

Commercial Practice Task, I ) walked into the

new duck line to the CO2 chamber. As I was observing the ducks

coming out of the CO2 chamber, I noticed the ducks were not

gased and were fully awake. I saw one jump out the green open

module (height of jump was approximately well over 6 feet). At

this time was observing the

situation. She immediately took action by picking up the duck

and checked to see if it was hurt, then handed the duck to 

 I proceeded to watch to see

what the establishment was going to do with the rest of the

ducks that were trying to jump out. As they proceeded to keep

hanging live and fully awake ducks, I observed six ducks jump

out of the green modules. I immediately told to

cover the green modules because the ducks were continuing to

jump approximately over 6 feet out of the green modules onto

the cement floor. I observed this behavior to be unacceptable

and that the process was out of control. I also questioned 

 on the functionality of the CO2 chamber and if the

establishment was utilizing their backup stunner. He replied

“the CO2 is being worked on and that he will have the ducks go

through the back up stunner.” I informed that I

would be documenting an MOI and that I would discuss this

occurrence with the .  During my walk toward

the USDA Office I informed 

), and ) of

my findings. After informing of the occurrence, she

immediately walked to the duck line.  After she noticed that one

duck was running on the floor and another leaped

(approximately over 6 feet) from the open green module she

instructed and to stop hanging birds

until they were able to get the CO2 chamber to function

properly. instructed me to observe the

establishment’s corrective action until all ducks that were not

gased and sitting in the three open modules were stunned

appropriately.  And that no ducks are to be transported on the

unloading conveyor without being anesthetized with CO2. At

approximately 1227 hours, I confirmed the CO2 gas chamber

was functioning properly and that the establishment had their

process under control.  I stated that that there will be a

forthcoming GCP Memorandum of Interview.

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

(b) (6)

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

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 12

EstNbr EstName Task_Code MOI# Date Description

M3213

0

Dakota

Provisions LLC

04C05 JEB491203

1321G

2017-03-21 Est. 32130, Dakota Provisions, 03/21/17, 1135 hours.  Meeting

Attendance:  and 

 On 03/21/17 at 1110 hours, while

performing ante-mortem inspection in the live hang

department, I noticed a turkey coop in line to be stunned with a

turkey’s leg that had fallen through the top cage deck and

hanging into the next floor below.  The cages are designed with

3 compartments/levels per coop.  The fiberglass floor was in

disrepair which allowed the bird’s leg to completely fall through

the floor and become trapped.  I immediately notified 

, of my observations and concern of

the welfare of the bird.  He grabbed a small ladder and was able

to push the leg up out of the hole.  I was unable to determine if

the bird was injured while still in the cage.  I retained the cage

with US Retain Tag. No. B42252089 and when the cage was

emptied after stunning, the cage was sent for repair.  Further

observations of the cage included the following:  Approximately

a 14 in. by 6 in. hole in the center of the top cage’s floor in

which the bird’s leg had fallen through, a 14 in. slit in the middle

cage floor, and the lower level also had a 4 in. by 4 in. slit in the

fiberglass floor.  There were also 4 broken wires on the outside

of the cage that needed to be repaired.  A discussion was held

with of my observations

and concern for animal welfare. The establishment must

employ humane methods of handling and slaughtering

consistent with Good Commercial Practices in a way that

minimizes injury to poultry.  Poultry are to be handled in a

manner that prevents needless injury and suffering.  Employing

humane methods of handling and slaughtering that are

consistent with good commercial practices increase the

likelihood of producing unadulterated product.

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

(b) (6)

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 14

EstNbr EstName Task_Code MOI# Date Description

M3213

0

Dakota

Provisions LLC

04C05 JEB230705

5916G

2017-05-16 Est. 32130, Dakota Provisions, 05/16/17, 0710 hours.  Meeting

Attendance:  and 

 On 05/16/17 at 0647 hours, while

performing ante-mortem inspection, I observed a turkey with

his right wing caught between the framework and the fiberglass

floor above him.  The bird was discovered in trailer #1, front

cage, bottom tier under the trailer shed outside.  The cages are

designed with 3 compartments/levels per coop and the floors

are comprised of green fiberglass material held to the cage

framework with rivets.  I immediately notified 

 of my observations and concern of the

welfare of the bird.  ., was also

notified.  used a bar to leverage between the floor and

framework which took pressure off the wing and allowed the

wing to be dislodged.  I evaluated the turkey and didn’t see that

the wing was broken or dislocated from the entrapment.  It did

have a superficial cut.  I placed a US Reject Tag No. B42252160

on the cage so it could be repaired.  The fiberglass floor was

inadequately riveted in place which allowed the wing to become

trapped.  This was previously discussed and documented in MOI

JEB0206055711I written on 5/11/17.  It was also discussed in

the establishment weekly meeting on 5/11/17. A discussion

was held with of my

observations and concern for animal welfare at 0710 hours.  

The establishment must employ humane methods of handling

and slaughtering consistent with Good Commercial Practices in

a way that minimizes injury to poultry.  Poultry are to be

handled in a manner that prevents needless injury and

suffering.  Employing humane methods of handling and

slaughtering that are consistent with good commercial practices

increase the likelihood of producing unadulterated product.

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

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 15

EstNbr EstName Task_Code MOI# Date Description

M3213

0

Dakota

Provisions LLC

04C05 JEB510905

2418G

2017-05-18 Est. 32130, Dakota Provisions, 05/18/17, 0530 hours.  Meeting

Attendance: 

 and On 05/18/17 at

approximately 0500 hours, while performing ante-mortem

inspection, I observed 

observing a bird on a trailer that had his right wing caught

between the framework and the fiberglass floor above him.  The

bird was discovered in trailer #31, front cage, bottom tier under

the trailer shed outside.  The cages are designed with 3

compartments/levels per coop and the floors are comprised of

green fiberglass material held to the cage framework with

rivets.  used a bar to leverage between the floor and

framework which took pressure off the wing and allowed the

wing to be dislodged.  I evaluated the turkey and didn’t see that

the wing was broken or dislocated from the entrapment, but the

wing was bruised.  I placed a US Reject Tag No. B42252164 on

the cage so it could be repaired.  At approximately 0600 hours,

the establishment had to free another bird with his wing

trapped on trailer #3.  Once dislodged, this bird had a small

laceration and was bleeding, but the wing did not appear

broken.  I placed US Reject Tag No. B42252163 on the cage to

follow up with the cage repair.  The fiberglass floors are

inadequately riveted in place which allowed the wings to

become trapped.  This was previously discussed in two other

instances which were documented in MOI JEB0206055711I

written on 5/11/17 and MOI JEB2207055216L written on

5/16/17.  It was also discussed in the establishment weekly

meeting on 5/11/17. A discussion was held with 

, of my observations and concern for animal

welfare at approximately 0530 hours.  instructed Quality

Control personnel in the live hang department to look at all

cages today and place hold tags on the cages needing repair.  All

cages will be repaired May 19th and 20th.  The establishment

must employ humane methods of handling and slaughtering

consistent with Good Commercial Practices in a way that

minimizes injury to poultry.  Poultry are to be handled in a

manner that prevents needless injury and suffering.  Employing

humane methods of handling and slaughtering that are

consistent with good commercial practices increase the

likelihood of producing unadulterated product.

(b) (6)

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

(b) (6)

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 17

EstNbr EstName Task_Code MOI# Date Description

picking room space, one cadaver carcass with a head attached

was on the shackle line.  Upon arrival to the picking room space,

one manual (est. employee) back-up cutter was present

covering both production lines.  Birds appeared unresponsive

between the stunner and back-up stunner system.  The

machine/manual cutter appeared to be performing on a

majority of carcasses through the line.  One bird missed the

manual cutter and was cut by the back-up cutter.  The previous

Good Commercial Practices (GCP) verification performed at

06:20am did not have any observed deviations between the

stunner to rehang table.   GCP of the slaughter process right

before and during the 09:25am evisceration event could not be

verified.         While walking back to the evisceration

department space, a second condemned barrel was observed

near the rehang space behind the rehang crew at the middle of

the rehang table space.  This barrel was observed to have two

carcasses with the head attached with the aforemented dark

purple/red coloration of the upper breast skin, wings and neck. 

One carcass was observed to be headless.  The multiple

locations of these cadaver carcass findings along the slaughter

process demonstrate loss of process control. No corrections

were made to the process as it was reported to USDA that the

cadaver events occurred around a grower/lot change.  In-house

documentation was cited for the est. personnel involved. USDA

personnel discussed with establishment management (

) when sporadic uncut cadaver

events occurred during slaughter production the 20th and 22nd

of June 2017.  Cadavers observed during production were

discussed during the 13th of June 2017 (MOI

CNC3110062314G), 11th of April 2017 (MOI

CNC0816044212G), and 14th of March 2017 (MOI

CNC1818033414G) weekly meeting.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 18

EstNbr EstName Task_Code MOI# Date Description

M322A Pilgrim's Pride

Corporation

04C05 CNC41050

72207G

2017-07-07 The purpose of this Memorandum of Interview is to document

the recent events regarding an increase in poorly bled carcasses

condemnable as cadavers at USDA inspection stands over the

past two production nights at P322/Pilgrim’s Pride, Corp., Cold

Spring Minnesota.   During night shift production the morning

of the 6th of July 2017, I made the following observations in the

evisceration production space upon alert by on-line USDA food

inspectors: During the 4:15 inspector relief break, I was told by

an inspector that she had condemned 3 cadavers within

approximately a one hour time frame on line 2 stand 1.  The

condemn barrels had been emptied before I got there however

so I could not verify those carcasses. While performing post

mortem inspection during that 10 minute break on line 2 stand

1, I condemned one carcass that had come through USDA

inspection demonstrating dark red to purple coloration of the

upper breast, back and wings and although the head had been

pulled off it also had neck skin removed exposing dark

red/purple tissues along the neck muscles. After performing

the second 10 minute inspector relief break on line 2 stand 2, I

went to line 2 stand 3 where the inspector had hung back two

cadavers. One of the carcasses had the head attached with no

neck cut.  The head was swollen and red/purple colored and

both had neck, breast, back and wings discolored dark

red/purple.  I retrieved two other cadavers with similar

appearance as above from the condemn barrel on line 1 stand 1

that an inspector notified me of. I set aside these 5 carcasses

(see photo) on the table in front of the quality office in evis. at

approximately 4:40 am and notified 

 who said he would inform 

  I saw and

showed her the cadavers and she said no one notified her and

that she would address it. I walked to the evisceration rehang

table and saw a cadaver in the white tote next to the rehang

table with a head on and no neck cut. The head was dark

red/purple in color and swollen and the neck, upper breast and

back and wings were dark red/purple.  At the end of the rehang

table in the catch bin there were no fewer than 15 dark purple

to red swollen cadaver heads (see photo). There was an

additional head on uncut cadaver in a condemn barrel located

near the right end of the rehang table as well. When I walked

through kill and pick at approximately 5:00am, there were very

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 19

EstNbr EstName Task_Code MOI# Date Description

few carcasses on the line and the birds on the line at that time

appeared unresponsive between the stunner and back-up

stunner system.  The machine neck cutter appeared to be

performing cuts on a majority of carcasses through the line. 

One bird missed the manual cutter and was cut by the back-up

cutter.  While in live receiving I noticed all of the blue hats at the

far end near where the trucks exit loading drawers manually

into mods. Good Commercial Practices (GCP) of the slaughter

process right before and during the 4:15am USDA inspector

relief breaks could not be verified.  The previous GCP verification

performed at 12:10am did not have any observed deviations

between the stunner to rehang table.  However, over the past

several weeks it has been noted that one manual (est.

employee) back-up cutter was present covering both production

lines, whereas it had previously always been two back-up

cutters.  During the night shift of July 7th I asked the line

inspectors to hang back all cadavers for me to verify.  From start

up to midnight there were only three cadavers condemned by

USDA that I collected and put in the condemn barrel.  Between

12 am and the lunch break at 2:04am, the line inspectors had

hung back a total of 10 cadavers.  Three cadavers were head on

without a neck cut. They had dark swollen heads and red/purple

discoloration to the head, neck, breast, back and wings. The

remaining 8 did not have heads but had the characteristic red

upper breast, back, and to varying degrees wings.  I set all

carcasses on the table outside of the Quality Office and notified

 and .  told me that he would notify

. Later, I spoke again with the 

 and he said that both employees that

were responsible for back up cutting had be counseled and that

they would be staffing the back up cutter with two cutters for

the rest of the shift on 7/7. He mentioned that employees at the

1st processing rehang table have been instructed to remove all

heads and that he will discuss with 

 regarding the procedure moving forward. 

These carcasses demonstrate poor bleed out in violation of the

requirements of 9CFR 381.65(b): “Poultry must be slaughtered

in accordance with good commercial practices in a manner that

will result in thorough bleeding of the carcasses...”.  The

carcasses demonstrated characteristics of uncut or inadequately

cut cadaver carcasses.  Additionally, pulling off cadaver heads at

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 20

EstNbr EstName Task_Code MOI# Date Description

rehang could be interpreted as establishment intending to

interfere with USDA line inspectors ability to identify and thus

condemn cadavers. discussed with

establishment management 

) when sporadic uncut cadaver events occurred during

slaughter production the 20th and 22nd of June 2017.  Cadavers

observed during production were discussed during the 13th of

June 2017 (MOI CNC3110062314G), 11th of April 2017 (MOI

CNC0816044212G), and 14th of March 2017 (MOI

CNC1818033414G) weekly meeting.

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 21

EstNbr EstName Task_Code MOI# Date Description

M4412

1

Pelleh Poultry

Corp.

04C05 000141603

1505G

2017-03-05 At establishment 44121P, Pelleh Poultry, a meeting was held

with at 15:00 to discuss good commercial

practices and mistreatment of poultry.  During ante mortem

and prior to the start of slaughter operations while unloading

the poultry crates from the receiving trailer many chickens were

observed dead on arrival, (DOA). Later in the day it was

determined that approximately 1,200 chickens had been

received DOA. During the MOI meeting with he stated that

the trailer had arrived at the establishment at around 04:38

A.M. The temperature outside was between 0 and 20 degrees

fahrenheit during time of transportation and receiving. We

determined that the chickens had froze to death with the

majority occurring during transport. The trailer of chickens was

protected with outside plastic or tarp, however it was

insufficient to prevent the deaths of the chicken during extreme

cold. The establishment does not have an inside protected truck

and trailer bay to hold live birds thus, the load is delivered

outside and left there prior to employees beginning work. I

determined that the chickens had been mistreated while they

are required to be handled in a manner that prevents needless

injury or suffering. Preventing mistreatment of poultry

decreases the production of adulterated carcasses. There is not

an ongoing trend of birds dying otherwise by slaughter at the

establishment and this appears to be a rare circumstance and

incident due to the severe cold. The establishment contacted

the flock owner, however I am unaware of the conversation that

took place. had no further comments to provide during the

MOI. The establishment may go to their individual documents

and add a response in the plant response text field or upload an

attachment if they have access to E Authentication, PHIS

account. I am not certain at the time if they have this access.

Secondly, the establishment may provide a written response to

this MOI in reguards to the mistreatment of poultry if they

decided to.

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 22

EstNbr EstName Task_Code MOI# Date Description

M4513

4

Birdsboro Kosher

Farms Corp.

04C05 000041601

2023G

2017-01-23 On 01/23/2017 at approximately 1200 hours, while 

 and I were performing Good Commercial Practice task in

receiving area, we observed about 12 cages on a truck being

held in the truck bay, were broken with a hole of 3-5 inches

which is enough for passing heads and wings of chickens and

expose them to injury. In the entrance meeting, we addressed

this issue with , and Mr. Urieta,

Plant Manager. We clarified that damaged cages are not in

accordance with Good Commercial Practice. The establishment

stated that they had already addressed it and are going to

implement a record keeping for monitoring of the cages.

M4513

4

Birdsboro Kosher

Farms Corp.

04C05 FKJ240809

4605G

2017-09-05 On 09/04/2017 at approximately 720 hours, I was walking

through the ante-mortem area and looked inside the DOA barrel

and found a slaughtered bird that wasn’t completely dead and

still aive. I stopped the line and informed Mr. Urieta, Plant

Manager and . The bird was

removed from the barrel and put in the area specified for that

situation until it died and stopped moving, and then was moved

to DOA barrel.  It is not consistent with Good Commercial

Practices to have live birds in a situation where they could be

smothered by dead birds. Under the Poultry Products

Inspection Act (PPIA) and Agency requirements, live poultry

must be handled in a manner that is consistent with good

commercial practices, which means they should be treated

humanely. 

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 23

EstNbr EstName Task_Code MOI# Date Description

M56 PILGRIMS PRIDE

CORPORATION

04C05 MBJ06120

20902G

2017-02-02 On 2/2/17 at around 6:55am I, , was performing

Good Commercial Practices. In live hang, I observed a large pile

of DOAs (about 20-25 birds) at the end of the live hang belt. I

immediately began to sift through the pile and found a live bird

at the very bottom. The bird’s left leg was splayed so it was not

able to move itself. On the other side of the pile, I found another

live bird buried under several birds. I removed both live birds

from the pile. I observed as a live hang employee picked up a

few birds before returning to the line, and then a floor man

picked up all of the DOAs. Shortly after, I spoke to 

)

 and )

about my findings and how live birds buried underneath DOAs

was unacceptable. informed me that he would talk

to live hang personnel about picking up DOAs in a timely

manner. I informed that my findings would be

documented. My findings are not in keeping with Good

Commercial Practices. Measures should always be taken to

ensure that poultry are handled and kept in conditions that will

not result in death or injury unnecessarily. In addition,

“employing humane methods of handling and slaughtering that

are consistent with good commercial practices increases the

likelihood of producing unadulterated product”. Establishment

P56 is hereby advised to address the above observations and

take preventative measures to reduce the likelihood of

occurrence. 

(b) (6)

 Cc’d 

(b) (6)

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

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 24

EstNbr EstName Task_Code MOI# Date Description

M56 PILGRIMS PRIDE

CORPORATION

04C05 MBJ09090

51224G

2017-05-24 On 5/23/17 at around 1:50pm I, , was in live

hang performing Good Commercial Practices. I noticed there to

be a pile of about 10 DOAs at the end of the conveyor belt. The

pile was moving up and down in a rhythmic pattern at the top

right corner. I found there to be a live bird underneath a DOA

and, wedged between 2 DOAs and a wall of chicken

feathers/dirt. Upon my uncovering the live bird, the bird began

to gasp for air. I was attempting to remove the bird out of the

way of falling DOAs when 

appeared. I informed him of my findings and

brought his attention to the live bird. said he would

immediately pick up the DOAs and I observed him do so. He put

the live bird back on the belt. At the weekly meeting at 2:15pm

I informed management of my findings. I explained that warmer

temperatures meant that DOAs would be presenting more

frequently and that the establishment was responsible for

making the necessary provisions to keep up with the increase.

Lastly, I emphasized that it was not acceptable for live birds to

be buried under DOAs. My findings are not in keeping with

Good Commercial Practices. Measures should always be taken

to ensure that poultry are handled and kept in conditions that

will not result in death or injury unnecessarily. In addition,

“employing humane methods of handling and slaughtering that

are consistent with good commercial practices increases the

likelihood of producing unadulterated product”. Establishment

P56 is hereby advised to address the above observations and

take preventative measures to reduce the likelihood of

occurrence. 

(b) (6)

 Cc’d 

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

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 26

EstNbr EstName Task_Code MOI# Date Description

M5842 Tyson Foods,

Inc.

04C05 NPF14120

11618G

2017-01-18 TO:  Matt Evans, Plant Manager, Est. 5842P, Tyson Foods Berry

Street Plant, Springdale AR. Subject:  Issues with Good

Commercial Practices on the 18th of January 2017. On

Wednesday January 18th, 2017 while on our way to give

inspector breaks on the evisceration lines at approximately

0730 hours, I observed in the area between the backup venter

station and the venter machine,  1 carcass hanging on a grey

evisceration line shackle moving down the line with the neck

having no apparent  cut and the head still attached.  The carcass

was not bled out at all, was bright red in color, and appeared to

have died of other means than the normal slaughter process. 

This was shown to at the

time of the observation by who was present at

the time of the observation and the carcass was condemned.  

 informed of the issues and

informed him that IPP would be documenting an MOI.  

 performed follow up observations of the killing process

and no further issues were observed and it was assumed by

 that it was an isolated incident and there was no

loss of process control.  The issue was conveyed to 

 as well as 

at approximately 1200 hours on the 18th of January

2017.  Est. 5842P Springdale, AR

M5842 Tyson Foods,

Inc.

04C05 NPF20230

35314G

2017-03-14 Subject:  Issues with Good Commercial Practices. On Tuesday

March 14, 2017 while providing breaks to the Food Inspectors

at approximately 2145 hours, I observed one of the carcasses

presented for inspection at Post Morten inspection station 3

evisceration line 2, with the neck intact, having no apparent cut

and the head still attached.  The carcass was not bled out and

was bright red in color, and appeared to have died of other

means than the normal slaughter process. This carcass was

removed from the line and shown to 

 and 

  and I 

informed that IPP would be

documenting an MOI. At 22:20 hours,  performed

follow up observations of the killing process and no further

issues were observed, it appeared that it was an isolated

incident and there was no loss of process control.  

(b) (6)

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

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

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

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 27

EstNbr EstName Task_Code MOI# Date Description

M5842 Tyson Foods,

Inc.

04C05 NPF41060

42603G

2017-04-03 TO:  Hunter Wray, Plant Manager, Est. 5842P, Tyson Foods

Berry Street Plant, Springdale AR. Subject:  Issues with Good

Commercial Practices on the 3rd of April, 2017. 

On Monday, April 3rd,, 2017 while on our way to give inspector

breaks on the evisceration lines at approximately 0600

hours,  and 

observed in the area between the backup venter station

and the venter machine,  1 carcass lying on the floor next to a

yellow condemned barrel having no apparent  cut and the head

still attached.  The carcass was not bled out at all, was bright red

in color, and appeared to have died of other means than the

normal slaughter process.  This was shown to 

 at the time of the observation by 

   The carcass was taken by to show to the

responsible parties to insure no further issues would arise and

then condemned by 

informed   of the issues and informed him that IPP

would be documenting an MOI.  performed follow

up observations of the killing process and no further issues were

observed and it was assumed by that it was an

isolated incident and there was no loss of process control.  The

issue was conveyed to at

approximately 0700 hours on the 3rd of April 2017.  

 Est. 5842P Springdale, AR

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

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 28

EstNbr EstName Task_Code MOI# Date Description

M5842 Tyson Foods,

Inc.

04C05 NPF38000

40208G

2017-04-08 Subject:  Issues with Good Commercial Practices. On Friday

April 7, 2017, while providing breaks to the Food Inspectors at

approximately 1605 hours, I observed one of the carcasses

presented for inspection at Post Morten inspection station

1, evisceration line 2, with the neck intact, having no apparent

cut and the head still attached.  The carcass was not bled out

and was bright red in color, and appeared to have died of other

means than the normal slaughter process. Also at the same

station three DOA carcasses were presented to me for

inspection, the carcasses were purplish in color the viscera

appeared congested. The carcasses and viscera were exhibit

signs of decomposition (visceral organs, carcass discoloration

and condition odor).  These carcasses were removed from the

evisceration line 2. Another DOA carcass was presented for

inspection at Evisceration line 1, station 2, and was removed by

. All the carcasses were shown to

 and 

.  After discussing this observation with

management. I and elected to

observed production at rehang area, 5 more DOA carcasses

were observed in the condemned barrels. These carcasses were

also shown to management. was present

went I informed 

that all the DOA carcasses should be condemned at

ante-mortem inspection and not brought into the slaughter

process. He was also informed of my intentions of documenting

an MOI . At 1700 hours, I performed follow up

observations of the killing process and no further issues were

observed.  

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 29

EstNbr EstName Task_Code MOI# Date Description

M5842 Tyson Foods,

Inc.

04C05 NPF46080

74307G

2017-07-07 TO:  Hunter Wray, Plant Manager, Est. 5842P, Tyson Foods

Berry Street Plant, Springdale AR. Subject:  Issues with Good

Commercial Practices on the 7th of July, 2017. On Friday, July

7th,, 2017 while giving inspection relief breaks on Evisceration

Line #1at inspection station #2, at approximately 0749 hours,

 observed  1 carcass presented for post mortem

inspection having no apparent  cut and the head still attached. 

The carcass was not bled out at all, was bright red in color, and

appeared to have died of other means than the normal

slaughter process.  This was shown to 

at the time of the observation by  .   The

carcass was presented to at approximately

0800 hours who verified that the bird had died from other

means than slaughter.    informed 

of the issues and informed him that IPP would be

documenting an MOI.  performed follow up

observations of the killing process and no further issues were

observed and it was assumed by that it was an

isolated incident and there was no loss of process control.  The

issue was conveyed to at

approximately 0830 hours on the 7th of July 2017.  

 Est. 5842P Springdale, AR

(b) (6)

(b) (6)

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

(b) (6)

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

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 31

EstNbr EstName Task_Code MOI# Date Description

Evisceration GPM on Saturday 7/8/2017 from 1105 to 1111

concerning this GCP poultry mistreatment incident: 

met with the establishment evisceration GPM on shift 1 in the

SPHV’s office from 1105 to 1111 on Saturday 7/8/2017.  During

this meeting described his observations concerning

this incident as outlined above told the

establishment evisceration GPM at this meeting that due to the

results of the 3 follow up checks on 7/8/2017 performed from

1034 to 1102 the 1 live bird he’d observed and removed from

kill line 2 at 1014 before it entered the first scald tank during

the GCP check that day was deemed by IPP to be an isolated

incident and not a loss of plant killing process control. Thus IPP

will issue this Poultry Mistreatment MOI in lieu of a GCP NR

concerning this incident as per guidance in FSIS Notice 44-16

dated 6/27/2016. The last time a live bird was removed from

one of the 2 plant the kill lines immediately before that bird

entered the first scald tank during a GCP station 1 check

performed by IPP at Est M5842 was on 7/25/2016 and is

documented on Poultry Good Commercial Practices MOI

NPF0007071526I.

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 32

EstNbr EstName Task_Code MOI# Date Description

M5842 Tyson Foods,

Inc.

04C05 NPF19100

73514G

2017-07-14 GCP MOI Day, Date and Time of Meeting:  Wednesday

7/5/2017 from approximately 0604 to 0608 Place Meeting

Held:  Est. M5842 Live Hang Room  Persons Attending: FSIS

Attendees – . Tyson Foods Attendees – Joel

Ferguson, APM; of shift

1.   Author(s) of this Meeting Report:    Date this

Meeting Report was Written:  Saturday 7/8/2017 & Friday

7/14/2017. Subject: GCP Poultry Mistreatment MOI. 

Background: On Wednesday 7/5/2017 at approximately 0600

one of the CSIs on our in-plant inspection team told 

that the kill line 2 live hang belt or live in the plant live

hang room had stopped due malfunction and as a result live

young chickens were allowed to had pile up on this belt

resulting in birds on the bottom of the belt dying by

suffocation.  then proceeded to the Live Hang room

to perform the good commercial practices PHIS task for that

shift from 0604 to 0608. Upon arrival in the Live Hang room

 observed plant personnel pushing dead young

chickens on the surface of this kill line 2 live hang belt to the

south end of the belt then onto a pile of dead young chickens

located on the floor adjacent to the west end of this belt. This

pile of smothered carcasses was approximately 7’ long, up to 5’

wide and up to 4’ high. The day shift APM and Live Hang

supervisor were already on the scene when arrived

in the live hang room. The Following was Discussed at the

Subsequent Meeting Concerning this Issue: asked

the plant APM what had occurred then asked the APM how

many birds died of suffocation due to this belt malfunction and

subsequent piling up of live birds one upon another. The APM

told that plant personnel would count the number

of birds that had died from suffocation then give him this

information later. then told the APM that he would

write a GCP MOI or NR to document this incident based on the

advice of the DVS and left the live hang area at approximately

0610. Subsequently the plant told that

approximately 200 live birds had suffocated during this incident.

 contacted the DVS about this incident and the DVS

recommended that a GCP MOI be written. 

Assigned to Est. M5842 CC:          , Joel Ferguson,

(b) (6) (b) (6) (b) (6) (b) (6)(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 33

EstNbr EstName Task_Code MOI# Date Description

M5842 Tyson Foods,

Inc.

04C05 NPF26110

80011G

2017-08-11 On Friday August 11th, 2017 while performing Operational

Sanitation Inspection in the area of the rehangers for lines #1

and #2 at approximately 1105 hours,  I observed a carcass being

conveyed on the belt which appeared to be a cadaver.    The

carcass was not bled out at all, was bright red in color, and

appeared to have died of other means than the normal

slaughter process.  Upon removing the carcass from the

rehanger belt for evisceration line #1, I observed that the head

was still attached and there was no cut present anywhere on

the carcass that would have shown that it would have been

killed by the normal slaughter process.  This carcass was shown

to  at the time of the

observation.  The carcass was then presented to 

 whom also confirmed that the carcass had been

killed from other means than the normal slaughter process.

M5842 Tyson Foods,

Inc.

04C05 NPF19080

95712G

2017-09-12 On Monday September 11th 2017, I was informed by the line

inspector on evisceration line #1 station #3 that he had found a

carcass with the head still attached and no cut in the neck or

head.  I observed the carcass on the inspectors PM evaluation

hook for and observed that it was a carcass that had died from

other means than the normal slaughter process.  The carcass

was also taken to who also verified this as a

carcass that died from other means than the normal slaughter

process.   This carcass was shown to 

 at the time of the observation who agreed with

the determination by IPP.

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 34

EstNbr EstName Task_Code MOI# Date Description

M6137 Foster Farms 04C05 BXL210101

4510G

2017-01-10 At establishment P-6137 on 01/09/2017, I and

 found the following: At approximately 0145

hours, while performing Poultry Good Commercial Practices

Task, we were observing the birds after the stunner (line ) for

stunning effectiveness. Several birds were blinking their eyes

and/or lifting their heads showing that they were not properly

stunned before they entered the kill machine. This is an

indication that the birds are still awake. 

 showed up and informed him about the

issue and instructed him to immediately stop hanging live birds

on  Line . informed us that it was almost

time for lunch break and the maintenance personnel was going

to look into it and after this period the line will be ready for a

recheck. At approximately 0241 hours, the line started and we

observed six birds blinking their eyes and/or lifting their heads

in less than 30 seconds. instructed 

 to immediately stop hanging live birds. Maintenance

worked on the Stunner again and at approximately 0305 hours

the line resumed again and failed. At approximately 0315 hours

and 0325 hours, I performed rechecks. Both of the rechecks

failed, the first recheck had 15 birds that were not properly

stunned and the second had 7 birds not properly stunned. This

exceeds the limit of five birds that the Establishment allows on a

five hundred bird sample. At approximately 0340 hours, after a

passing recheck, the line was released. We informed 

 that an MOI will be documented.

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

(b) (6)

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

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

(b) (4) (b) (4)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 36

EstNbr EstName Task_Code MOI# Date Description

M737 House of

Raeford -

Wallace Div

04C05 DHA22030

20914G

2017-02-14 P737 House of Raeford-Wallace Division, 2/14/17 at

approximately 0300. In attendance: 

.  While

performing a Good Commercial Practices task shortly before

0300, I observed a live bird in the DOA bin.  This DOA bin is a

forklift front end loader attachment, one flat end flush with the

ground with a deeper opposite end. The DOA bin was half full

and the bird was located near one of the deep corners. It was

crouched down on top of dead birds with numerous dead birds

around it and behind it at the low edge of the bin.  The bird was

very quiet, but alert and alive.  It did not have any denaturant

on it.  Other nearby dead birds did have denaturant on them.

 Due to its location in the bin and amount of dead birds around

it, the bird had not walked into the bin on its own.    I did not

see any other live birds in the DOA bin.  

 was immediately notified.  She observed

the bird in the bin and then the bird was pulled out and was

active while held, and stood quietly when placed on the ground.

  Given the bird’s location in the DOA bin, the next barrel of

DOAs from live hang would have been dumped on top of this

live bird.  The bird in question would then have suffocated and

died by means other than slaughter.  It is the establishment’s

responsibility to ensure that birds are slaughtered in accordance

with 9 CFR 381.65(b).  I informed that this finding

of a live bird in the DOA bin was improper handling and would

result in a MOI.  The bird appeared healthy and with no

presence of denaturant on the bird, I approved it to go on to

slaughter.    told me that the establishment

employees would receive retraining on proper good commercial

practices, and she would further investigate how this bird ended

up in the DOA bin. This MOI will be forwarded to the District

Office and the District Veterinary Medicine Specialist (DVMS) in

case additional follow up is recommended. If you have any

questions or concerns regarding this MOI, please feel free to

contact myself or . 

Respectfully, 

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 37

EstNbr EstName Task_Code MOI# Date Description

M7478 Tyson Foods,

Inc.

04C05 LDB300809

0218G

2017-09-18 On 9/14/17, at approximately 13:15 hours while performing a

Good Commercial Practices check, I observed 2 birds with

shallow cuts proceeding down line to enter the scalder. 

When I initially saw the first bird, I noticed that its eyes were

wide open and it was trying to hold its head up while still

hanging on the line.  I did see a cut on the neck, however there

was no active and steady bleeding coming from the area of the

cut.  I immediately notified of

my findings and proceeded to the area of the scalders to see if

the bird would expire prior to entering the scalder.  There we

observed the bird go through the head puller located just at the

entrance to the scalder and the head was removed causing the

bird to flap its wings and jerk its entire body excessively as it

went into the scalder.  We then returned to line to check to

see if there were any more conscious and breathing birds and

we observed another bird that was shallowly cut proceeding

down the line.  At this time, proceeded to remove the

bird from the line and address the findings with the back-up

cutter on that line.  I then proceeded to check the conditions of

the other two lines which appeared to be acceptable and

returned to line to verify whether or not the conditions had

improved and that was when I observed 2 alert and uncut birds

with their eyes open going down the line.  Both birds were

removed from the line and I informed 

and , of the

noncompliance with 9CFR 381.65(b).  Management removed

the back-up cutter from the line and placed a new team

member in that position and informed me that he was

counseled on his job performance yesterday for a similar finding

and that they would address this noncompliance with the team

member accordingly. FSIS considers one source for Good

Commercial Practices to be the National Chicken Council

Guidelines.  My observations are not consistent with guidance in

the National Chicken Council Animal Welfare Guidelines: F.

Processing Operations, section 13) Stunning & Slaughter:  "d) 

There must be backup personnel after the automatic knife to

induce bleed-out in any birds not effectively killed by the

equipment. Backup personnel must have sufficient room and

lighting to ensure that the blood vessels are cut on 100% of the

birds." A copy of this Memorandum of Interview will be

forwarded to appropriate personnel in the District Office.

(b) (6)

(b) (6) (b) (6)(b) (4) (b) (4 (b) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 38

EstNbr EstName Task_Code MOI# Date Description

M751 Norbest, LLC

(Moroni)

04C05 MMK1315

033620G

2017-03-20 Memorandum of Interview to Discuss Birds Held Over for

Slaughter Norbest Turkey / Est# P01049 Meeting Time:

Monday, March 20, 2017 at 1025 Attendees: 

USDA                                                             Establishment 

                      

 This meeting was necessitated by an observation

made in the bird holding area while performing a Good

Commercial Practices task on Saturday, March 18. On

Saturday, the establishment held over birds on trailer #81 for

slaughter this morning.  After slaughter ended on Saturday

afternoon, I verified the trailer was parked in the holding area, a

roofed structure on site.  The same trailer was observed on

Sunday.  This morning, the trailer was the first one emptied, and

the birds entered the plant for slaughter.  According to the flock

processing schedule from Saturday, the birds arrived here

Saturday morning at 0120.  They were finally slaughtered this

morning beginning at 0600.  As a result of the hold over, the

flock had remained on site in coops on the trailer for a period of

53 hours.  After receiving instructions from agency leadership,

I met with , to notify him

personally of my observations.  will investigate the

matter further. 

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

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 39

EstNbr EstName Task_Code MOI# Date Description

M751 Norbest, LLC

(Moroni)

04C05 MMK0409

040306G

2017-04-06 Est. P1049, Norbest LLC. (Moroni ), April 5, 2017, 1015 hours. In

attendance:

 and

 At approximately 1522 hours, on April 4, 2017, I,

, while performing the good commercial

practices task, observed the following incident. I observed 5

turkeys that had escaped in the hanging bay. 2 went outside the

bay, 2 moved a short distance from the trailer and 1 was under

the trailer. When the driver moved the trailer forward so that

the last few cages on the trailer could be unloaded the bird

under the trailer was crushed to death. Death by crushing is not

an acceptable GCP or a humane way to euthanize anything. I did

not observe anyone monitoring the area so that this would not

occur. I told and that the PPIA and Agency

regulations reguire poultry be handled in a manner that is

consistent with good commercial practices (GCP’s) and that they

not die from causes other than slaughter. I stressed to them the

importance of adherence to the GCP’s, especially because of the

issues and possible repercussions if there is continued

recurrence of this. I recommended management review the

Federal Register on Treatment of Live Poultry Before Slaughter,

published September 2005, for FSIS recommendations

concerning treatment of live poultry before slaughter. I provided

them a copy of this document. They were informed that this

MOI would be forwarded to District Office (DDM, Dr. Robert

Reeder) and the and ) in case

additional follow-up is recommended. stated that he

had plenty of help in the hanging bay area and that they would

be instructed to observe and prevent escaped turkeys from

being run over by the transport vehicle. Respectfully 

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

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

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 40

EstNbr EstName Task_Code MOI# Date Description

M751 Norbest, LLC

(Moroni)

04C05 MMK3514

081102G

2017-08-02 At approximately 1015 hours I was notified by 

 that there were several birds (Toms) being noted

with broken hocks. I immediately went out to the live hang bay

to review Good Commercial Practices. I observed that the

hangers were performing their duties as expected. I did not

notice anything out of the ordinary except that the birds

seemed more agitated than I normally notice them to be. I also

noticed that about one in five birds were vomiting on the line.

Typically I notice about one in twenty five vomiting. I alerted

 and to the items noted

above. Considering that the lunch hour was 1100 to 1200 they

agreed to look into it and review the procedures during

production after lunch. Upon returning from lunch break, I

returned to the live hang bay. I noted that they had closed the

doors on one side of the hanging bay as well as the man door on

the opposite side of the bay. received notification from

 that he had also taken the time to observe the

hangers out in the hanging bay and had noted that the birds

seemed more flighty than normal himself. He had asked for the

doors to be closed (as had been noted) and agreed to continue

to keep an eye on things. I also told him that I would be

continuing to keep an eye on the situation and would report

any further findings to him for action.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 41

EstNbr EstName Task_Code MOI# Date Description

M7559 David Elliot

Poultry Farm

Inc.

04C05 SNA08070

61615G

2017-06-15 On June 14, 2017 at 1100hrs, a meeting was held with

management; 

 and . The purpose of this meeting was

to discuss the large number of dead on arrival (DOA) chicken

carcasses that occurred at this establishment on June 13, 2017.

There were approximately 1,337 DOA carcasses out of the

 broiler chickens intended for slaughter on this day.

During the meeting management discussed the factors they

believed may have led to the large number of DOAs- including,

but not limited to- the high temperature and humidity

(weather) and the density to which the birds were loaded into

the crates for transport. In light of this event, management

intends to take additional planned corrective measures,

including proactively coordinating with the hauler that

transports the birds when warmer outside temperatures are

anticipated, to decrease the density/number of birds placed in

each crate and thereby increasing air flow/cooling.

Management also discussed the possibility of changing the

location of the trucks after they arrive at the establishment from

the farm (inside vs. outside) prior to production starting the

following day or changing the times the trucks are loaded. IPP

reminded management of their responsibility to ensure that live

poultry are handled in a manner consistent with good

commercial practices (GCPs) and that they do not die from

causes other than slaughter per Agency regulations and the

Poultry Products Inspection Action (PPIA). Management was

also advised that in accordance with FSIS Notice 44-16 and as

previously discussed, lack of adherence to GCPs could

potentially result in a noncompliance record (NR). Management

was notified that this MOI will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case any additional follow-up is recommended.

(b) (6)

(b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 42

EstNbr EstName Task_Code MOI# Date Description

M7559 David Elliot

Poultry Farm

Inc.

04C05 SNA12110

94211G

2017-09-11 A meeting was held at 1515hrs, on September 11, 2017, with

establishment management;

, and .  The

purpose of the meeting was to further discuss the incident that

occurred on Friday, September 8th involving live chickens in a

barrel with other dead chickens. At approximately 9:45am in

the corner of the kill floor/hanging area, adjacent to the crate

washer, there were two, largely full barrels,-each containing an

estimated 45-50 chicken carcasses of dead-on-arrival (DOA)

chickens unloaded from the crates on the truck. Next to these

barrels were approximately 3 to 4 crates, each containing 2-3

chickens each. Based on past observations, it is not uncommon

for a few DOAs to be left in the loading crates that are emptied

later into the barrel designated to hold dead chickens, or

occasionally when there is a question as to whether or not a

chicken is dead/DOA. While in the hanging area performing a

Good Commercial Practices verification task, I observed a live

chicken in one of these barrels, as evidenced by observable

rhythmic respiratory effort and minimal movement. This

particular bird did not receive any cut to bleed out.  At that

time, I notified Natan Fink, Plant Manager, and showed him the

live bird in the full barrel of dead chicken carcasses.  While then

locating the Slaughter Foreman, several employees were

witnessed removing the chickens from the crates adjacent to

the dead barrels and placing these additional chickens into the

barrels. Upon further examination, not all of these chickens

removed from the crates and placed into the container

designated for dead chickens, were actually dead. Several of

these chickens were in a debilitated/weakened state- but still

alive (as evidenced by observable rhythmic respiratory effort

and movement), were placed on top of one another into the

barrel containing dead chickens/chicken carcasses. (Note: The

establishment was in the process of changing over from

slaughtering broilers to cornish, and that is presumably the

reason the establishment employees were trying to clear and

empty the loading crates of broilers. ) After notifying the

Slaughter Foreman, the birds were removed from the dead

barrel, their throats were cut (per usual practice) and they bled

out separately in the containers used for miscut birds to bleed

out, before transferring them to the dead barrel.  IPP

reminded management of their responsibility to ensure that live

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 43

EstNbr EstName Task_Code MOI# Date Description

poultry are handled in a manner consistent with good

commercial practices (GCPs), including handling poultry in a

manner that prevents needless injury and suffering, per Agency

regulations and the Poultry Products Inspection Action (PPIA).

There should not be any instance where dead poultry carcasses

are placed with/upon live poultry, or a live poultry put in

container with other dead poultry- this includes the use of the

“intermediate barrel” (a term used to designate an intermediate

step, primarily for miscut birds- birds that are no longer

considered Kosher and will be removed from the process and

not presented for inspection- to verify that these birds are dead

prior to placing them in the barrel with other dead chicken

carcasses).  Though several factors may have contributed to this

occurrence- new employees (lack of training), the

pandemonium surrounding the time in switching from broilers

to corners- along with the general fast pace maintained in this

area, IPP recommended establishment management put

measures in place to prevent recurrence in keeping with

adhering to good commercial practices. Several items for

potential implementation were discussed, including increased

oversight/monitoring of all containers holding chicken carcasses

in the unloading/hanging area, additional employee training,

and a standardized euthanasia program (cervical dislocation) for

chickens that are not fit for Kosher standards (ex. injured,

weak/debilitated, and/or immobile) and will not be ritually

slaughtered and presented for inspection. IPP will follow up with

the establishment on any plans or implemented practice

changes regarding this issue. Management was notified that

this MOI will be forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case any additional

follow-up is recommended.
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 44

EstNbr EstName Task_Code MOI# Date Description

M757 The Hillshire

Brands Company

04C05 PYJ071209

3920G

2017-09-20 While performing good commercial practices task at

approximately 0650 on Wednesday, September 20, 2017, I

observed a live bird flapping its wings, breathing, and trying to

right itself along the last quarter of the serpentine belt before

the birds enter the scalder. I notified 

, who stopped the line prior to the bird

entering the scalder. The neck had been slit but the bird was still

breathing. The backup neck slitter re-cut the neck, and

approximately 15 seconds later the bird ceased breathing. The

line was restarted. A supervisor stayed to monitor the birds

going into the scalder. During observation for the next

approximately 15 minutes, the line was stopped three more

times to allow a conscious bird to fully bleed out and cease

breathing. In conversation with 

 when the CO2 stunner has issues and birds need to be

live hung, a supervisor is out monitoring live hang. He expressed

that in this situation they would also need to station someone

to make sure no live birds enter the scalder, and/or change line

speeds to allow more time for the birds to fully bleed out. 

There had been issues with CO2 stunner fully stunning one

section of the trucks, but maintenance informed me that they

had fixed the issue at 0715, and birds were no longer being live

hung. Observation after that showed no birds still breathing at

the end of the serpentine. I saw no cadaver birds in the

condemn barrels or listed on the sorter sheets in the

evisceration department. I informed 

 of the situation and that it seemed to have

been handled properly. He will inform the offsite animal welfare

specialist of the situation in case adjustments to protocol need

to be initiated.

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 45

EstNbr EstName Task_Code MOI# Date Description

M9977 Tyson Foods Inc. 04C05 YBL460901

1014G

2017-01-14 The first lot slaughtered on 1st shift 1/13/17, Lot 21 (holdovers),

had 742 DOAs out of head,  or DOA's.    It was

heavily afflicted with air sacculitis.  The house was begun the

previous day, 1/12/17, on 2nd shift (Lot 1B) and the incidence

of DOA's was only 0.18%.   While the high mortality can be

attributed to the severe air sacculitis pathology, holding these

birds overnight greatly increased the mortality from 0.18% on

Thursday night to 12.5%  on Friday morning.   For the entire 1st

shift of 1/13/17, there were 1.46% DOAs, which still exceeds the

norm. It is a good management practice to avoid holding sick

birds overnight for slaughter the next day.   The establishment

should take these factors into consideration when managing its

slaughter operations.

(b) (4) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 46

EstNbr EstName Task_Code MOI# Date Description

M9977 Tyson Foods Inc. 04C05 YBL131604

4501G

2017-04-01 On 3/30/17 at approximately 1351 hours, while conducting a

routine Poultry Good Commercial Practice Task in live receiving,

the following was observed.  I was standing on the dumper

stand next to the dumper-operator while he was actively

operating the dumper.  When the dumper-operator

mechanically removed a cage away from the dumper to be

taken away to the transportation trucks, I observed that one

half of the cage doors (the entire left half of the cage doors

when observing the cage with the cage doors facing the

observer) had not opened at all and that this half of the cage

was still full of live chickens.  The dumper-operator mechanically

opened the doors.  He then mechanically moved the cage with

the doors still open against the dumper, which did not align

properly against the dumper.  Immediately, the

dumper-operator mechanically moved the cage away from the

dumper again with the cage doors still open.  I observed several

live chickens standing at the edge of cage at the location of the

hinge where the cage edge and door edge connect, as well as on

the inside aspect of the cage doors.  At this point, the

dumper-operator closed the doors on the live chickens, resulting

in several body parts of live chickens being stuck between the

edge of the cage doors and the cage itself.  I observed

approximately two live chickens with their necks stuck between

a door edge and the cage, approximately one live chicken with

its neck and its wing stuck between a door edge and the cage,

and approximately one live chicken with its wing stuck between

a door edge and the cage.  

and were immediately notified of the

situation.  assumed control of operations,

mechanically opened the cage doors, manually released the

stuck chickens back into their cages, and dumped the cage onto

the conveyer belt.  I informed him that the District Office would

be made aware of the situation.  informed me that the

dumper-operator should have gently pushed the live chickens

completely back into the cage before closing the doors.  He also

informed me that the dumper-operator had been taken to

Human Resources.  Live bird body parts getting stuck in

equipment from operator error is not consistent with good

commercial practices.  Under the Poultry Products Inspection

Act (PPIA) and Agency requirements, live poultry must be

handled in a manner that is consistent with good commercial

(b) (6) (b) (6)(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 47

EstNbr EstName Task_Code MOI# Date Description

practices, which means they should be treated humanely. 

Please indicate what permanent preventive measures will be put

into place to prevent this from reoccurring. Respectfully, 

M9977 Tyson Foods Inc. 04C05 YBL001105

5618G

2017-05-18 At approximately 1050 hours in the evisceration department of

Est. P1325, I observed the Line line leader person holding

two cadavers that had been removed from the line.    One

cadaver was a deep red color throughout the carcass and its

neck was completely uncut with the head still attached and

engorged with blood.   The 2nd cadaver had the head removed

but was uniformly red in color indicating it had not been bled

out.   The cadavers were shown and given to the ,

 by the line leader who took them back to

the kill area to show the responsible person.     The back-up kill

person failed to manually cut the necks to permit the required

bleed out.  No other cadavers were observed at the time,

indicating the process was still under control.    Poultry are to be

slaughtered in a manner that ensures that breathing has

stopped before scalding, so that the birds do not drown, and

that slaughter results in thorough bleeding of the poultry

carcass (9 CFR 381.65(b)).   Live poultry must be treated in a

manner consistent with good commercial practices. At

approximately, 1145 hours, 

retained a carcass for my examination.   I confirmed it was a

Dead On Arrival (D.O.A.) as it had a foul odor of decomposition

with congested, friable viscera engorged with dark red blood,

and large dark red patches in the breast muscle.    I showed the

D.O.A. to who took it back to the

slaughter area to dispose of it, and when 

arrived I notified him as well.  At 1300 hours, 

 retained another bird that had the

characteristic lesions of a D.O.A. as well.   I showed it to 

.   DOA carcasses are to be condemned at

ante-mortem inspection and should not be dressed or conveyed

into any department of the official establishment where poultry

products are prepared or held (9 CFR 381.71).

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

(b) (6)

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

(b) (6)

(b) (6) (b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 48

EstNbr EstName Task_Code MOI# Date Description

M9977 Tyson Foods Inc. 04C05 YBL061605

2826G

2017-05-26 On 5/26/17 at approximately 1441 hours while performing a

routine Good Commercial Practices Verification task, I was

watching establishment employees shackling live poultry in the

live hang area when I observed an establishment employee

retrieve a live, loose chicken located in a metal offal bin

positioned to the left of the end of the conveyer belt, outside of

the fenced in area.  I informed 

of my observation. Instances of live, loose chickens in the live

hang area have been previously observed, discussed, and

documented in Memorandum of Interviews (MOIs) from routine

weekly meetings with establishment management: From MOI

YBL0920055317G On 5/10/17 at approximately 1339 hours

while conducting antemortem/GCP in the live hang area two

live chickens fell from the conveyer belt onto the floor within

one minute of each other.  I informed 

 that process control needed to be maintained at all

times. On 5/12/17 at approximately 1351 hours in the live

hang area I noticed two instances of live birds at the end of the

conveyer belt, where the hanger controls the belt speed with a

knee pedal, jump over the metal barrier and into the offal bin. 

 and 

 were informed. From MOI YBL2716054324G 

On 5/18/17 at approximately 1342 hours while performing

antemortem and good commercial practices in the live hang

area I noticed one live bird jump from the moving conveyer belt

at the left most end in front of the conveyer belt operator/live

hanger over the left metal barrier and land under the Dead

Upon Arrival (DOA) table (where moribund birds and DOAs are

placed before being humanely euthanized and placed in the

DOA bin) OUTSIDE of the fenced in area.  No management was

present and the hanger buzzed.  When arrived I

informed him of the situation.  Less than one minute later one

live bird landed from the conveyer onto the floor within the

fenced in area and was promptly retrieved.  notified

afterward.  Loose live birds also noted within live hang area on

5/10/17 and 5/12/17. On 5/19/17 at approximately 1340

hours while performing a routine antemortem/GCP task in live

hang I noticed one live bird jump from the conveyer belt onto

the floor within the fenced in area and was promptly retrieved. 

 notified.  Loose live birds also noted in live hang area on

5/18/17, 5/12/17, and 5/10/17. To be documented in the next

(b) (6)

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 49

EstNbr EstName Task_Code MOI# Date Description

weekly meeting with establishment management MOI: On

5/25/17 at approximately 1424 hours in live hang area during

antemortem/good commercial practice inspection I observed

 pick up a live, loose bird outside of the fenced in area to

the left of the left-most hanger.  Loose live birds also noted in

live hang area on 5/19/17, 5/18/17, 5/12/17, and 5/10/17. 

Brian Tietjens notified. Repeatedly allowing live chickens to fall

and/or jump from the waist-level conveyer belt onto the floor

and floor-level areas in the live hang area can result in injury to

live chickens and is not consistent with good commercial

practices.  Previous corrective actions were either not

implemented or ineffective at preventing recurrence.  Under the

Poultry Products Inspection Act (PPIA) and Agency

requirements, live poultry must be handled in a manner that is

consistent with good commercial practices, which means they

should be treated humanely.  Respectfully, 

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 50

EstNbr EstName Task_Code MOI# Date Description

M9977 Tyson Foods Inc. 04C05 YBL201208

3711G

2017-08-11 On 8/10/17 and 8/11/17 during postmortem inspection, I

observed approximately 10 severely bruised poultry carcasses. 

The first carcass on 8/10/17 had its entire left breast tissue

affected with a severe red/purple bruise.  

 and 

were shown the carcass.  Two more severely bruised poultry

carcasses were seen on 8/10/17.  The first carcass had dark

red/purple bruising across the entire left breast, corresponding

shoulder joint, and ventral neck with blood pooled under the

skin in all these locations.  There was also a laceration

approximately 2 inch in length located just to the left of the tip

of the keel bone with the associated breast tissue infiltrated

with blood.  was shown the

poultry carcass.  The second poultry carcass had bruising

centered in the right hip area which had spread to the

corresponding breast and wing joint with blood pooled under

the skin in all these locations.  The hip joint was completely

dislocated.  Additionally, there were multiple caudal rib

fractures present.  was

shown the poultry carcass. On 8/11/17, after giving inspector

breaks on evisceration line #2, I showed

two poultry carcasses with severe bruising.  In both

cases approximately one half of the entire breast and the

corresponding wing joint was affected by a dark red/purple

bruise.  There was blood pooled under the skin of all these

locations and the tissues were infiltrated with blood as well. 

There was a 1-2 inch long laceration in the breast muscle near

the tip of the keel bone with bloody infiltrate.  I showed 

 approximately five more

poultry carcasses which had red/purple bruising on the entire

left breast muscle with blood pooled under the skin in this

location and a 1-2 inch long laceration in the breast muscle near

the tip of the keel bone.  9CFR 381.65(a) states: "Operations

and procedures involving the processing, other handling, or

storing of any poultry product must be strictly in accord with

clean and sanitary practices and must be conducted in a manner

that will result in sanitary processing, proper inspection, and the

production of poultry and poultry products that are not

adulterated."  The lesions suggest that these chickens had

significant force applied to the affected areas.  Severe bruising is

indicative of improper handling of live poultry.  Under the

(b) (6)

(b) (6)

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 51

EstNbr EstName Task_Code MOI# Date Description

Poultry Products Inspection Act (PPIA) and Agency

requirements, live poultry must be handled in a manner that is

consistent with good commercial practices.  Please provide a

response which addresses this concern. Respectfully, 

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 53

EstNbr EstName Task_Code MOI# Date Description

P1009 Wayne Farms

LLC

04C05 DSM57210

44603G

2017-04-03 At approximately 1500 hours while assisting 

, with an annual GCP audit, a cadaver was noted exiting

the last picking machine.  The head was intact, engorged and

red/purple in color, edematous, and no neck cut was present.  I

followed the carcass into the evisceration department.  The

head was removed by the head puller after the rehang table.  I

followed the carcass to inspection station 2 to ensure it was

condemned.  The inspector at station 2 condemned the carcass

and instructed the trimmer to document it on the

condemnation lot sheet as a cadaver at approximately 1508

hours.  At approximately 1545 hours, informed plant

management that an MOI would be issued.  9 CFR 381.65(b)

states that "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.

P1201 Pilgrims Pride

Corporation

04C05 JAB011106

1310G

2017-06-10 At 1144 hours, while performing a GCP task on Saturday, I 

 observed the plant employee

make an attempt to retrieve a live bird from a cage rack. The

employee was standing at the DOA observation station when I

noticed him go with urgency to automatic loading area for the

cage wash. He was unable to stop the cage from entering

washer or retrieve the live bird. The live bird was retrieved from

the cage after passing through the washer (water temperature

unknown) and placed on the CO2 conveyer chamber for

slaughter. I discussed this occurrence with plant personnel, 

 and assured me the

incident will be addressed. On Monday (6/12/2017) at 0605

hours, informed me of documentation the

employee was retrained and how to proceed if a bird is

observed in cage rack entering the washer. A copy of this MOI

and your response will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended.

(b) (6)

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

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 54

EstNbr EstName Task_Code MOI# Date Description

P1235 Wayne Farms

LLC

04C05 GKN29140

31230G

2017-03-30 On Wednesday, March 29, 2017 at approximately 1521 hour

while performing an Ante Mortem inspection and a Good

Commercial Practice Check, I observed several conditions

concerning the treatment of poultry prior to slaughter in the live

hang area.  At the end of the live hang belt there was a large red

“inedible” barrel that employees had put 12-15 live birds piled

on top of each other in, the barrel was full to the very top. 

These are larger birds, putting them at a greater risk for

crushing / suffocating the ones at the bottom and causing death

by means other than slaughter.  There were at least 30 loose

birds running around in the live hang room as well, with many

tucked under the belt and very difficult to visualize.  The belt

hangs low in this area and birds can easily become

entrapped / snared.  In addition there was a weak / minimally to

non-responsive, laterally recumbent bird, that was unable to lift

its head and had shallow respirations that was against a wall in

the live hang room with a pile of three already deceased birds. 

At the end of the belt there was a pile of filth / feathers that was

stacked approximately 2-2.5 feet high.  Tucked under the belt

among the pile of feathers was a live bird that was very difficult

to visualize.  Establishment employees had failed to notice this

bird, and were not tending to the increasing size of the pile of

filth / feathers at the end of the belt.  In order to prevent this

bird from almost certain suffocation I immediately notified the

, so he could get the

bird and prevent it from dying by means other than slaughter. 

During this time I also discussed the other above concerns with

 and pointed out the recumbent bird next to the

already deceased birds, at which time this bird was picked up

and put back into production by .  The employees had

already emptied the birds out of the “inedible” barrel and

gathered all of the loose birds by the time arrived. 

 had told me that they should not have that barrel

back in live hang and he was unsure why they were putting the

birds in there, this is not something that they do at this

establishment.  At the time of my inspection in the live hang

area it appeared that control over that area had been lost. 

Establishment management was notified as well of the incident

and informed of the resulting MOI.  As per Federal Register

Notice Docket No. 04-037N dated September 28, 2005,

“Treatment of Live Poultry before Slaughter,” the Food Safety

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 55

EstNbr EstName Task_Code MOI# Date Description

Inspection Service (FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good Commercial Practices

(GCPs) as described by industry guidelines. My observations

are consistent with less than good commercial practices. A

copy of this Memorandum of Interview will be forwarded to

appropriate personnel in the District Office.  Respectfully

submitted on March 29, 2017. Cc:

         DDM DVMS  FLS’

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 56

EstNbr EstName Task_Code MOI# Date Description

P1235 Wayne Farms

LLC

04C05 GKN16120

41507G

2017-04-07 On April 7, 2017, at 0843, I,

observed less than Good Commercial Practices. While

performing a routine Ante-Mortem Inspection and Good

Commercial Practice check (GCP), I observed one live bird whose

throat had not been cut about to enter scalder number one. The

bird had open, blinking eyes and was lifting its head in an

attempt to right itself. I was standing at the west (entrance) end

of scalder number one where the establishment has installed a

stop button for occurrences such as this. Therefore, I

immediately stopped the picking line, per establishment’s

written permission, to prevent the bird from entering the scald

vat. and 

 arrived quickly and 

removed the bird from the line prior to restarting the picking

line. I immediately performed an additional 1,000 bird check

and did not observe any improperly slaughtered carcasses. I

then proceeded to the kill room to verify the function of the

stunner and kill machine. During my observation period all

except 3 small birds were stunned and killed. The 3 small birds

were then missed by the kill blade but were properly cut by the

back up killer. The aforementioned bird had passed all plant

intervention steps and the entrance into the scalder was

imminent when the line stopped. Hence, it is reasonable to

conclude that without intervention and the utilization of the

emergency stop button, the bird would have entered the scalder

alive. After removal of the live bird and examination of the kill

process, the establishment determined that due to bird size

variations the stunner needed to be raised. After adjusting

equipment, verification checks performed by QA humane

handling technician indicated that additional adjustments were

needed. These adjustments were made and verification checks

were found to be acceptable. At approximately 0900, I notified

Plant Manager Heath Loyd that GCP MOI documentation would

be forthcoming.  A copy of this Memorandum of Interview will

be forwarded to appropriate personnel in the Jackson District

Office. Respectfully, Cc:

Dr. David Thompson, DDM, Jackson

DO                                                                                                        

                          

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

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 57

EstNbr EstName Task_Code MOI# Date Description

P1235 Wayne Farms

LLC

04C05 GKN51160

93712G

2017-09-12 On September 12, 2017, at 1550, I, 

observed less than Good Commercial Practices while

performing a routine Ante-Mortem Inspection and Good

Commercial Practice verification check.   While monitoring the

cage dump operations, I observed the fork lift driver run over

and kill a live bird.  The driver was moving rapidly to the cage

dump when a door on the cage opened and three birds fell onto

the pavement.  Before he could stop, one of the birds went

under a tire on the forklift; the head was immediately crushed

and severed from the body.   The driver stopped and caught the

remaining two birds replacing them into the cage and closing

the door.  He then retrieved the dead bird and took it to the

DOA chute.  and

 were called to the back

dock and immediately notified.  stated that the

driver of the forklift was in training but had already been trained

in animal welfare practices.  She relieved him from this job for

the remainder of the day, due to weather conditions and until

time allowed for more training so that the driver did not feel the

need to speed.  The cage was pulled from rotation until repairs

can be made. At approximately 1640, I notified Plant Manager

Brad Trapp and that GCP MOI

documentation would be forthcoming.    As per Federal Register

Docket NO. 04-037N, “Treatment of Live Poultry before

Slaughter”, the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices  as described by

industry guidelines.  A copy of this Memorandum of Interview

will be forwarded to appropriate personnel in the Jackson

District Office. Respectfully, 

 Cc: Dr. David Thompson, DDM

                                                                                                             

                                      

                                                                                       

                                                           

(b) (6)

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

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 58

EstNbr EstName Task_Code MOI# Date Description

P1241 Tyson Foods,

Inc.

04C05 MGJ54150

25809G

2017-02-09 At approximately 1540 hours while and 

 were performing a Poultry Good Commercial

Practices task, they observed a live chicken in the condemn

barrel at the end of the transfer belt in the Live Hang Area.  This

condemn barrel is designated for dead chickens only, and no

live chickens should be placed in this barrel.  notified

 and of this finding, and he notified

 of the impending MOI.

P1241 Tyson Foods,

Inc.

04C05 MGJ21180

72211G

2017-07-11 Establishment # 01241-P; Tyson Foods, Inc.; July 11, 2017; 1725

hours; and At approximately

1725 hours while performing a Good Commercial Practices task,

I observed the following issues in the Live Hang area:      1. I

found a live chicken in a condemn barrel that contained and

was designated for dead chickens.      2. I found 3 live chickens

that were partially covered by several dead chickens at the end

of the live hang belt. I immediately notified 

 of this finding and of the impending MOI.  I also

reminded of the importance of following good

commercial practices when handling live poultry.  

removed the live chicken from the condemn barrel and

euthanized it by cervical dislocation.   The live chickens that

were partially covered by the dead chickens were hung on the

slaughter line prior to arrival to the site.  

then discussed the issue with , of

this department. 

P1241 Tyson Foods,

Inc.

04C05 MGJ52150

83014G

2017-08-14 Establishment #01241-P; Tyson Foods, Inc; August 14, 2017;

1550 hours; , and 

At approximately 1550 hours while verifying Poultry Good

Commercial Practices in the Live Hang area, I found a live

chicken buried in a pile of approximately 30 dead chickens on

the floor at the end of the live hang belt.  A live hang employee

removed the live chicken from the pile and placed the chicken

onto the kill line.  I immediately notified 

and , of

this finding and of the impending MOI.  I also documented a

similar finding in MOI# MGJ2018070311I dated 7/11/2017. 

(b) (6)

(b) (6)

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

(b) (6)

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 59

EstNbr EstName Task_Code MOI# Date Description

P1243 Perdue Foods,

LLC.

04C05 XLB330708

2003G

2017-08-03 This MOI is being issued to document the finding of a live bird in

the DOA bin.  On 08/03/2017, at approximately 0635 hours,

while performing the Good Commercial Practices task, I

observed a live bird travel down the conveyor that is used to

remove dead on arrival birds from the live hang area.  This bird

fell to the floor when it reached the end of the conveyor.  An

establishment employee then picked up this bird and placed it

in the DOA bin.   was present and I showed him

the live bird in the DOA bin.  There was no denaturant applied

to this bird at this time.   removed this bird and it was

placed back on the live hang table.  If this bird had remained in

the DOA bin, it likely would have died by asphyxiation due to

being smothered by having dead birds placed on top of it. 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. I recommend that management 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.  A copy of this

MOI will be forwarded to the District Veterinary Medical

Specialist (DVMS) in the event that an additional follow-up is

recommended.

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 60

EstNbr EstName Task_Code MOI# Date Description

P1249 George's

Chicken, LLC

04C05 UVG13000

13925G

2017-01-25 Poultry Good Commercial Practices Reg. 381.65(b) verified from

17:18 to 18:04 hours and from 20:50 to 20:58 hours. At

approximately 17:18 hours, while performing the Poultry Good

Commercial Practices Verification Task, I, 

observed two carcasses on Kill Line 2 which appeared to be

cadavers.  Immediately I followed these carcasses to the

Evisceration Department, pulled them off the line at the rehang

belt and confirmed that both were indeed cadavers; one had

obviously not received a kill cut and both were a deep purple

color due to not having bled out.  I then showed the carcasses

to  who was in the area at the

time.  At approximately 17:32 hours while watching the kill

process, I observed the backup employee miss one of the birds

that had not received a cut by the kill blade.  Immediately I

stopped the line and notified the employee.  I then observed

him search for the missed bird, find it and make the necessary

cut.  Shortly thereafter, arrived and

we both observed that several birds (4-6) in a row were not cut

by the kill blade.  Again I stopped the line (I was closer to the E

stop than .) and the backup employee was able to

make the necessary cuts.  Having made these observations and

having been informed that the backup employee is new, my

concern is that there may be an increased chance of birds not

being slaughtered according to the Poultry GCP Regulation

381.65(b) when there is an increase in the number of birds

missed by the kill blade. The observations noted above were

discussed with and 

  I also expressed the need for backup employees to

feel comfortable stopping the line when necessary to ensure

that all of the birds receive the proper kill cut.  

questioned whether or not there needed to be an adjustment of

the line speed.  stated that a reduction in line speed

should not be needed in order to correct the problem.  He

further stated that the matter would be looked into

and addressed.

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

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 61

EstNbr EstName Task_Code MOI# Date Description

P1249 George's

Chicken, LLC

04C05 UVG53230

20608G

2017-02-08 Poultry Good Commercial Practices Reg. 381.65(b) verified from

 16:52 to 17:02 hours, from 17:47 to 18:00 hours and from

approximately 19:18 to 19:36 hours. GCP Findings: At 16:52

hours, I, , observed 2 cadavers on line 2 in the

picking room and I followed them to the Evisceration

Department’s Rehang Station.   There I had these 2 cadavers

pulled off of the line and then another cadaver was observed

and pulled off by a rehang employee.  Immediately I informed

 and showed him the cadavers.  I then showed

 my

findings and she notified . The

above finding were shown to and discussed with 

 and USDA . 

 responded by saying that 

 would be placed in the back up kill position and

that maintenance would check the equipment. At 17:34 hours

 followed up on the initial meeting and stated the

following:                and [the usual back up

employee] were now both working in the back up kill position. 

              The line speed was slowed down by birds per

minute.               Maintenance checked the equipment and

found no mechanical problems.               The varied bird sizes

may be the result of the birds being weaned off of

gentamycin [a factor leading to                         the inability to set

the kill blade at an appropriate level].  He will check with 

 *Note  -  was not present at

this meeting but was informed of my findings at a later time. 

*Note -  My concerns stem not only from today’s finding but

also from findings noted in MOI UVG10000151251 dated

1/24/17 and NR UVG3021015730N/1 dated 1/27/17.

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

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (4)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 62

EstNbr EstName Task_Code MOI# Date Description

P1249 George's

Chicken, LLC

04C05 UVG06140

23827G

2017-02-27 Poultry Good Commercial Practices Reg. 381.65(b) verified at

16:46 hours, from 16:54 to 17:00 hours, from 19:48 to 19:58

hours and from 21:25 to 21:41 hours. At 16:54, 16:55 and

17:00 hours, while performing the above mentioned task, I, 

, observed a cadaver bird on Kill Line 2 in the

picking room at each of the times listed for a total of 3 birds in a

6 minute time frame.  The first 2 cadavers were pointed out to

 who had them removed from the kill

line and disposed of.  The third cadaver I pointed out to 2nd

 at 17:00 hours. These findings were

discussed with and with 

 at 17:05 hours.  responded

by saying that the current back-up kill cut employee was not

consistently focused enough to remain in the position.  She was

therefore placing in this position

until a capable employee could be trained to do the job. 

*Note:  was not present at the meeting

but was informed of these findings at a later time. **Note:  I

met with again at 20:07 hours to

discuss observations made from 19:48 to 19:58 hours.  During

this time I observed another cadaver on Kill Line 2 and I also

observed a rehang employee in the Evisceration Department

tossing birds into the drain instead of into the inedible barrel

where they could be accounted for.  said that she

would get with  immediately

regarding the cadaver and that she would also get with the

Evisceration Department supervisors regarding the use of the

inedible barrel for proper bird disposal.  My subsequent findings

during observations made from 21:25 to 21:41 hours were

acceptable.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 63

EstNbr EstName Task_Code MOI# Date Description

P1249 George's

Chicken, LLC

04C05 UVG54180

73011G

2017-07-11 An Establishment Awareness Meeting was held on 7/11/17 at

approximately 2000 hours to discuss observations made in the

Receiving/Live Hang Department.  I, 

nd 

 were present at this meeting. The first issue

addressed was the cadaver birds found between 1547 and 1557

hours.  During this time, while in the picking room, I observed a

cadaver bird on Line 1.  Then after following the bird into the

Evisceration Department, I observed 3 more cadavers in the Line

1 inedible barrel and 1 cadaver in the inedible barrel for Lines

2 &   Immediately thereafter, I notified  of my

findings.  After returning to the picking room I observed another

cadaver on Line 1.  responded by saying that the

back up kill cutter had already been warned on two previous

occasions about his job performance and that she and the line

leaders would continue to monitor his performance on an

basis. The second issue addressed was concerning

a small bird found in the blood pit.  At approximately 1607

hours, while observing the blood level in the pit, I noticed a bit

of movement and discovered that a small bird was sitting in the

pit.  The bird was covered in blood and was in danger of

drowning in blood if it remained in the pit much longer. 

Immediately I notified who then notified 

 responded by having the bird removed from

the pit. also stated that they would keep and eye on

the blood pit and that she would get with the Day Shift Senior

Supervisor to make sure that the pit was being checked and

pumped out before the shift change. The third issue addressed

was the presence of birds on the floor in the Live Hang Area. 

When I walked into the Live Hang room I counted

approximately 21 birds walking around or sitting on the floor. 

After I stood there for a few minutes, I then saw the line leaders

begin to gather the birds and get them back on the belt for

hanging.  stated that I may have come into the area

just before she did because shortly thereafter, she had spoken

with the line leaders about the importance of keeping the floor

clear of birds. The last issue addressed was the 2 loose birds

found sitting between cages on trailer #148.  While making

observations in the receiving shed, I noticed a cage with an open

door and then further observed that 2 birds were sitting

between cages.  Again I notified of my findings and

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

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (4 (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 64

EstNbr EstName Task_Code MOI# Date Description

she instructed a line leader to remove the birds. 

also stated that they were working to ensure that all damaged

cages were set aside for repair because with well maintained

cages, they would be able to keep the birds from getting loose. 

This meeting was then adjourned. 

* Note - The first issue discussed was resolved with the

termination of said employee on 7/12/17.  Subsequent

observations in this department on 7/12 & 7/13 have shown a

marked reduction in the number of cadavers.

P1250 Fieldale Farms

Corporation

04C05 OAA34090

42511G

2017-04-11 124 birds were accidently suffocated on the hanging belt in the

live hang room at P-1250 on the morning of April 10 between

0700 and 0800 hrs. due to a malfunction of the hanging belt

causing the cogs to run but the belt to slip.  Consequently birds

from the dumping belt dropped on top of the birds on the

hanging belt below and suffocated the birds on the hanging

belt.   I observed many of the dead birds while performing

the Good Commercial Practices task.  I met with 

 and 

 later the same morning at approximately 0945

hrs. They gave me the above explanation, also adding that the

dumping belt automatically continues to operate as long as the

cogs on the hanging belt are turning and cannot recognize when

the hanging belt is slipping, i.e. the dumping belt keeps

running.  They said that when the malfunction was recognized

by establishment personnel, no new cages of birds were

dumped on the dumping belt. They didn’t see how the incident

could have been avoided and said that it doesn't happen very

often.

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 65

EstNbr EstName Task_Code MOI# Date Description

P1272 Pilgrim's Pride

Corporation

04C05 CCA381201

1510G

2017-01-10 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Monday, January 9,

2017 at approximately 0553 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the pre-evisceration area. I observed one live bird

enter the scald vat on line number one alive. The bird was

observed alive and blinking its eyes. I immediately notified 

 of the observation who retrieved

the cadaver upon exit from the scald vats.  

 and 

 were both notified shortly

thereafter. stated he would place a second backup

killer on line one for the remainder of the shift. No other live

birds were observed entering the scald vat alive. This issue will

be discussed with management at the next USDA weekly

meeting on January 11, 2017. There was no immediate

response given by establishment management. Respectfully, 

P1272 Pilgrim's Pride

Corporation

04C05 CCA330602

3115G

2017-02-15 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Monday, February

13, 2017 at approximately 0441 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the pre-evisceration area. I observed one deceased

bird on the picking line exit scald vat number two and reenter

scald vat number three on line number two that was bright red

in color. Once removed by an employee, the bird was observed

to be bright red with engorgement throughout the neck and

head. There was no cut visible to the neck to indicate proper

slaughter procedure. I immediately notified 

of the observation who retrieved the cadaver

from the employee

and 

 were both notified shortly thereafter. stated

he would replace the backup killer on line two for the remainder

of the shift. This issue will be discussed with management at

the next USDA weekly meeting on February 16, 2017 and

documented in the weekly meeting MOI. Respectfully, 

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

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

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

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 66

EstNbr EstName Task_Code MOI# Date Description

P1272 Pilgrim's Pride

Corporation

04C05 CCA220704

5425G

2017-04-25 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Monday, April 24,

2017 at approximately 0605 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the pre-evisceration area. I observed one live bird

enter the scald vat on line number two alive. The bird was

observed alive and blinking its eyes prior to entry into the scald

vat. I immediately notified . We

both observed the cadaver upon exit from scald vat number 2

and scald vat number 3. stated he would replace the

current backup killer on line two with another backup killer. No

other live birds were observed entering the scald vat alive. This

issue will be discussed with management at the next USDA

weekly meeting on April 25, 2017. There was no immediate

response given by establishment management. Respectfully, 

P1272 Pilgrim's Pride

Corporation

04C05 CCA340306

0014G

2017-06-14 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Friday, June 9, 2017

at approximately 0834 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the evisceration area. I observed and pulled from

the line one cadaver bird during inspection on line number one

at station number three. The cadaver was observed with an

engorged head intact with the neck to which there was no cut

visible. I immediately notified

 and . I held the cadaver at the PHV hold

rack at the station to show both supervisors. stated

he would place a second person to assist the current backup

killer on line one. During verification of this corrective action, it

was later observed that instead switched backup

killers instead of placing two people at this position. No other

live birds were observed entering the scald vat alive. This issue

will be discussed with management at the next USDA weekly

meeting on June 15, 2017. There was no immediate response

given by establishment management. Respectfully, 

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

(b) (6)

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

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 67

EstNbr EstName Task_Code MOI# Date Description

P1272 Pilgrim's Pride

Corporation

04C05 CCA420606

3216G

2017-06-16 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Wednesday, June 14,

2017 at approximately 0840 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the evisceration area. I observed and pulled from

the processing line one cadaver bird on line number two at the

rehang table. The cadaver was observed with an engorged head

intact with the neck to which there was no cut visible. I

immediately notified ,

who observed the bird shortly after the occurrence. Plant

Manager, Mark Dean was notified and observed the bird shortly

thereafter. At approximately 0842 hours while still performing

a Good Commercial Practices Task in the pre-evisceration area, I

again observed a live bird enter the first scald vat on line

number two. I immediately notified

The bird was removed from the line after

exiting scald vat number two. We both observed an engorged

head and that there was no cut to the neck of the bird. 

 and were also notified shortly thereafter. 

For both instances, stated that two employees will

be placed at the position of backup killer on line two for the

remainder of the shift. No other live birds were observed

entering the scald vat alive. This issue will be discussed with

management at the next USDA weekly meeting on June 15,

2017. There was no immediate response given by establishment

management. Respectfully, 

(b) (6)

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

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 68

EstNbr EstName Task_Code MOI# Date Description

P1272 Pilgrim's Pride

Corporation

04C05 CCA420606

4620G

2017-06-20 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Monday, June 19,

2017 at approximately 1042 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the pre-evisceration area. I observed one live bird

enter the scald vat on line number two alive. The bird was

observed alive and blinking its eyes prior to entry into the scald

vat. I immediately notified 

and . We all observed

the cadaver upon exit from scald vat number two. 

removed the bird at this point before entering scald vat number

three. The cadaver was observed with an engorged head intact

with the neck to which there was no cut visible. 

stated he would add another backup killer on line two for the

remainder of the shift. No other live birds were observed

entering the scald vat alive. This is the fifth bird in

approximately one week to be observed entering a scald vat

alive at this establishment. Those corrective actions which have

been stated and used thus far may not be sufficient to prevent

reoccurrences of this nature. This issue will be discussed with

management at the next USDA weekly meeting on June 20,

2017. There was no immediate response given by establishment

management. Respectfully, 

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 69

EstNbr EstName Task_Code MOI# Date Description

P1272 Pilgrim's Pride

Corporation

04C05 CCA220606

4320G

2017-06-20 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Friday, June 16, 2017

at approximately 1105 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the pre-evisceration area. I observed one live bird

enter the scald vat on line number two alive. The bird was

observed alive and blinking its eyes prior to entry into the scald

vat. I immediately notified 

 We both observed the cadaver upon exit from scald vat

number two. removed the bird at this point before

entering scald vat number three. The cadaver was observed with

an engorged head intact with the neck to which there was no

cut visible. First shift plant manager, Demaricus Green was

notified and shown the cadaver shortly thereafter. Mr. Green

stated he would replace the current backup killer on line two to

allow for further re-training of the employee and if placed back

in the position of backup killer there would always be a second

person with him. No other live birds were observed entering the

scald vat alive. This is the fourth bird in one week to be

observed entering a scald vat alive at this establishment. Those

corrective actions which have been stated and used  thus far

may not be sufficient to prevent reoccurrences of this nature.

This issue will be discussed with management at the next USDA

weekly meeting on June 20, 2017. There was no immediate

response given by establishment management. Respectfully, 

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

(b) (6)
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EstNbr EstName Task_Code MOI# Date Description

P1284 Pilgrim's 04C05 GDA37010

30002G

2017-03-02 EST. P-1284, Pilgrim’s, March 1, 2017, 0415 hours. In

attendance:

 At

approximately 0415 hours on 3/1/2017, I was observing

conditions in the live room. As I was watching the picking line

move through the electrostimulation unit, I observed a live

chicken. I followed the line (no safe emergency stop within

reach). I observed the live chicken enter the first scalder. At the

exit of the final picker, I removed the cadaver that had no neck

cut, red skin and a deep purple swollen neck and head. I

immediately showed the cadaver to and . I

reminded plant management that the PPIA and agency

regulations do require that live poultry be handled in a manner

that is consistent with good commercial practices (GCPs).

Poultry are to be slaughtered in a manner that ensures that

breathing has stopped before scalding, so that the birds do not

drown, and that slaughter results in thorough bleeding of the

poultry carcass. Poultry carcasses showing evidence of having

died from causes other than slaughter are considered

adulterated and must be condemned. Compliance with these

requirements helps ensure that poultry are treated humanely. I

recommended that the Federal Register on Treatment of Live

Poultry before Slaughter, published September 2005, be

reviewed for FSIS recommendations concerning treatment of

live poultry before slaughter, and provided a copy of this

document. A live chicken has been found on the picking line at

this same location (GCP MOI dated 5/25/16) and the issue was

discussed during the weekly MOI meeting (dated 5/26/16). 

This MOI will be forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in the event additional

follow-up is recommended. Respectfully, 

P-1284

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 71

EstNbr EstName Task_Code MOI# Date Description

P1284 Pilgrim's 04C05 GDA10020

30520G

2017-03-20 EST. P-1284, Pilgrim’s, March 20, 2017, 0130 hours. In

attendance:

 At approximately 2236 hours

on 3/19/2017, I was observing conditions in the live room. As I

was watching the picking line move through the

electrostimulation unit, I observed a live chicken. I followed the

line (no safe emergency stop within reach). I observed the live

chicken enter the first scalder. At the exit of the final picker, I

stopped the picking line and removed the cadaver that had no

neck cut, bright red skin and a deep purple swollen neck and

head. I immediately showed the cadaver to 

 who was in the picking room at that time and

observed me stop the picking line. I reminded plant

management that the PPIA and Agency regulations do require

that live poultry be handled in a manner that is consistent with

good commercial practices (GCPs). Poultry are to be slaughtered

in a manner that ensures that breathing has stopped before

scalding, so that the birds do not drown, and that slaughter

results in thorough bleeding of the poultry carcass. Poultry

carcasses showing evidence of having died from causes other

than slaughter are considered adulterated and must be

condemned. Compliance with these requirements helps ensure

that poultry are treated humanely. I recommended that the

Federal Register on Treatment of Live Poultry before Slaughter,

published September 2005, be reviewed for FSIS

recommendations concerning treatment of live poultry before

slaughter, and a copy of this document was provided on

3/1/2017. A live chicken has been found on the picking line at

this same location (GCP MOI dated 5/25/16) and the issue was

discussed during the weekly MOI meeting (dated 5/26/16). In

addition, an MOI was documented on 3/2/2017 for a similar

occurrence. This MOI will be forwarded to the District Office

and the District Veterinary Medical Specialist (DVMS) in the

event additional follow-up is recommended. Respectfully, 

 P-1284

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 72

EstNbr EstName Task_Code MOI# Date Description

P1307 Mar-Jac

Poultry-AL

04C05 KIL560602

3403G

2017-02-03 On Friday, February 3, 2017 at approximately 1:12 am, I

observed less than Good Commercial Practices. While

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed 5 birds piled up on the floor under

shackles just prior to the kill machine.  Four of these birds were

deceased and the fifth bird in the pile was breathing, recumbent

and very weak.  The , was immediately

and verbally notified of the situation.  At which time he had live

hang personnel gather the birds and manually decapitate the

live bird.  was informed that this situation would result

in an MOI for live birds co-mingling with dead birds and dying

by means other than slaughter.  This has been an on-going trend

for the past three nights at this establishment, which was

previously discussed with management, that if birds die by

means other than slaughter, such as suffocation from live birds

co-mingling with dead birds, an MOI for less than Good

Commercial Practices could result.  On February 1, at

approximately 12:29 am, while performing an Ante Mortem

inspection and Good Commercial Practice Check, I observed

approximately 20 loose birds in the live hang area.  There were

also approximately 20 dead birds and a large amount of debris,

such as feathers and filth at the end of each belt that the birds

traverse to be shackled.  I observed three smaller live birds fall

off of the belt and land in and around the pile at this time,

several other dead birds continued to fall onto the pile and on

top of the live birds as well.  Management, , was

immediately notified of the situation to prevent the birds from

becoming crushed.  At approximately 2:02 am the same night

there was no change in the conditions in the live hang are, there

were still approximately 15-20 loose birds, a pile of

approximately 20 dead birds with filth at the ends of each belt

and smaller live birds falling off the belt onto the pile of dead

birds and one bird stuck under the belt.  was again

notified, at which time he informed me that he would have the

live hang employees keep the ends of the belts clean.  The

following night, February 2, while performing an Ante Mortem

inspection and Good Commercial Practice Check, there

remained issues with smaller birds falling off the belts and

comingling in the piles of dead birds.  At this time it was

thoroughly explained to that it is not in accordance

with Good Commercial Practices for birds to die by means other

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 73

EstNbr EstName Task_Code MOI# Date Description

than slaughter.  If these birds become crushed and suffocate in

the pile of dead birds that is death by means other than

slaughter and will result in an MOI for less than Good

Commercial Practices.  I was informed at that time by 

that two establishment employees would be kept back in the

live hang area to keep the piles at the ends of the belts clean

and monitor the birds to prevent this situation.  These

preventative measures failed to prevent recurrence. As per

Federal Register Notice Docket No. 04-037N dated September

28, 2005, “Treatment of Live Poultry before Slaughter,” the

Food Safety Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely and abide by the Good

Commercial Practices (GCPs) as described by industry

guidelines. My observations are consistent with less than good

commercial practices. A copy of this Memorandum of

Interview will be forwarded to appropriate personnel in the

District Office.  Respectfully submitted on February 3, 2017 

 Cc:          DDM                DVMS 

                FLS

P1307 Mar-Jac

Poultry-AL

04C05 KIL531308

4102G

2017-08-02 At approximately 10:10 on July 28, 2017, I observed less than

Good Commercial Practices (GCP) wile performing

Antemortem/GCP/Mishandling verification at Mar-Jac Poultry in

Jasper, AL.  I observed one chicken in the DOA dumpster that

was still breathing and fully alert.  The chicken was one of

approximately 10-15 chickens that had been dumped on top of

the pile of denatured DOA's in the dumpster.  All of the other

chickens had been decapitated except the one live chicken.  I

notified , who immediately retrieved the

live chicken, and euthanized it by cervical dislocation and

decapitation. Federal Register Notice Docket No. 04-037N

dated September 28, 2005, "Treatment of Live Poultry Before

Slaughter" states that under the Poultry Products Inspection Act

(PPIA) and Agency Regulations, all establishments engaged in

the slaughter of poultry to make every effort to treat poultry

humanely and abide by Good Commercial Practices.  cc: 

(b) (6)

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 75

EstNbr EstName Task_Code MOI# Date Description

P1317 Wayne Farms

LLC

04C05 QUI111004

3118G

2017-04-18 On Monday April 17, 2017 at approximately 0817 hour while

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed a weak bird on its back under the

dump cages in a puddle of water, with weak respirations,

soaking wet and unable to right itself.  In addition its right wing

was contorted in an abnormal angle in the mid humeral region

appearing fractured.  I immediately went to ask the dump cage

operator if he had a radio to call for a supervisor, he asked if it

was for the loose bird, I replied yes.  He told me that he did not

and that I needed to go around front to the office to find

someone.  I went towards the front of the building, at which

time I found a maintenance worker with a radio and asked him

to call for a supervisor to meet me at the dump cages as quickly

as possible.  At approximately 0819 a supervisor came to the

dump cages, got the bird and took it back into production.  At

0822 a meeting was held with supervisors explaining that it is

imperative that birds be handled/treated humanely prior to

slaughter and do not die by means other than slaughter.  This

bird was in imminent danger of dying by drowning.  At this time

I was told that the bird had fallen out of a hole in the bottom of

a cage to the area under the dump cages, which has a large

amount of water at all times.  The bird had not been retrieved in

a timely manner allowing it to become injured and at risk of

drowning.  Management was informed of the resulting MOI

from this incident. As per Federal Register Notice Docket No.

04-037N dated September 28, 2005, Treatment of Live Poultry

before Slaughter, the Food Safety Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines. My observations are consistent with less

than good commercial practices. A copy of this Memorandum

of Interview will be forwarded to appropriate personnel in the

District Office. Respectfully submitted on April 17, 2017. 

 Cc: DDM DVMS FLS

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 76

EstNbr EstName Task_Code MOI# Date Description

P1317 Wayne Farms

LLC

04C05 QUI151104

0919G

2017-04-19 On Wednesday April 19, 2017 at approximately 0647 hour

while performing an Ante Mortem inspection and a Good

Commercial Practice Check, I observed a weak, moribund bird

on its back with shallow respirations on the ground in live hang

at the end of the live hang belt under a pile of four other dead

birds.  This bird was in imminent danger of becoming crushed

and dying by means other than slaughter.  There was not a

supervisor in the area, nor was one close by.  No one was

monitoring the birds at the end of the belt.  I asked one of the

live hang employees if anyone in the area had a radio to call a

supervisor and was told no; that in order to get a supervisor I

would have to go through the building and find the offices to

locate someone.  Due to the immediate risk of

death/suffocation to the weak bird and the length of time it

would take to get a supervisor, I first pulled the bird off to the

side out from under the pile of already dead birds in order to

prevent it from dying until I could locate a supervisor.  An

employee with a radio was found in the building.  I asked her to

please call a supervisor to meet me in live hang.  Approximately

5 minutes from finding the bird, 

 arrived and I showed her the bird and told her that

it had been under the pile of the dead birds that were now

beside it.  She had gotten an employee to get the bird and put it

back on the belt and into production and also instructed the

employee to stay at the end of the belt to monitor the area. 

 informed me that the supervisors had been in a

meeting discussing the similar event that occurred yesterday

and previous GCP MOI issued earlier this week. Yesterday,

Tuesday April 18, 2017 at approximately 0827 while doing the

Ante Mortem and Good Commercial Practice Check for that day,

I observed a similar incident.  In the live hang room at the end of

the live hang belt on the ground there were a total of 8 birds, 7

of them were dead and one was live.  The live bird was

moribund and very weak.  I asked an employee to get a

supervisor and it took approximately 6 minutes for a supervisor

to arrive.  By the time the supervisor had gotten to the area the

bird had expired.  I asked for the supervisor to radio 

, to discuss the incident.  Good

Commercial Practices were discussed in depth at that time and

 assured me that the situation would be rectified, as

this had never been an issue at this establishment before and it

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 77

EstNbr EstName Task_Code MOI# Date Description

would be prevented from happening again in the future.  I

explained to him that this was very serious and the agency takes

treatment of birds prior to slaughter very serious as well as birds

dying by means other than slaughter.  I also informed him that I

would be doing additional GCP checks to verify that this did not

occur again.  Live birds should not comingle with the DOA birds

as this puts them at risk for suffocation / becoming crushed.  

Once the incident occurred today was informed that

an MOI would result from these issues. As per Federal Register

Notice Docket No. 04-037N dated September 28, 2005,

Treatment of Live Poultry before Slaughter, the Food Safety

Inspection Service (FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good Commercial Practices

(GCPs) as described by industry guidelines. My observations

are consistent with less than good commercial practices. A

copy of this Memorandum of Interview will be forwarded to

appropriate personnel in the District Office. Respectfully

submitted on April 19, 2017. Cc: Dr.

David Thompson, DDM 

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 78

EstNbr EstName Task_Code MOI# Date Description

P1317 Wayne Farms

LLC

04C05 QUI072108

3023G

2017-08-23 TO: Mr. BRYAN ELROD, Plant Manager Wayne Farms LLC. 700

McDonald Ave. Albertville AL, 35950 FROM: 

 Dear Mr. Elrod, On August 23, 2017 at

approximately 20:50 hours, while performing an Ante-Mortem

Inspection and Good Commercial Practices at P-01317, Wayne

Farms Albertville AL, I observed a live bird in the DOA barrel. The

bird was lying on the top of dead birds and being in eminent

danger to be crushed and smothered by other birds when piling

up on the top of each other. 

, was notified about my observation.

 also observed the deficiency. I then notified 

, of the observed

deficiency, during a brief meeting held in USDA/FSIS office at

approximately 21:10 hours. I also informed them that a GCP

MOI documentation of our meeting and discussion of the

observed deficiency would be forthcoming. FSIS Docket No.

04-037N, Treatment of Live Poultry before Slaughter, states that

under the Poultry Products Inspection Act (PPIA) and Agency

regulations, live poultry must be handled in a manner that is

consistent with good commercial practices. In order to ensure

that poultry is handled and slaughtered in a manner that is

consistent with Good Commercial Practices, poultry should be

treated in such a manner as to minimize excitement, discomfort,

and accidental injury throughout processing. Corrective and

preventive measures addressing this incident are appropriate. I

look forward to your response. A copy of this Memorandum of

Interview will be forwarded to appropriate personnel in the

Jackson District Office. Dr. David

Thompson, DDM 

                                                                 Albertville AL, 35950

(b) (6)

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

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 79

EstNbr EstName Task_Code MOI# Date Description

P1317 Wayne Farms

LLC

04C05 QUI141809

4718G

2017-09-18 From: To: Mr. Bryan Ellrod Plant

Manager Dear Mr. Ellrod, On Monday, September18, 2017 at

approximately 17:40 hours, I observed less than Good

Commercial Practices. While performing an Ante Mortem and

Good Commercial Practice verification inspection procedures I

observed the fork lift driver ran over the bird which fell on the

ground because the cage door was open. When he saw what

happened, he stopped the fork lift and got out if it. I

immediately asked him not to move a fork lift until I find the live

hanging Supervisor or his assistant. Also I asked the live hanging

personnel to stop hanging birds until I get immediately

corrective action(s) from the . A

couple minutes after and the 

came to my office with their corrective action.

 stated that he will immediately replace the fork lift

driver with another trained one.  After his statement I told him

that they can resume their production. Because of this egregious

situation I informed that MOI is going to be issued to

the plant manager. As per Federal Register Notice Docket No.

04-037N dated September 28, 2005, “Treatment of Live Poultry

before Slaughter,” the Food Safety Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines. My observations are consistent with less

than good commercial practices. A copy of this Memorandum

of Interview will be forwarded to appropriate personnel in the

Jackson District Office. Dr. David

Thompson, DDM Respectfully submitted

on September 18, 2017 ,

                                                                 Albertville AL, 35950

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 80

EstNbr EstName Task_Code MOI# Date Description

P1353 Pilgrims Pride

Corporation

04C05 WUM0610

021502G

2017-02-02 At approximately 0235 on 2-2-17, while performing a Poultry

Good Commercial Practices task on 3rd shift, I observed a live

bird in the far right corner of the dead bin.  I asked the

associate picking up the dead birds to tell 

I would like to see him.  He, however, had seen the live

bird, retrieved it and hung it on the line before he understood

what I had asked. I walked down the line, found 

and asked to speak with him.  I informed I had found

a live bird in the dead bin but the associate had retrieved and

hung it before I could show him.  I informed I would

be writing a Good Commercial Practices MOI.  There were no

other live birds found in the bin. The establishment’s program

failed to segregate a live bird from the dead birds.  Without

USDA-FSIS intervention, it is reasonable to conclude the bird

would have been crushed or smothered and died by means

other than slaughter. After discussing this matter with 

, I then went on to finish my GCP task.  My next step was

to observe the birds entering the scalder. At 0241, I observed a

live bird enter the scalder.  The establishment’s program failed

to prevent a live bird from entering the scalder and, hence,

failed to comply with 9 CFR 381.65(b). I informed 

 of my findings and stated I would be

including this incident in my Good Commercial Practices MOI. 

While went to discuss this with the backup head

puller associate, I went to the bleeding room to observe the

slaughter and bleeding of the birds.  I observed the associate

performing the backup slaughter and he did not appear to have

to excessively back up the bleeding machine. These two

incidents, found within minutes of each other, indicate the

plant’s program was not consistent in following Good

Commercial Practices as required by 9 CFR 381.65 and as

discussed in Federal Register Docket No. 04-037N titled

“Treatment of Live Poultry Before Slaughter”.

(b) (6)

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

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 81

EstNbr EstName Task_Code MOI# Date Description

P1353 Pilgrims Pride

Corporation

04C05 WUM4600

084815G

2017-08-15 On 08/14/2017 at approximately 0058 hours, while performing

a Good Commercial Practice Check at establishment 01353P,

one young chicken out of a subset of 500 was observed with an

uplifted head, pupillary reflexes, rhythmic breathing and no cut

to the neck entering the scald tank. This incident was verified at

the exit of the first picker. The carcass was brick red in

appearance with a purple, uncut neck. The incident appeared to

be isolated and no evidence of a system failure existed.  To

confirm, a second verification check of approximately 500 birds

was conducted prior to the scald tanks and there were no live

birds observed entering the scald tanks during this retest.  

 and 

 were notified. I explained my observations and

informed them that a Memorandum of Interview (MOI) was

going to be documented and a copy forwarded to the

appropriate personnel in the Jackson District Office. Live bird(s)

entering the scald system is a less than Good Commercial

Practices and results in adulterated product. The establishment

is responsible for ensuring that birds under their control on the

official premises are treated in a humane manner that will

minimize excitement, discomfort, injury and/or death by means

other than slaughter. As per Federal Register Notice Docket

No. 04-037N dated September 28, 2005, “Treatment of Live

Poultry before Slaughter,” the Food Safety Inspection Service

(FSIS) strongly encourages all establishments engaged in the

slaughter of poultry to make every effort to treat poultry

humanely and abide by the Good Commercial Practices (GCPs)

as described by industry guidelines.    Respectfully submitted, 

(b) (6)

 Cc: Dr. David Thompson, DDM; 

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 82

EstNbr EstName Task_Code MOI# Date Description

P1353 Pilgrims Pride

Corporation

04C05 WUM5623

093818G

2017-09-18 At approximately 2130 hours, came to the office to

inform me that live hang was having issues with birds being

dead on arrival. Upon entering the live hang area, I found that

the establishment had already stopped hanging due to the

significant number of DOAs. There were already 8 barrels filled

with DOAs and a pile at the end of the belt approximately 3 feet

high. No live birds were uncovered during the removal of the

DOAs, but considering the pile up of birds, it is a logical

assumption that if there were any live birds on the bottom of

the pile they had died from asphyxiation. I spoke with 

 and 

to see what had caused the high number of DOAs. I was

informed that the particular lot was carried over from first shift

and had arrived at 0657 hours that morning. The birds had been

in the truck since that time. No issues were observed with the

fans throughout the day. I was informed that the establishment

would be investigating further to see if there was an additional

cause to the high number of DOAs or if it was due to the

significant amount of time the birds were held in the truck prior

to slaughter. There were no significant findings on either

antemortem or postmortem inspection for live birds found in

that same lot. I informed both and

 that I would be writing an MOI for Good Commercial

Practices for the incident. The establishment is responsible for

ensuring that birds under their control on the official premises

are treated in a manner that will minimize excitement,

discomfort, injury and/or death by means other than slaughter. 

As per Federal Register Notice Docket No. 04-037N dated

September 28, 2005, “Treatment of Live Poultry before

Slaughter,” the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to abide by the Good Commercial

Practices (GCPs) as described by industry guidelines.    

Respectfully submitted, Cc: Dr.

David Thompson, DDM; 

(b) (6)

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

(b) (6)

(b) (6)

(b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 83

EstNbr EstName Task_Code MOI# Date Description

P1353 Pilgrims Pride

Corporation

04C05 WUM5203

092528G

2017-09-28 While doing a Good Commercial Practices task on the morning

of 9-27-17 on 3rd shift at Pilgrims of Chattanooga, I, 

 observed 4 live birds enter the scalder.  I

informed that I had

seen 3 live birds enter the scalder within a matter of minutes

(the first at 0059 hours and two at 0106 hours) and would be

writing a MOI.   A fourth live bird entered the scalder a few

minutes (0109 hours) after I had informed of the first

three.  I also informed him of this 4th bird. I continued to

observe the carcasses entering the scalder for 10 more minutes. 

I did not observe any more live birds enter the scalder. These

four incidents of live birds entering the scalder, found within

minutes of each other, indicate the plant’s program was not

consistent in following good commercial practices as required

by 9 CFR 381.65 and as discussed in Federal Register Docket No.

04-037N titled “Treatment of Live Poultry Before Slaughter.” 

However, there were no other factors observed to support a

process control failure and thus a regulatory control action.  

Respectfully, 

P1362 Tyson Foods,

Inc.

04C05 LPC180902

5307G

2017-02-07 Live chicken on ground below dumping unit. The bird was

picked up by unloading personnel at my request. One cage on

each of two trailers( #91083 and #91084; license #'s Oklahoma

) had large gaps in cages where vertical bars

were broken and pushed inward. Both had holes large enough

for birds to potentially escape. Also, the inward protrusion of

the bars is a hazard to any birds inside the cages. Both cages had

live birds in them.

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

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(b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 84

EstNbr EstName Task_Code MOI# Date Description

P1362 Tyson Foods,

Inc.

04C05 LPC160906

2809G

2017-06-09 On June 8, 2017, at approximately 09:20 hours, 

, and

 met with 

The following is a synopsis of the events and discussion

regarding GCP related issues.  I  began that while verifying that

poultry was slaughtered in accordance with good commercial

practice, I observed approximately 25 carcasses on the floor

behind Line 1  live hang that were dead on arrival. I observed

live hangers discarding several carcasses from the Line 1 live

hang belt to the floor. I  continued my GCP verification. While

observing the poultry in the receiving shed, I observed several

modules on several trailers in which the green plastic liner on

the bottom layer of the module was displaced upwards limiting

the space in which the birds could move freely. Some of these

liners were displaced upwards in which there was only about 4

inches between the bottom of the next module and the liner of

the lower module. I also observed a module in which there was

a hole approximately 6-8 inches long and 4 inches tall in which

birds could easily fall out or escape. Lastly, I observed a cage

with a 4 inch piece of the module had been dislodged and was

bent inside the cage where it could easily impale the bird. At

approximately, 09:20 hours while returning from the receiving

shed, I located and and

informed them of his observations. I  inquired about the cause

of the large number of DOAs. informed me that

these were due to holdovers from nightshift. I inquired about

whether the establishment scheduled these holdovers to be

slaughtered first. informed me that they did. I

 inquired about if the holdovers should be finished by this point

and thought they were after consulting with 

 It should be noted that NR number

LPC1219064002N dated June 1st was issued due to DOA at the

inspection station. Furthermore, DOAs presenting at inspection

stations have been a developing trend discussed in the weekly

meeting. In addition, cages being in disrepair were also most

recently noted in the weekly meetings April 13th.  There was no

response by the establishment. MOI LPC1809025307G was

issued on February 7th for similar instances of cages in disrepair.

The meeting was adjourned at approximately 09:30 hours.

(b) (6)

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 85

EstNbr EstName Task_Code MOI# Date Description

P1362 Tyson Foods,

Inc.

04C05 LPC081407

0305G

2017-07-05 On July 5, 2017 at approximately 12:10 PM while performing

the Good Commercial Practices task, I observed two live birds

between cages on Trailer #091090 in Bay #7 of holding shed. I

could not tell which cage they had come out of as all cage doors

appeared to be closed. I notified and

 about this less than

ideal situation. We have previously discussed problems with Live

Haul concerning cages with holes in them and cages missing

doors. Also, these afore mentioned problems predispose birds to

getting loose and falling from trailers enroot to the

establishment from the farm.

P1362 Tyson Foods,

Inc.

04C05 LPC161809

2804G

2017-09-04 On September 4, 2017 at 18:01while doing a Good Commercial

Practices task I observed a dead chicken that appeared to have

been crushed between two cages. The chicken was on the roller

chain that brings the cages up to the dump station. It was

partially wedged under the front side of the next cage in line to

be dumped on Line # 2. The chicken had only recently died. The

person operating the dumping machine said he did not see the

bird and said that neither of the forklift drivers notified him of

any loose birds.This type of mistreatment of the birds, even if

accidental, must not be allowed to happen again. Repeated

incidents of this type could result in a violation of Good

Commercial Practices. I notified the 

 and of the

situation and the subsequent MOI that I would be issuing.

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

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(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 86

EstNbr EstName Task_Code MOI# Date Description

P146 Tyson Foods,

Inc,

04C05 EJJ531004

3926G

2017-04-26 P 146 Tyson Poultry On April 25, 2017 at approximately 0515

while performing ante-mortem and Good Commercial Practice I

observed while walking through the live hang area there were a

large number of dead chickens on the DOA belt. This seems to

be a constant finding when there are chickens left over from the

night shift that did not get slaughtered. In checking I found

there were 17,680 chickens that were held over from the

previous night. While continuing to perform ante-mortem and

Good Commercial Practice on the live chickens on the trailers in

the shed, I observed the chickens in the cages to be very

depressed and cold looking. I could see there were some that

had also died. These were also part of the numbers that were

left from the previous night.I Inquired if there had been any

equipment failure or a mechanical issue that caused this

number of chickens not to be slaughtered and there was none.

This seems to be a continual issue of too many chickens

delivered to be slaughtered within the shift. The weather during

the night was rainy and there was a cold damp air. The shed is

open without any protection from the weather allowing these

chickens to endure the elements of the weather. The chickens

are held off feed prior to being caught and loaded into the cages

on the trailers and have not had any water after they were

loaded. Therefore these chickens had no food or water for

approximately 12 to 24 hours.I have observed prior that when

chickens are carried over from the previous day to bear the

elements of the weather whether it is very cold or very hot there

is an increase in the number of DOA’s during my ante-mortem

and GMP

checks.

                                                                                                             

                                                                 Therefore my observation

is that all this these chickens evidently died due by means other

than the normal slaughter process.This issue had been discussed

at the last weekly meeting and evidently no corrective measures

have been taken to correct the issue.
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 87

EstNbr EstName Task_Code MOI# Date Description

P165H OK

FoodsProcessing

Plant

04C05 DAF05130

13225G

2017-01-25 OK Foods, Inc. PO Box 158 1000 Old Pike Road Heavener, OK

74937 At approximately 0548 on 1/25/17, while performing a

good commercial practice check, I observed a sensible bird (eyes

open, head erect) proceeding down the line and into the line 1

scalder.  I traveled down the line and observed a cadaver exit

the pickers.  I removed the carcass and observed no evidence of

a neck cut.  I motioned for a lead in the area and asked him to

radio .  I showed

 the cadaver at which point he immediately left in

the direction of the blood tunnels where the kill machine and

back-up killers are located.  Shortly thereafter, I performed a

recheck and observed zero sensible carcasses prior to the

scalder.  I met with later

in the morning and discussed this incident informed

me that had replaced the back-up killer with

another employee.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 88

EstNbr EstName Task_Code MOI# Date Description

P165H OK

FoodsProcessing

Plant

04C05 DAF29140

44417G

2017-04-17 At approximately 1225 on 4/17/17 while performing a good

commercial practice check in the back dock area, I observed the

following poor live bird handling techniques.  A live bird holding

cage was resting on the concrete with all the doors open and

approximately 300 live chickens huddled in the area.  It

appeared that the cage had fallen from a forklift and spilled the

birds out.  I observed the cage boomer correctly lifting birds,

one at a time and placing them into the cage.  As I monitored

the situation, I observed two live hang employees come to the

assistance of the boomer.  However, one of these employees

was scooping up multiple chickens (3) at a time, resulting in

birds being carried by a wing or leg.  These chickens were then

crammed into the cage using more force than necessary.  At this

point, I walked to the cage and asked the live hang employee to

stop catching birds.  Both live hang employees immediately

stopped catching birds and returned to the live hang room.  I

then began looking around the area for someone with a radio to

contact plant management.  I observed one of the live hang

leads watching from under the cage dumping area and asked

him to radio .  

arrived a short time later.  I immediately informed him

of my observations.  I stayed in the area until all the live birds

were caught and returned to the cage using proper live bird

handling techniques.  commented that he would

discuss my observations with the back dock lead in an attempt

to determine who the live hang employee was.  Later, 

reported that the live hang employee denied catching

birds by the wing or leg.  On the morning of 4/18/17, 

met with to further

discuss this incident.  asked what caused the cage to

fall from the live haul truck and what steps the establishment

was taking to prevent this from happening in the future.  

later explained that the forklift driver had not raised the

top cage high enough prior to backing up the lift.  The top cage

caught on the lip of the cage below, pulling it off the forks of the

lift, causing it to fall to the concrete.  also commented

that the establishment plans to retrain the forklift driver to

prevent future incidents

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 89

EstNbr EstName Task_Code MOI# Date Description

P165H OK

FoodsProcessing

Plant

04C05 DAF13140

65203G

2017-06-03 6-3-17 OK Foods, Inc. PO Box 158 1000 Old Pike Road 

Heavener, OK 74937 At approximately 0659 on 6/3/17, while

observing cages being dumped as part of a good commercial

practice task, I observed a chicken resting between the incoming

track and the exit track of the cage dumper.  The employee

operating the cage dumper continued to dump chickens as the

bird squatted between the tracks.  Incoming cages passed the

chicken on one side and outgoing cages passed the chicken on

the other side.  The chicken became excited as the doors of an

exiting cage were closed and the chicken moved onto the track

in front of the cage.  The chicken was then pushed along in front

of the cage until the point that it became crushed between the

cage and the end stop plate at the exit end of the cage dumper

track.  I immediately notified 

 of my observation and discussed the incident at

approximately 0850 with 

  Later in the shift I discussed the incident again

with .  She informed me that the employee operating

the cage dumper was unaware that a chicken was on the

equipment because he was unable to see it from his vantage

point.  I explained that the establishment may need to consider

placing a mirror on the cage dumper so the employee can

visualize this area.

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 90

EstNbr EstName Task_Code MOI# Date Description

P165H OK

FoodsProcessing

Plant

04C05 DAF22070

80704G

2017-08-04 At approximately 0505 on Friday, August 04, 2017, while

performing a good commercial practice check in the live hang

room I observed the following.  An employee hanging live

chickens on line 2 was repeatedly using excessive force to place

the birds in the metal shackles.  The force being applied was

such that I was easily able to hear the metal shackles banging

loudly against the metal guide bar as the employee used a rapid

downward motion to force the birds into the shackles.  After

observing this same forceful technique used several times, I

immediately proceeded to the cage dumper and motioned for

the operator to cease dumping cages of live birds onto the

transfer conveyor.  I then attached US reject tag B37528025 to

the dumper and requested that a supervisor come to the area. 

Shortly thereafter, I met with 

 and and

notified them of my observation.  explained that all

of the night shift contract live hangers had received training on

animal welfare.  The live hanger who had been using excessive

force had been removed from the live hang room and would not

be allowed back on the premises ever again.  The remaining

contract hangers would all receive additional animal welfare

training.  At that point I released regulatory control of the cage

dumper.  A short time later I toured the live hang room again

and observed all employees using the appropriate hanging

techniques.

(b) (6)

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 91

EstNbr EstName Task_Code MOI# Date Description

P165S OK Foods, Inc. 04C05 LWA22190

64121G

2017-06-21 On 6/21/2017 at about 1645 hours I had gone out to the

hanging dock to complete a GCP task. I saw cages of birds on

the line ready to go to the dumper. There were two cages in the

hypobaric chamber and two cages sitting on the end of the line

sitting in the sun. At about 1715 hours I noticed that birds

were being dumped into the hopper ready to go into the live

hang area. Two cages of birds were dumped into the hopper and

another was ready to be dumped on top of those. The birds

were stacked two deep in the hopper causing them to stand on

top of each other. The misters were not on and the birds were

noticeably in distress. I called up to the top of

the stairs so that he could see what was happening. I told him

that the birds were stacked two deep in the hopper and there

were no misters on. He told me that he would get maintenance

to get a hose and fix the misters. The birds were in the hopper

five minutes before hanging started. When I went inside the

hanging room I saw that there were several DOAs being thrown

away from the birds that had been sitting in the hopper. I

counted about 30 DOAs. I told about what I had seen

before start up and informed him that the birds could not be

piled so high in the hopper. He said that he would take care of

the situation. I also told of my concerns about the

birds in the cages sitting on the line in the sun during break.

They do not have misters nor fans and the sun it shining directly

on the cages. He said that from now on he would make sure the

lines are clear when they go to break so that birds are not left in

the sun. 

(b) (6) (b) (6)(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 92

EstNbr EstName Task_Code MOI# Date Description

P165S OK Foods, Inc. 04C05 LWA44160

85507G

2017-08-07 At approximately 1512 on Monday August 7, 2017 I, 

, was in the Live Hang Room preforming a GCP Task.  As I

observed the hangers I noticed that live chickens were

continuously getting to the bar at the end of the belt and

crowding up against it.  After I had been watching for a couple

of minutes, I observed a healthy, alert chicken fall off of the end

of the belt into a condemn barrel.  There were 2 condemn

barrels side by side under the end of the live hang belt.  The

employees ignored the chicken in the barrel.  I asked the

employee on floor duty to request either the Supervisor, or the

Lead to come to the area for me.  He nodded yes, but went

directly to the 2 barrels at the end of the belt instead and

looked in them.  The employee pulled 1 live chicken out of the

right barrel and placed it back up onto the belt, then pulled a

dead chicken out, pulled the head off of it and placed it into

another barrel on the side.  Then he pulled 3 live chickens out of

the left side barrel.  The employee then went to get

management.  The Lead and the other employee that works in

the office came downstairs.  Immediately the Lead checked the

condemn barrels at the overhead door that were full of dead

chickens to see if any were moving while the other employee

moved both barrels away from the end of the belt and checked

in them.  Only then did the Lead approach me.  I told him the

situation, then I returned to the USDA Office and notified 

 then went and found 

 and notified her of the happenings and that this MOI

would be issued.

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 94

EstNbr EstName Task_Code MOI# Date Description

P170 Wayne Farms 04C05 IAA541309

1622G

2017-09-22 September 15, 2017 To:  Matthew Wooten, Plant Manager 

From:  Re:  MOI of Incident on

9/15/2017 On today, September 15, 2017 at approximately

5:25pm, I observed a large number of birds piled up on the belt

entering into the plant approximately 2.0 ft high.  It was later

determined that during that time approximately 300 birds were

smothered on the belt.  I spoke with the 

 approximately 6:15pm who informed me that

the regular cage dumper was absent and the person filling in

was trained but made a mistake with the controls and dumped

2 cages on the belt resulting in the pile up.  The immediate

corrective action was to stop operations and remove birds from

the pile up as quickly as possible. I informed him that I would be

documenting this incident in a Memorandum of Interview

(MOI).  I am aware of your staffing shortages which results in

use of persons not completely familiar with the job they are

performing.  This does not negate you clearly understooding

that live poultry MUST be treated in a manner consistent with

good commercial practices at all times. FSIS’s systemic

approach to slaughter means the ”establishments focus(es) 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”. In this incident

today, this was not observed. This is the 2nd MOI today; the

first one IAA21120900151 given earlier in the 1st shift,

documented by .  This MOI will be forwarded to

the District Office and the District Veterinary Specialist (DVMS)

in case additional follow-up is recommended. Repeated

incidents could result in further enforcement action.

P17340 Pilgrim's 04C05 UQB25030

52029G

2017-05-29 At approximately 2:45am, on 5-28-2017, while performing the

Poultry Good Commercial Practices task, I found one live bird in

the DOA dumpster on the "old side".  The bird was resting

between birds that had been sprayed with denaturant but did

not have denaturant on it. I notified 

 retrieved the bird.  I then informed

 the .The

establishment's program failed to segregate a live bird from the

dead birds.  Without USDA-FSIS intervention, the

establishment's plan would have failed to prevent a bird from

dying by means other than slaughter.

(b) (6)

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 95

EstNbr EstName Task_Code MOI# Date Description

P17340 Pilgrim's 04C05 UQB42140

64513G

2017-06-13 On 06/12/2017 at approximately 1210 hours while performing

a good commercial practices verification task, I observed a very

large accumulation of comingled dead, moribund, and live birds

at the convergence of the cage dump conveyor and live hang

conveyor belts which had obstructed the latter, and

accumulated to the point that the birds on the incline line were

dragging across the accumulation of birds on the live hang

conveyor belt as they advanced up the line.  I also noted that

despite the aforementioned obstruction that establishment

personnel continued to hang live birds.  I verbally notified .

, of the aforementioned

obstruction.  subsequently attempted to address

the aforementioned obstruction, whereby I observed live and

moribund birds struggling to breathe, and suffocating

underneath the carcasses of the dead.  

, was also notified of the aforementioned

issue. Several minutes later, I observed a very large

accumulation of dead birds on the opposite side of the live hang

conveyor belt which had been thrown off the conveyor and onto

the floor by the live hangers.  The aforementioned accumulation

of birds was so substantial so as to impede my passage behind

the live hangers on that side of the table. Upon closer inspection

of the aforementioned accumulation of birds with a flashlight, I

immediately observed two live birds partially entrapped within

the accumulation of dead birds. Upon inspection of the fans

on the west and east sides of the truck unloading dock (old

side), 3/7 and 2/7 fans, respectively, were non-functional. 

 and I noted that the birds were panting

heavily. Upon observing the cage dumper platform (old side), I

noted that the large fans suspended above the cage dumper and

the cage dumper conveyor belt were nonfunctional.  Upon

further inspection of the live hang conveyor belt (at

approximately 1400 hours), I observed a large, rigid white

plastic divider in the middle of the live hang conveyor belt

(oriented perpendicular to the belt) running throughout its

length, which had effectively narrowed its width by half (plastic

divider installed secondary to the current non-operational status

of line 1).  I also noted that additional, poorly secured white

plastic divider components had been installed at an angle, at the

origin of the live hang conveyor belt, to funnel birds onto the

live hang conveyor belt. Hence, birds falling off the cage dump

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 96

EstNbr EstName Task_Code MOI# Date Description

conveyor belt and onto the live hang conveyor belt are being

funneled into a narrow area (choke point) resulting in

congestion and heaping of birds on the belt to the extent that

birds on the incline line are dragging across the top of them.

Upon further observation, and I also noted

that the feet of birds were being caught between the divider and

the live hang conveyor belt, and that one bird was entrapped in

the aforementioned equipment by its wing. 

 subsequently freed the bird from its entrapment. 

, was verbally notified of

the aforementioned. Federal Register Notice Docket No.

#04-037N dated September 28, 2005, "Treatment of Live

Poultry Before Slaughter," encourages those involved in the

slaughter of poultry to abide by Good Commercial Practices.  A

copy of this MOI will be forwarded to the District Office and to

the District Veterinary Medical Specialist in case additional

follow-up is recommended.  Respectfully, 

(b) (6)

(b) (6)

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(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 97

EstNbr EstName Task_Code MOI# Date Description

P17340 Pilgrim's 04C05 UQB07100

91809G

2017-09-09 Est. P-17340, Pilgrim's, August 28, 2017, 1457 hours. Those in

attendance: 

 On 8/28/17 at

approximately 2:57 PM while observing conditions in the old

side live hang department, I observed multiple chickens with

their toes trapped underneath the live hang conveyor belt

divider. I did not observe any amputated toes, but the toes were

entrapped to the point that live hang personnel had to pull

some of the birds' feet out from underneath the divider. This

divider was installed after evisceration line 1 operations ceased,

and this divider's purpose is to direct birds to one side of the live

hang conveyor belt. Upon observance of this mistreatment, I

advised to stop the live

hang conveyor belt. I discussed this mistreatment with

 and he advised maintenance

personnel to remove the divider. At 3:02 PM after removal of

the divider, I advised that

the live hang conveyor belt could be re-started and operations

resumed. Plant management decided to permanently remove

the divider on 8/29/17 after divider modifications did not

prevent further mistreatment. Poultry must be handled in a

manner that prevents needless injury and suffering. Employing

humane methods of handling and slaughtering increases the

likelihood of producing unadulterated product. I 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. Respectfully, 

Pilgrim's P-17340

(b) (6)

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 98

EstNbr EstName Task_Code MOI# Date Description

P17766 Southern Hens,

Inc

04C05 SSN341304

5311G

2017-04-11 Good Commercial Practices MOI: On April 11,

2017 @ approximately 0905 hours, I observed a less than good

commercial practice while performing Ante-mortem

inspection and a Good Commercial Practices check at

Establishment P-17766. While performing a 500 bird count, I

saw a live, non-stunned and uncut bird enter the scalder.  This

was the result of two birds having been hung together in one

shackle. The other bird in the shackle was dead from a proper

cut to the neck before entering the scalder.  

 and 

 were immediately notified of this finding.  In

accordance with FSIS Docket No. 04-037N, Treatment of Live

Poultry before Slaughter, live poultry must be handled in a

manner that is consistent with good commercial practices. In

order for this to occur, poultry must be treated in a manner that

will minimize excitement, discomfort and accidental injury

throughout processing.  A copy of this Memorandum of

Interview will be sent to the Jackson District Office for further

review.  Thanks for your attention to this matter. Respectfully, 

P17766 Southern Hens,

Inc

04C05 SSN081304

5524G

2017-04-24 Good Commercial Practices MOI: On April 24,

2017 @ approximately 0838 hours, I observed a less than good

commercial practice while performing Ante-mortem

inspection and a Good Commercial Practices check at

Establishment P-17766. While performing a 500 bird count, I

saw a live, non-stunned bird enter the scalder.  The bird was

flapping and attempting to right itself.  As it entered and

traveled half the length of the first scalder, the bird jerked

violently, while lifting itself until it was no longer in my

immediate sight.  

was immediately notified of this finding.  In accordance with

FSIS Docket No. 04-037N, Treatment of Live Poultry before

Slaughter, live poultry must be handled in a manner that is

consistent with good commercial practices. In order for this to

occur, poultry must be treated in a manner that will minimize

excitement, discomfort and accidental injury throughout

processing.  A copy of this Memorandum of Interview will be

sent to the Jackson District Office for further review.  Thanks for

your attention to this matter. Respectfully, 

(b) (6)

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 99

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P17766 Southern Hens,

Inc

04C05 SSN061707

2624G

2017-07-24 On July 24, 2017 at ~1640 hours, I observed a less than good

commercial practice while performing and Ante-mortem and

Good Commercial Practices (GCP) check at P-17766. While

performing the GCP on the back dock, I noticed a bird pinned

beneath the unloading conveyer and a coop.  Only half of the

bird was visible due to bobbing from the constant pulling and

releasing action as the coops rolling over its body.  I

immediately alerted ,

 and

 of this

unacceptable practice.  Upon removal of the coop covering the

bird, I noticed a slight movement.  Examination revealed

that there was golf-ball sized hole in the middle of its chest that

extended deep enough to allow viewing of the internal organs. 

The bird was also blinking and attempting to lift his head.  In

accordance with FSIS Docket No. 04-037N, Treatment of Live

Poultry before Slaughter, live poultry must be handled in a

manner that is consistent with good commercial practices. In

order for this to occur, poultry must be treated in a manner that

will minimize excitement, discomfort and accidental injury

throughout processing.  A copy of this Memorandum of

Interview will be sent to the Jackson District Office for further

review.  Thanks for your attention to this matter. Respectfully, 

P18414 MB Consultants

LTD

04C05 JYI5211045

513G

2017-04-13 On 4/11/2017 I observed in the area before the plucker 24

broken wings out of 500 total birds that passed by. On

4/12/2017 when I asked for the animal welfare guidelines they

stated they didn’t have one.  I discussed with the plant that

broken wings are considered mistreatment and are more likely

to result in the birds being adulterated during processing, which

is not following good commercial practices.  Following animal

welfare guidelines would be more likely to result in good

commercial practices than not having any guidelines at all. 

Mishandling birds and creating 24 broken wings on 500 birds is

not good commercial practice.  Failure to follow good

commercial practices could result in further regulatory action

being taken

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 100

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

04C05 QNA24100

41527G

2017-04-27 On April 27, 2017 at approximately 0905, 

 observed less than Good Commercial Practices while

performing an Ante-Mortem Inspection and Good Commercial

Practices check at 18557 P in Summit, MS. While observing the

kill machine of each picking line for proper function, I did not

observe any abnormality in the equipment's operation. I walked

to the end of the blood trough to observe for any live birds

entering the scalder. I observed a single, live  bird at 0905 enter

the scalder on picking line #1. The bird was hanging on the

shackle with its eyes open, still breathing, and without a cut on

its neck. This bird entered the scalder alive and still breathing.  I

did not take any regulatory action with this single-bird incident,

since no evidence of a system failure existed. I notified

, of the observed

nonconformance, during a brief meeting held in his office at

approximately 0910. I presented the cadaver to him, explained

my observation, informed him that a Memorandum of

Information (MOI) was going to be documented, and

relinquished the carcass into his control. FSIS Docket No.

04-037N, Treatment of Live Poultry before Slaughter, states that

under the Poultry Products Inspection Act (PPIA) and Agency

regulations, live poultry must be handled in a manner that is

consistent with good commercial practices. In order to ensure

that poultry is handled and slaughtered in a manner that is

consistent with good commercial practices, poultry should be

treated in such a manner as to minimize excitement, discomfort,

and accidental injury throughout processing. A copy of this

Memorandum of Information will be forwarded to the

appropriate personnel in the Jackson District Office. 

Respectfully, cc: 

, and Mr. Don

Coley, Jackson DDM.

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 101

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

04C05 QNA18110

53715G

2017-05-15 On May 15, 2017 at approximately 1045, 

 observed less than Good Commercial Practices while

performing an Ante-Mortem Inspection and Good Commercial

Practices check at 18557 P in Summit, MS. While observing the

kill machine of each picking line for proper function, I did not

observe any abnormality in the equipment's operation. I did

observe that a new employee was backing the kill machine on

line #2.  I walked to the end of the blood trough to observe for

any live birds entering the scalder. I observed a single, live  bird

at 1045 enter the scalder on picking line #2. The bird was

hanging on the shackle with its eyes open, still breathing, and

without a cut on its neck. This bird entered the scalder alive and

still breathing.  I did not take any regulatory action with this

single-bird incident, since no evidence of a system failure

existed. I notified , of

the observed nonconformance, during a brief meeting held

in his office at approximately 1050. I presented the cadaver to

him, explained my observation, informed him that a

Memorandum of Information (MOI) was going to be

documented, and relinquished the carcass into his control. FSIS

Docket No. 04-037N, Treatment of Live Poultry before

Slaughter, states that under the Poultry Products Inspection Act

(PPIA) and Agency regulations, live poultry must be handled in a

manner that is consistent with good commercial practices. In

order to ensure that poultry is handled and slaughtered in a

manner that is consistent with good commercial practices,

poultry should be treated in such a manner as to minimize

excitement, discomfort, and accidental injury throughout

processing.A copy of this Memorandum of Information will be

forwarded to the appropriate personnel in the Jackson District

Office. Respectfully, cc:

 and

Mr. Don Coley, Jackson DDM.

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 102

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

04C05 QNA02110

64712G

2017-06-12 On June 12, 2017 at approximately 1049 while performing a

GCP task in the and 

 observed less than Good Commercial Practices.  A

weak, moribund bird was observed lying in the vat of DOA birds

located in the live receiving/cage dumper area.  The bird had a

very shallow and labored  respiratory movement.  Two

employees were in the act of throwing more DOAs into the vat. 

This action would have certainly smothered the debilitated bird

with the additional weight, since the bird could not right itself

and escape.  A new employee in the Management Trainee

Program was informed of our observation. He removed the live

bird, before any more DOAs were deposited into the vat, and

replaced it on the hanging belt. We discussed the incident with

, at about 1055.  He

immediately communicated with 

  in an effort to prevent future incidents.  As per

Federal Register Notice Docket No. 04-037N Treatment of Live

Poultry before Slaughter, states that under the Poultry Products

Inspection Act (PPIA) and Agency regulations, live poultry must

be handled in a manner that is consistent with good commercial

practices.  In order to ensure that poultry is handled and

slaughtered in a manner that is consistent with good

commercial practices, poultry should be treated in such a

manner as to minimize excitement, discomfort, and accidental

injury throughout processing.  A copy of this Memorandum of

Information will be forwarded to the appropriate personnel in

the Jackson District Office. Respectfully, 

cc: 

 and Mr. Don Coley, Jackson DDM

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

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 103

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

04C05 QNA01120

61222G

2017-06-22 On June 22, 2017 at approximately 1041 while performing a

GCP task in the 

 observed less than Good Commercial Practices.  A weak,

moribund bird was observed lying in the vat of DOA birds

located in the live receiving/cage dumper area.  The bird had a

very shallow and labored respiratory movement.  I immediately

stopped the employee from throwing more DOAs into the vat. 

This action could have led to smothering the debilitated bird

with the additional weight, since the bird could not right itself

and escape.  He removed the live bird, before any more DOAs

were deposited into the vat, and replaced it on the hanging

belt. I discussed the incident with 

 at about 1056,  in an effort to prevent future

incidents.  As per Federal Register Notice Docket No. 04-037N

Treatment of Live Poultry before Slaughter, states that under

the Poultry Products Inspection Act (PPIA) and Agency

regulations, live poultry must be handled in a manner that is

consistent with good commercial practices.  In order to ensure

that poultry is handled and slaughtered in a manner that is

consistent with good commercial practices, poultry should be

treated in such a manner as to minimize excitement, discomfort,

and accidental injury throughout processing.  A copy of this

Memorandum of Information will be forwarded to the

appropriate personnel in the Jackson District Office. 

Respectfully, cc: 

, and Mr. Don

Coley, Jackson DDM

(b) (6)

(b) (6)(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 104

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

04C05 QNA12120

75613G

2017-07-13 On July 13, 2017 at approximately 1155 while performing a GCP

task in the  observed less than

Good Commercial Practices.  A weak, moribund bird

was observed lying in the vat of DOA birds located in the live

receiving/cage dumper area.  The bird had a very shallow and

labored respiratory movement.  One bird was laying on top of

this bird, further hindering its respiratory activity. No supervisor

was immediately available to discuss this matter, so I removed

the bird from the vat and returned it to the live receiving

conveyor.  Addition of more birds to the vat could have led

to smothering the debilitated bird with the additional weight,

since the bird could not right itself and escape.   I discussed the

incident with , and

 at about 1202,  in an

effort to prevent future incidents.  As per Federal Register Notice

Docket No. 04-037N Treatment of Live Poultry before Slaughter,

states that under the Poultry Products Inspection Act (PPIA) and

Agency regulations, live poultry must be handled in a manner

that is consistent with good commercial practices.  In order to

ensure that poultry is handled and slaughtered in a manner that

is consistent with good commercial practices, poultry should be

treated in such a manner as to minimize excitement, discomfort,

and accidental injury throughout processing.  A copy of this

Memorandum of Information will be forwarded to the

appropriate personnel in the Jackson District Office. 

Respectfully, cc: 

, and Mr. Don

Coley, Jackson DDM

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

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 105

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

04C05 QNA11110

73318G

2017-07-18 On July 18, 2017 at approximately 1044 while performing a GCP

task in the Live Receiving area,  observed less than

Good Commercial Practices.  A weak, moribund bird

was observed lying in the vat of DOA birds located in the live

receiving/cage dumper area.  The bird had a very shallow and

labored respiratory movement.  Several birds were laying on

top of this bird, further hindering its respiratory activity. I

notified , about the

observed nonconformance.  He came to the DOA vat, removed

several dead birds from the top of the vat, in order to find the

live bird, and removed the live bird from the DOA vat, in order

to return it to the live receiving conveyor.  The addition of more

birds to the vat could have led to smothering the debilitated

bird with the additional weight, since the bird could not right

itself and escape.   I also discussed the incident with 

  in an effort to prevent future

incidents.  As per Federal Register Notice Docket No. 04-037N

Treatment of Live Poultry before Slaughter, states that under

the Poultry Products Inspection Act (PPIA) and Agency

regulations, live poultry must be handled in a manner that is

consistent with good commercial practices.  In order to ensure

that poultry is handled and slaughtered in a manner that is

consistent with good commercial practices, poultry should be

treated in such a manner as to minimize excitement, discomfort,

and accidental injury throughout processing.  A copy of this

Memorandum of Information will be forwarded to the

appropriate personnel in the Jackson District Office. 

Respectfully, cc: 

 and Mr. Don

Coley, Jackson DDM

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 106

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

04C05 QNA32090

72025G

2017-07-25 On July 24, 2017 at approximately 1043 while performing a GCP

task in the Live Receiving area,  observed

less than Good Commercial Practices. I observed a bird with a

normal respiratory movement, eyes open and very alert, lying in

the vat of DOA birds located in the live receiving/cage dumper

area.  I immediately had an employee to come to the DOA vat,

remove the live bird, in order to return it to the live receiving

conveyor belt.  This action could have led to smothering the

fully alert bird if additional weight would have been added to

the DOA vat, since the bird could not right itself and escape.  I

discussed the incident with 

 at about 1059,  in an effort to prevent future

incidents.  As per Federal Register Notice Docket No. 04-037N

Treatment of Live Poultry before Slaughter, states that under

the Poultry Products Inspection Act (PPIA) and Agency

regulations, live poultry must be handled in a manner that is

consistent with good commercial practices.  In order to ensure

that poultry is handled and slaughtered in a manner that is

consistent with good commercial practices, poultry should be

treated in such a manner as to minimize excitement, discomfort,

and accidental injury throughout processing.  A copy of this

Memorandum of Information will be forwarded to the

appropriate personnel in the Jackson District Office. 

Respectfully, cc: 

, and Mr. Don

Coley, Jackson DDM

(b) (6)

(b) (6)

(b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 107

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

04C05 QNA14060

92806G

2017-09-06 On September 6, 2017 at approximately 0532 while performing

a GCP task in the Live Receiving area,  observed less

than Good Commercial Practices.  A weak, moribund bird

was observed lying in the vat of DOA birds located in the live

receiving/cage dumper area.  The bird had a very shallow and

labored respiratory movement.  Several birds were laying on

top of this bird, further hindering its respiratory activity. I

notified , about the

observed nonconformance.  He came to the DOA vat, removed

the live bird from the DOA vat, and returned it to the live

receiving conveyor.  The addition of more birds to the vat could

have led to smothering the debilitated bird with the additional

weight, since the bird could not right itself and escape.   I also

discussed the incident with 

,  in an effort to prevent future incidents.  As per

Federal Register Notice Docket No. 04-037N Treatment of Live

Poultry before Slaughter, states that under the Poultry Products

Inspection Act (PPIA) and Agency regulations, live poultry must

be handled in a manner that is consistent with good commercial

practices.  In order to ensure that poultry is handled and

slaughtered in a manner that is consistent with good

commercial practices, poultry should be treated in such a

manner as to minimize excitement, discomfort, and accidental

injury throughout processing.  A copy of this Memorandum of

Information will be forwarded to the appropriate personnel in

the Jackson District Office. Respectfully, 

 cc: 

 and Mr. Don Coley, Jackson DDM

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 108

EstNbr EstName Task_Code MOI# Date Description

P19112 Perdue Foods

LLC

04C05 OXA34220

94913G

2017-09-13 At 0031 on 9-13-17, while performing a Poultry GCP task, I

observed the DOA Cage area.  This area is in a room that is

separate from the Live Hang room.  There were approximately 4

or 5 live birds in the cage area.  I noticed movement coming

from under the pile of birds under the belt for Line 2.  I went in

the cage and removed a couple of live birds from the top and

the periphery of this pile.  I pulled one bird from under the pile. 

It was still breathing but unresponsive.  As I was searching

through the pile for more buried live birds, dead and live birds

were dropping onto the pile.  When 4 live birds dropped in

succession, I left the DOA room in search of assistance.  

 met me in the DOA room.  I

informed him that I had observed the pile under the belt moving

or “jumping” and had pulled out some partially covered birds

and one bird from below the others.  I informed him the bird

had been breathing but unresponsive and that several live birds

had fallen off the belt while I was trying to sort through the

dead ones. I stated that I would be documenting this with a

MOI as there did not seem to be an adequate measure to keep

the live birds out of the DOA cage and becoming covered by

dead birds.  It is reasonable to conclude that said covered birds

would eventually be crushed or smothered by the falling birds

and, as such, would die by means other than slaughter. 

 proffered to retrieve the gates that go on the ends of

the live hang belts and bolt them on as a preventative/corrective

measure.  He assured me they would remain on.

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 109

EstNbr EstName Task_Code MOI# Date Description

P19128 Case Farms of

North Carolina,

Inc.

04C05 FCA290603

4411G

2017-03-11 At P19128, Case Farms of North Carolina, Inc. on 3/11/17:  At

approximately 0712, while performing a Good Commercial

Practices verification I proceeded to the DOA dumpster located

outside the live hang area to determine whether any live birds

were present.  Upon looking into the dumpster, which was

about 1/2 full, I observed a live bird on it's back lying amongst

the dead birds and noted the bird was experiencing respiratory

difficulty.  I then noticed a second bird that was partially under

dead birds that was experiencing more respiratory difficulty

than the first.  Shortly after this observation 

 was observed in the area so I

obtained his attention and summoned him to the dumpster to

demonstrate the live birds.  retrieved both birds

from the dumpster and I notified him that I would be

documenting a MOI.  protested and requested

that I "give him a break" and not document the issue.  I

informed that I would be issuing the MOI as the

live hang personnel should be able to properly identify a live

bird by determining whether or not they are still breathing and

at that point in the process, i.e. the DOA bin, this determination

has failed.  I then proceeded back to the inspection office and

left a voice mail for regarding

the incident.  Shortly thereafter I notified Plant Manager Reuben

Mayronne of the observation.  Mr. Mayronne said he would go

to live hang to talk with .  According to plant

management personnel received disciplinary action and were

re-trained on proper identification of live birds to ensure they do

not go into the DOA bin.

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 110

EstNbr EstName Task_Code MOI# Date Description

P19128 Case Farms of

North Carolina,

Inc.

04C05 FCA000007

5522G

2017-07-22 At 22:00 while during an observation of the Live hang area, I

observed an excessive amount of birds on the floor in the

hanging room. Some were alive, however, most of them

appeared to be DOAs. Two employees were picking up the birds

and throwing them through an opening on the back wall of Live

Hang area. This opening leads to the DOA bin. At 22:08 after

observing the Live hang employees I decided to examine the

DOA bin. I observed a live bird in the DOA Bin laying on its back

with another bird on top of it.  I immediately notified 

, of my findings.  By the time I

located the Supervisor and arrived back to the bin, denaturant

had been applied on the birds, including the live bird. The

live bird was removed from the DOA bin by the Live Hang

Supervisor, killed by breaking the neck, and placed back into the

DOA bin once it was dead.  apologized for the

incident and stated that he was working with a short staff.  He

stated that numerous DOAs were dumped on the belt at one

time and the employees had been working hard to sort through

the birds.  He ensured me that an incident of this sort would not

happen again.  also stated that he would monitor the

DOA bin, himself, for the rest of the night.  This issue was also

discussed with, Steve Ritchie, the Plant Manager on night shift. 

 informed me that plant employees will break the

neck, i.e. utilize cervical dislocation, of moribund birds from now

on. Once the bird dies, employees will also remove the heads

before throwing the birds into the DOA bin.

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 111

EstNbr EstName Task_Code MOI# Date Description

P19128 Case Farms of

North Carolina,

Inc.

04C05 FCA140809

5515G

2017-09-15 At approximately 0615 one of the line inspectors in 1st

processing request for me to come their inspection station.  The

inspector showed me three DOA’s they had just condemned

while performing postmortem inspection.  I went to live hang

area to notify ) but at that

particular time he wasn’t available.  I notified my supervisor 

 of the situation and then return to

evisceration to give inspector breaks at which time the inspector

told me they had gotten three more DOA’s.  At this time Reuben

Mayronne (plant manager) was coming through evisceration

when he observed the three DOA’s that had been hung back by

the inspector and I told him of other DOA’s that had been

condemn.  He immediately notified the live hang supervisor of

the excessive amount of DOA’s observed.  During the time 

 and I was giving breaks we each had observed

approximately 6 or 7 more DOA’s on the line.  After 

and I finished giving breaks we went to the live hang dock. 

While I was standing behind the backup killer observing the

process the backup killer pulled three DOA’s off the line. While

 was observing in the live hang room, the hangers

hung approximately 5 or 6 DOA’s on the kill line.  We observed

approximately 20 + DOA’s either being hung on the line in live

hang or reaching the inspection stations in evisceration in a 30

to 40 minute time span. This MOI is a failure of the plant to

follow their training procedure for handling live young chickens

in processing plant, which states that DOA’s should be identified

and removed to the floor, which will be collected into barrels in

a timely manner at the end of each lot or more frequently as

required. At one point stopped the line for

a couple of minutes to talk with his live hang employees about

hanging DOA’s on the line. The observance of DOA's was

discussed in the weekly HACCP meeting and plant management

said they would investigate the situation.

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 112

EstNbr EstName Task_Code MOI# Date Description

P192 Pilgrims Pride

Corporation

04C05 OOB00180

10706G

2017-01-06 Today 1/6/17 while performing a check for Good Commercial

Practices at 1520 I found unacceptable conditions in live

receiving. On the floor at the end of the Line 2 hanging belt

there was a DOA pile of carcasses that was too large and not

being managed in a timely manner.  I notified 

 and that the floor

employees were not taking care of the DOA pile properly. I

returned to live receiving with the Supervisor to watch as they

picked up carcasses and performed manual decapitation and

disposal in a condemn barrel.  As they progressed through the

pile, two birds were observed to move when picked up. One bird

was barely alive. The second bird was very alert, eyes blinking.  I

informed that a GCP MOI would be issued for

allowing live birds to be co-mingled with dead birds, and further

putting them at risk of dying by way of smothering from the

weight of birds on top of them in the DOA pile. We discussed

today’s weather conditions, which was extreme cold weather

and chance of snow. The establishment had already noted an

increase in DOA numbers related to the weather.

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 113

EstNbr EstName Task_Code MOI# Date Description

P192 Pilgrims Pride

Corporation

04C05 OOB02140

10018G

2017-01-18 On Wednesday, January 18, 2017 at approximately 0715 hour, I

observed less than Good Commercial Practices. While

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed approximately 10 birds loose under

the area where the cages are dumped onto the belts in the

outside region to enter the building into live hang.  The plant

was leaving for break at this time while the birds were still

loose.  It took approximately four minutes to locate

establishment personnel to inform of the loose birds.  The birds

were caught and placed in a pen on top of the belt on line two

in the outdoor region that would enter into live hang.  The

employee that caught the birds put them in the pen and then

returned to his break.  I noticed one of the birds was dorsally

recumbent with its feet outstretched in the air.  I moved closer

to examine the bird further.  The bird appeared weak/unable to

right itself, several other birds were sitting on its head, its

breathing was very slow and shallow.  I attempted to find

establishment management to inform them of the bird’s

condition so it would not die via suffocation/means other than

slaughter.  It took approximately three minutes to locate

establishment personnel.  I asked him to come with me and

showed him the bird.  I informed him that this was not good

and the bird was going to die by means other than slaughter if

not attended to.  He got a plant employee to come and turn the

bird back over and then had the employee resume his break.  He

also stated that the employee that he had come out to “right”

the bird knew how to properly put the birds in the pen and he

would have him inform everyone else how to do so properly and

that this should not happen.  I informed him that the employee

that he was referring to was the one that had placed the bird in

the pen originally.  He then stated that he knew better.  The

weak/moribund bird was then left in the pen with the

remainder of the birds.  The establishment was notified of the

incident and informed of the resulting MOI.  As per Federal

Register Notice Docket No. 04-037N dated September 28, 2005,

“Treatment of Live Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good Commercial Practices

(GCPs) as described by industry guidelines. My observations

are consistent with less than good commercial practices. A
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 114

EstNbr EstName Task_Code MOI# Date Description

copy of this Memorandum of Interview will be forwarded to

appropriate personnel in the District Office.  Respectfully

submitted on January 18, 2017 Cc:

         DDM                 DVMS                 FLS

P192 Pilgrims Pride

Corporation

04C05 OOB07070

11130G

2017-01-30 On January 28, 2017, at approximately, 1200 I went into the

live receiving area.  There were over 100 dead on arrival (DOA)

birds piled up on the floor in the live receiving area.  Upon

taking a closer look with a flashlight, I saw a bird that was in

imminent danger of being crushed or smothered at the bottom

of the pile still flapping its wings.  There was only one plant

employee handling the DOA birds.  I immediately made this

particular employee aware of the live bird and he proceeded to

euthanize it by disarticulation of the neck.  At 1100, 

had gone into the live receiving area and noted five

employees handling the DOA birds.  At 1150, 

informed plant management that the number of DOA birds on

the floor was still significantly high and needed to be corrected. 

At 1230, checked on the condition of the

live receiving area and noted that there were still over 100 DOA

birds present and only one employee handling them.  Federal

Register 04-037N encourages those involved in the slaughter

poultry to abide by Good Commercial Practices.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 115

EstNbr EstName Task_Code MOI# Date Description

P192 Pilgrims Pride

Corporation

04C05 OOB09160

75713G

2017-07-13 On Thursday, July 13, 2017 at approximately 1511 hour, while

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed one young chicken, with an uplifted

head, pupillary reflexes, rhythmic breathing and no cut to the

neck entering the scald tank that feeds evisceration line #2

 was immediately notified. 

Live bird(s) entering the scald system is a less than Good

Commercial Practices and results in adulterated product. The

establishment is responsible for ensuring that birds under their

control on the official premises are treated in a humane manner

that will minimize excitement, discomfort, injury and/or death

by means other than slaughter. My observations are consistent

with less than good commercial practices. As per Federal

Register Notice Docket No. 04-037N dated September 28, 2005,

“Treatment of Live Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good Commercial Practices

(GCPs) as described by industry guidelines.  A copy of this

Memorandum of Interview will be forwarded to appropriate

personnel in the District Office.  Respectfully submitted on July

13, 2017 Cc: Dr. David Thompson,

DDM 

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

(b) (6)
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EstNbr EstName Task_Code MOI# Date Description

P192 Pilgrims Pride

Corporation

04C05 OOB52210

72114G

2017-07-14 On Friday, July 14, 2017 at approximately 1744 hour, while

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed a live bird intermingled in a pile with

six other dead birds at the bottom of the slide at the end of the

belt in live hang that feeds evisceration line #1.  Initially upon

entering live hang I saw the pile of birds with movement

towards the bottom of the pile and no establishment employees

were attending to the pile.  Once employees were aware of my

presence they came to attend to the pile of birds.  The dead

birds were removed from the live bird at the bottom of the pile

that was in imminent danger of becoming crushed/suffocating

and dying by means other than slaughter.   The bird was then

put back into production.  

was immediately notified.  The same Supervisor was

spoken with yesterday as well over the concern for numerous

loose birds in live hang and piles of dead birds that were not

attended to until USDA entered the area.  The establishment is

responsible for ensuring that birds under their control on the

official premises are treated in a humane manner that will

minimize excitement, discomfort, injury and/or death by means

other than slaughter. My observations are consistent with less

than good commercial practices. As per Federal Register Notice

Docket No. 04-037N dated September 28, 2005, “Treatment of

Live Poultry before Slaughter,” the Food Safety Inspection

Service (FSIS) strongly encourages all establishments engaged in

the slaughter of poultry to make every effort to treat poultry

humanely and abide by the Good Commercial Practices (GCPs)

as described by industry guidelines.  A copy of this

Memorandum of Interview will be forwarded to appropriate

personnel in the District Office.  Respectfully submitted on July

14, 2017 Cc: Dr. David Thompson,

DDM 

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

(b) (6)
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EstNbr EstName Task_Code MOI# Date Description

P192 Pilgrims Pride

Corporation

04C05 OOB52140

73426G

2017-07-26 On Tuesday, July 25, 2017 at approximately 1726, while

performing a Good Commercial Practices task, I observed a

truckload of birds directly in the sun with no misters or fans. 

Upon closer examination, I observed approximately half of the

birds exhibit labored breathing.  

 was immediately notified.  These observations

are consistent with less than Good Commercial Practices.  It is

the responsibility of the establishment to ensure that all birds

on their premises are treated in a humane manner.  Federal

Register 04-037N encourages those involved in the slaughter of

poultry to abide by Good Commercial Practices.

P19514 Tyson Foods,

Inc.

04C05 UMF01200

13206G

2017-01-06 At approximately 19:45 hours I went to 

 office to perform the weekly record

keeping aspect of the GCP task.  She could not find any data

entry for second shift for the week.  The week's production was

not over yet, but it does cause one to wonder if I had not asked

to see the data if any observations were going to be done for

this week.  I asked to see results from first shift; results were

found for the yard and only one of the lines.  The other line data

was not in the system.  The first shift plant observations were

done on Tuesday of this week.  The plant has had ample time

since Tuesday to recognize that either the observation of line 2

was not done or that the data associated with the observation

was not entered. This raises several questions: 1.) When does

management look at the "Animal Welfare" data?  2.)  Is the data

collected just to have something to show an auditor that the

establishment is "actively" doing something about good

commercial practices?  3.)  If the data collected during a week

shows possible animal abuse and the data is not looked at for

over a week's time, is that possible abuse allowed to continue

during that time?  4.)  In what time frame does the

establishment react to the input?  5.)  How can the

establishment state that they are concerned about animal

welfare and will react to abnormal findings when it has

obviously not looked at the data for four days of production?

(b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 118

EstNbr EstName Task_Code MOI# Date Description

P19514 Tyson Foods,

Inc.

04C05 UMF06210

30202G

2017-03-02 On 2/21/2017 at approximately 19:15 hours while performing a

GCP task, I was on the live receiving platform observing the

birds, the cage conditions and the cage dumping process.  The

operator dumped a cage and moved the cage on the transfer

chains about 2/3s of the way and noticed that there were still

two birds in the bottom right compartment of the cage.  He

reversed the travel of the cage several times to position it back

at the dumping area.  He proceeded to start tilting the cage

when I noticed that one of the birds was trapped between the

dumper slides, the door and the bottom of the cage. 

Approximately 1/3 of the bird was visible beneath the cage

door.  I alerted the operator, who lowered the cage and

retrieved the carcass.  A portion of the fresh looking intestines

were dangling between the legs. I immediately notified

 of the situation.  

came to see what was going on and I told him we would talk in

a quieter area.  At 19:30 hours I met with and

 in the Evisceration MCC room.  I

explained to them what I witnessed and that I needed a plan

from them on how to prevent this from happening again.  I did

not get a response that evening. On 2/22/2017 at

approximately 19:44 hours I asked what their

planned actions were and he said they were putting an end to

the practice of moving the cage away from and then back to the

tilting mechanism until guidelines could be established. It

needs to be noted that witnessed a similar incident

in November of 2015.  She wrote a MOI (attached) covering that

incident and the corrective actions (attached) did not prevent

this most recent occurrence.  It appears that the Establishment

has not instituted protocols to prevent this type of action. As

per Federal Register Notice docket No. 04-037N dated

September 28, 2005, “Treatment of Live Poultry before

Slaughter,” the USDA Food Safety and Inspection Service (FSIS)

strongly encourages all establishments in the slaughter of

poultry to make every effort to treat poultry humanely and

abide by good commercial practices (GCP) as described by

industry guidelines. Thank you for your attention in this matter. 

A copy of this memorandum will be forwarded to the DVMS in

the Jackson District Office.

P19514 Tyson Foods,

Inc.

04C05 UMF10230

71813G

2017-07-13 MOI rescinded per DVMS

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

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P20245 Equity Group

Kentucky

Division, LLC

04C05 ISL071609

5428G

2017-09-28 At approximately 1351 hours on September 28, 2017 while

performing the Good Commercial Practices and Ante Mortem

task, the following was observed in live hang.  At the end of the

belt under the shackles that feeds evisceration line #2 there was

a pile of 21 DOA birds that continued to grow.  I observed this

pile for several minutes using a flashlight to determine if any live

birds were present in the pile due to the rapid rate at which

birds continued to accumulate in the pile.  There was movement

seen within the pile of birds under several DOAs.  I could not

locate a supervisor at the time to inform of my observations.  At

approximately 1354 establishment members began clearing the

pile and a live bird was removed from about half way down the

pile and placed back into production.   

was notified of the incident and informed that it would be

documented in a MOI.  It was also discussed that live birds

should not be comingled with DOAs due to imminent danger of

birds becoming crushing and dying by means other than

slaughter. The establishment is responsible for ensuring that

birds under their control on the official premises are treated in a

humane manner that will minimize excitement, discomfort,

injury and/or death by means other than slaughter. As per

Federal Register Notice Docket No. 04-037N dated September

28, 2005, “Treatment of Live Poultry before Slaughter,” the

Food Safety Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely and abide by the Good

Commercial Practices (GCPs) as described by industry

guidelines.  My observations are consistent with less than

Good Commercial Practices. A copy of this Memorandum of

Interview will be forwarded to appropriate personnel in the

District Office.  Respectfully submitted on September 28, 2017

(b) (6)

 Cc: Dr. David Thompson, DDM 

(b) (6)

(b) (6)
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P20251 Tecumseh

Poultry, LLC

04C05 PBM01070

10804G

2017-01-04 On Wednesday, January 4, 2017, I, USDA 

, met with to discuss what

was observed in the loafing shed earlier that day. At 0525 hours

on January 4, 2017 while performing ante-mortem inspection in

the loafing shed, I, observed a dead bird on

trailer T69.  The bird was located on the driver’s side, first

module on the bottom row, 4th level.  There were four broken

wires, approximately 1 inch apart, bent inwards and at an angle

creating an approximately 6 x 5 inch opening on the outside

module panel.  The bird's head was stuck between two of the

broken wires.  The other ten chickens in this module were not

injured.  There was no mark on the module indicating that it

was damaged.  I notified the establishment's 

 what I observed.  The scale operators perform

a Leg/Head Audit on each trailer that enters the loafing shed. 

Trailer T69 arrived at 0100 hours.  The modules are inspected

by establishment and marked if damaged.  As of December 27,

2016, the percentage of damaged modules was 4.5% with the

maximum limit being 5%.  The marked modules are tracked or

removed from service pending on the damage. The

establishment will mark the module as damaged and have it

repaired.  Further investigation will be performed by the

establishment to determine if any other actions need to be

made. The Poultry Products Inspection Act and Agency

regulations (9 CFR 381.65(b)) require that live poultry be

handled in a manner that is consistent with good commercial

practices (GCPs). Compliance with GCPs increases the likelihood

of producing unadulterated product. Poultry are to be handled

in a manner that prevents needless injury and suffering in order

to produce a commercially marketable product.  Establishment

management may review Federal Register notice "Treatment of

Live Poultry Before Slaughter",70 Fed. Reg. 56624 (September

28, 2005) for FSIS recommendations concerning the treatment

of live poultry before slaughter. This MOI will be forwarded to

the District Office and the District Veterinary Medical Specialist

(DVMS) in case additional follow-up is recommended. 

Respectfully,

(b) (6)

(b) (6)

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

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 123

EstNbr EstName Task_Code MOI# Date Description

381.65(b)) require that live poultry be handled in a manner that

is consistent with good commercial practices (GCPs).

Compliance with GCPs increases the likelihood of producing

unadulterated product. Poultry are to be handled in a manner

that prevents needless injury and suffering in order to produce a

commercially marketable product. Establishment management

may review Federal Register notice “Treatment of Live Poultry

before Slaughter”, 70 Fed. Reg. 56624 (September 28, 2005) for

FSIS recommendations concerning the treatment of live poultry

before slaughter. This MOI will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended. Respectfully, 

 Est. P-20251 Tecumseh, NE

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 124

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

04C05 PBM48140

12225G

2017-01-25 On January 19, 2017, I ) met with 

 and to

discuss observations I had made while performing a PHIS Good

Commercial Practices verification task. On January 18, 2017 at

approximately 1140 hours, I observed loose birds on

trailer # T922. A bottom panel door on a lower level battery

crate was open. Two birds were roosting between two battery

crates. As I continued I noticed another panel door opened on a

different battery crate the chickens were all in the battery.  I

notified of the loose chickens. 

 told me she would place the chickens back into battery

cages, and close the open panels. I then notified both my

supervisor and and then arranged a meeting to

discuss these findings. At the meeting, I reviewed my

observations. added that had

observed loose birds earlier this week as well. In that instance,

establishment employees were already present and in the

process of catching a loose bird on the ground underneath the

trailers when arrived at the loafing sheds

 and I both expressed concern about the battery cage

doors popping open. I asked if the establishment

had a program to fix or remove damaged battery crates. 

 replied that the establishment does have a program.

She further stated that this program requires that at least 95%

modules are maintained in acceptable condition, and that the

establishment is meeting that requirement. I followed up and

verified that the Standard Operating Procedure requires

ensuring that at least modules are maintained in a

condition that prevents animal welfare issues. I asked 

 if I could see the establishment’s current reports on the

condition of the battery cages. told me that she

could not show them to me. When I asked why I could not see

them, she replied, “Because we haven’t been receiving them.”

She did not know why the reports were not being received and

added that she would have to “look into that.” The Poultry

Products Inspection Act and Agency regulations (9 CFR

381.65(b)) require that live poultry be handled in a manner that

is consistent with good commercial practices (GCPs).

Compliance with GCPs increases the likelihood of producing

unadulterated product. Poultry are to be handled in a manner

that prevents needless injury and suffering in order to produce a

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

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

(b) (6)

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

(b) (6)

(b) (6)

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

(b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 125

EstNbr EstName Task_Code MOI# Date Description

commercially marketable product. Establishment management

may review Federal Register notice “Treatment of Live Poultry

before Slaughter”, 70 Fed. Reg. 56624 (September 28, 2005) for

FSIS recommendations concerning the treatment of live poultry

before slaughter. This MOI will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended. Respectfully, 

 Est. P-20251 Tecumseh, NE

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 126

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

04C05 PBM19070

14827G

2017-01-27 On January 24, 2017, I ) met with 

 and to

discuss observations I had made while performing a PHIS Good

Commercial Practices (GCP) verification task. On January 23,

2017 at approximately 1230 hours, on trailer #T796 I observed

two QA Tech’s looking at what appeared to be a dead chicken

between two crates. The body of the chicken was located next

to a bottom panel door which had been damaged. The panel

door bowed inward along the top and the corners were bent

down in a dog-eared manner on both sides. This created an

opening of sufficient size to allow a chicken to escape. This crate

was previously marked with yellow tape to identify it as

damaged and in need of repair to restore it to working condition

according to . I followed up later and watched as an

establishment employee segregated the crate in question. 

During the GCP verification task I also observed one chicken

with its leg protruding out of the crate between the floor of the

battery and the bottom wire of the wire frame. The wire was

bent in a way that the chicken was trapped and could not pull

its leg back into the cage. The hock was abraded and bleeding

and the chicken was struggling to get free. I notified the QA

Tech and showed her my findings. The cage was not previously

marked to indicate that it was damaged. An employee freed the

chicken’s leg. Continuing the GCP verification task, I observed

two chickens on the floor near the kill machine. Both were alive

and sensible. One appeared to be bleeding from its head, and on

closer inspection I found that its lower beak and a portion of its

face were cut off. I showed this finding to 

, and asked if she would take care of this injured chicken.

She carried it back to the entrance to the unit and placed it

on the belt.  Furthermore, on January 24, 2017, at 1212 hours,

 found a chicken with its head protruding

from of a battery cage on trailer number T797, through wires

that were bent to allow room for the chicken to stick its head

out. The chicken was now deceased. notified 

 and and showed them his

findings.  He notified , who immediately informed

management. During the discussion of the damaged battery

cages, was adamant that the establishment was in

compliance with its Animal Welfare program, which requires

that at least of the battery cages be in acceptable

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

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

(b) (6)

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

(b) (6)

(b) (4) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 127

EstNbr EstName Task_Code MOI# Date Description

condition. assured that we did not

question that the establishment was in compliance with the

program. Nonetheless, compliance with the program may not

be sufficient to prevent the creation of situations which result in

the mistreatment of birds. During the discussion of the bird

with the mutilated face, suggested that the

establishment may wish to review how it responds to situations

in which inadequate stunning occurs. It is also interesting to

note that the injured bird was on the floor, and was not taken to

until I requested it. The Poultry Products Inspection Act

and Agency regulations (9 CFR 381.65(b)) require that live

poultry be handled in a manner that is consistent with good

commercial practices (GCPs). Compliance with GCPs increases

the likelihood of producing unadulterated product. Poultry are

to be handled in a manner that prevents needless injury and

suffering in order to produce a commercially marketable

product. Establishment management may review Federal

Register notice “Treatment of Live Poultry before Slaughter”, 70

Fed. Reg. 56624 (September 28, 2005) for FSIS

recommendations concerning the treatment of live poultry

before slaughter. This MOI will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended. Respectfully

submitted, 

(b) (6)

 Est. P20251 Tecumseh, NE

(b) (6) (b) (6) (b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 128

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

04C05 PBM05150

40127G

2017-04-27 Good Commercial Practice Mistreatment MOI at Est. 20251P 

 and met with

 at 0815 hours on April 27, 2017

to discuss the mistreatment of young chickens described below:

On April 26, 2017, at approximately 0520 hours, while

performing ante-mortem inspection of birds on Organic trailer

T-15, I, , observed several dead and dying

young chickens.  The young chickens were wet and the outside

temperature was 38 degrees Fahrenheit with an 18 mile per

hour wind speed.  I contacted the 

and requested more information on the trailer. Via

E-mail, informed me that the trailer of birds was

from Iowa.  The trailer arrived to the establishment covered. 

There were 112 DOAs and there were birds from two different

lots on the trailer. I explained to that allowing

birds the die by other means than slaughter is not consistent

with GCPs. will look into it and contact

transportation about it. The meeting was adjourned at 0840

hours.

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

(b) (6)

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

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EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

04C05 PBM56120

65428G

2017-06-28 On 27 June 2017 at 1315 hours, USDA FSIS 

 met with VP Operations Mr. Erik Monson and 

 upon request

from the establishment. The establishment does not believe

that the birds with red skin and red muscle being condemned

are cadavers.  They had a similar issue back in 2013.  By meeting

with the current USDA FSIS inspection team, they hope we can

come to a consensus. The establishment used the description

of a cadaver from the Compliance Guideline for Training

Establishment Carcass Sorters in the New Poultry Inspection

System (NPIS) Food Safety and Inspection Service U.S.

Department of Agriculture, September 2014, which states: “A

cadaver is a generalized condition that causes the carcass and

viscera to be unwholesome and unfit for human food.  Cadavers

are any birds that did not bleed out properly due to a poor or

missed cut of the neck veins before the bird entered the

scalder.  The heat of the scalder causes blood left in the carcass

to expand into the skin blood vessels, giving the skin of the

carcass and neck a cherry red to purple color.  The blood also

accumulates in the dependent (lower) regions, such as the

necks, wings, and upper breast area.  Some cadavers may

appear red all over; others will appear red only in the lower

regions of the carcass.  The blood vessels in the viscera will

appear enlarged and the liver may appear burgundy colored. 

The entire carcass and viscera of cadavers are unwholesome and

must be disposed of properly to ensure that they are not used

as human food.” It also states what the establishment sorter is

to look for: “cherry red to purple color of whole carcass or the

lower regions of the carcass; sometimes, just the neck will

appear cherry red or purple color; may be no cut on the neck,

or may be only partially cut; and blood vessels in the viscera

may appear engorged (filled up with blood)” The establishment

wanted to know if IPP are looking at the livers before

condemning the birds as cadavers.  Unfortunately by the time

the carcasses arrives to the Carcass Inspection Station, there are

no livers to examine and the IPP can only go by the skin, muscle

and what they can see inside the cavity. But, I, , was

able to examine the lot at the Leukosis station and noticed that

a large number of the birds have congested livers and ascites.

Mr. Monson asked if the condition of the birds were due to their

system.  I replied: “No, but the condition of the birds and your

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 131

EstNbr EstName Task_Code MOI# Date Description

system can cause cadavers. This is why birds need to be placed

on the line in a timely manner so they can go through the kill

machine and bleed out.” The establishment doesn’t

understand why IPP are looking at the breast muscle since they

have no documentation on looking at the breast meat to

disposition a carcass. They request to have some of the birds

submitted for pathology.  They will also share the documents

they have from 2013 to the USDA FSIS.  USDA FSIS agreed to

submit pathology samples from carcasses that are condemned

as cadavers and will review the documents the establishment

has on the matter.  Once all the information is review and

pathology results received, the establishment and USDA FSIS

will meet again on this matter.  The meeting was adjourned.
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 132

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

04C05 PBM30170

61329G

2017-06-29 On 28 June 2017 at approximately 0815 hours, I, 

, meet with 

 to discuss the Good Commercial Practice

mistreatment observed earlier that morning. On 28 June 2017

at 0759 hours while performing ante-mortem inspection in the

South loafing shed, trailer T325 had six loose young chickens on

it.  The top module at the second level from the top had a

broken door which was hanging down and pinned between the

trailer’s support post and the module. The Scale House

employee was notified. And, the birds were caught and placed

into another module without harm or added stress.  The

employee informed me that a plastic door would be placed in

front of the opening to prevent the remaining chickens from

falling out and the trailer would be unloaded first for that lot. 

As I continued ante-mortem inspection on trailer T325, 529 and

T796, I observed a large number of dripping wet young birds. 

During the time the trailers were being transported uncovered

to the establishment, there were thunderstorms in the area. The

small young chickens (under 3 pounds) were dead or very

lethargic and pale in color. The young chickens were from Lot

Number: 4308179, Total Head , Total DOAs: 178 (24, 36

and 9 DOAs were on the three trailers). The Poultry Products

Inspection Act and Agency regulations (9 CFR 381.65(b)) require

that live poultry be handled in a manner that is consistent with

good commercial practices (GCPs). Compliance with GCPs

increases the likelihood of producing unadulterated product.

Poultry are to be handled in a manner that prevents needless

injury and suffering in order to produce a commercially

marketable product. Establishment management may review

Federal Register notice “Treatment of Live Poultry Before

Slaughter”, 70 Fed. Reg. 56624 (September 28, 2005) for FSIS

recommendations concerning the treatment of live poultry

before slaughter. This MOI will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended. Respectfully, 

 Establishment P20251

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

(b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 133

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

04C05 PBM40060

70205G

2017-07-05 On 5 July 2017 at 0937 hours, USDA FSIS 

 met with to

discuss the Good Commercial Practice Mistreatment of a young

chicken.  At approximately 0537 hours this morning while

performing ante-mortem at the South Staging area, I, 

, observed a dead young chicken with its head

sticking out of the module with red substance (blood) splattered

across the right side of its neck and wing and from its mouth

down the module to the frame of the trailer.  The bird was

located in the middle of the organic trailer number 204 at the

bottom level of the top module. Upon further investigation of

the module, I observed that the bottom wire was broken

creating an opening big enough for the bird to stick its head out

of the module. The other young chickens (approximately 12)

were unharmed. informed me that she will notify Live

Op and the module will be fixed tonight.  The establishment’s

average percentage for damaged modules is 3.46%. The Poultry

Products Inspection Act and Agency regulations (9 CFR

381.65(b)) require that live poultry be handled in a manner that

is consistent with good commercial practices (GCPs).

Compliance with GCPs increases the likelihood of producing

unadulterated product. Poultry are to be handled in a manner

that prevents needless injury and suffering in order to produce a

commercially marketable product. Establishment management

may review Federal Register notice “Treatment of Live Poultry

before Slaughter”, 70 Fed. Reg. 56624 (September 28, 2005) for

FSIS recommendations concerning the treatment of live poultry

before slaughter. This MOI will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended. Respectfully, 

 Est. P20251

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

(b) (6)

(b) (6)

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 135

EstNbr EstName Task_Code MOI# Date Description

dumper will stop.  The person who shuts the system off has to

communicate with the Operator to shut off

the dumper belt.  Since the personnel did not realize that the

system was shut off, there was no communication to the 

Operator.  I thanked for the

information and that I will be documenting it in an MOI and

forward it to the District Office. The Poultry Products

Inspection Act and Agency regulations (9 CFR 381.65(b)) require

that live poultry be handled in a manner that is consistent with

good commercial practices (GCPs). Compliance with GCPs

increases the likelihood of producing unadulterated product.

Poultry are to be handled in a manner that prevents needless

injury and suffering in order to produce a commercially

marketable product. Establishment management may review

Federal Register notice “Treatment of Live Poultry Before

Slaughter”, 70 Fed. Reg. 56624 (September 28, 2005) for FSIS

recommendations concerning the treatment of live poultry

before slaughter. Respectfully, Est.

P20251 Acting IIC 8/31/2017

(b) (6) (b) (4) (b) (4)

(b) (4)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 136

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

04C05 PBM15100

92720G

2017-09-20 On 9/20/2017, at approximately 0550 hours, I, 

,  met with to inform her

of a Good Commercial Practice Mistreatment. At 0543 hours

this morning with outside temperature of 73 degrees

Fahrenheit, while performing ante-mortem in the loafing sheds,

I observed a Good Commercial Practice Mistreatment on

Organic Trailer 204. I observed a module on the top row

towards the back of the trailer with five (5) compartments all on

the same side overloaded with live young chickens

(approximately 125 birds involved). They were pressed up

against the sides of the module and piled on top of each other

panting (necks stretched out, open mouth breathing and

tachypneic), vocalizing, and restless (shifting side to side or from

laying to standing). One of the birds had its head and neck

sticking outside of the module due to broken wires on the

panel. No injuries were observed on the bird.  took

photos of the module and informed me that she will have Live

Op move the module and find out the cause. The Poultry

Products Inspection Act and Agency regulations (9 CFR

381.65(b)) require that live poultry be handled in a manner that

is consistent with good commercial practices (GCPs).

Compliance with GCPs increases the likelihood of producing

unadulterated product. Poultry are to be handled in a manner

that prevents needless injury and suffering in order to produce a

commercially marketable product. Establishment management

may review Federal Register notice “Treatment of Live Poultry

Before Slaughter”, 70 Fed. Reg. 56624 (September 28, 2005) for

FSIS recommendations concerning the treatment of live poultry

before slaughter. This MOI will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended. Respectfully, 

 at Est. P20251 

 Denver District/ Lincoln Circuit 9/20/2017

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 137

EstNbr EstName Task_Code MOI# Date Description

P206 Pilgrim's Pride

Corporation

04C05 KCC182101

1905G

2017-01-05 At approximately 1550 hours, while touring the facility with the

 was seen throwing birds by their

neck from one end of the conveyor belt to the other.  The birds

were thrown approximately 3-5 feet, from the north end of the

north conveyor belt hitting the bumper at the south end of the

conveyor belt.  At the time of this observation the conveyor belt

was empty and the birds were starting to come in from the cage

dumper.  Regulatory control action was taken by stopping the

picking lines and placing USDA Reject tags (B38482441 and

B3848438) on the start/stop button of both the east and west

picking lines.  spoke to 

 Tonya Byers (Plant Manger), and 

 regarding the incident.  The PPIA and Agency

regulations require that live poultry be handled in a manner that

is consistent with good commercial practices and preventing

mistreatment of poultry directly correlates with a decreased

production of adulterated carcasses.  and Tonya

Byers immediately held a documented training with all live hang

employees on 2nd shift before starting back up.  Regulatory

control action was relinquished by removing the Reject Tags

from the start/stop button for both the east and west picking

lines.  This MOI will be forwarded to the Front Line Supervisor,

District Office, and the District Veterinary Medical Specialist

(DVMS) in case additional follow-up is recommended. 

 P206

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

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 138

EstNbr EstName Task_Code MOI# Date Description

P206 Pilgrim's Pride

Corporation

04C05 KCC551507

5920G

2017-07-20 At approximately 2230 hours, while performing Good

Commercial Practices, I observed two large piles of DOAs

totaling approximately 200 birds in the live hang area.  The

DOAs were steadily being removed from the live hang conveyor

belt.  The picking lines were slow to accommodate the rate at

which the DOAs were entering live receiving.  The live hang

foreman and additional live hang employees were in the process

of removing the DOAs but they soon became overwhelmed and

stopped killing on this line.  At this time I went outside to

observe the establishment dumping the cages.  The cages from

this farm, Lot 4 - , were approximately

1/3 - 1/2 full of DOAs. At this time, no communication was

made to USDA regarding any emergency that occurred during

transport.  When questioned, 

 and 

were not aware of any issues that occurred

with this trailer or farm.  On the Poultry Lot Sheet (FSIS Form

6510-7) it shows that there were heads in the lot and

there were 1490 DOAs.  This is a DOA rate.  I discussed this

with .  He stated that they ran approximately 8

trucks from this farm and there was only 1 truck that had a

large number of DOAs.  This is indicative of an issue that arose

during transport regarding this one truck.  After consulting with

, I informed

), Tonya Byers (Plant Manager),

and ) that they would be

receiving a GCP MOI documenting the increased number of

DOAs observed from this farm.  On 07/19/2017 

reached out to Pilgrims Corporate Management to identify if

they were aware of the issue and informed them of the

findings.  USDA requested the establishment conduct an

investigation into the issue.  On 07/20/2017 she was informed

that an issue had occurred at the farm concerning the catch

equipment (in regards to the fans) and that there had been an

issue with the driver of the truck in question.  She also spoke

with Plant Manager Tonya Byers and was told that the

establishment had since implemented corrective actions to

include hiring additional drivers and working with the Live Bird

operation to decrease the number of birds loaded into the

cages.  She informed Plant Manager Byers that the information

should be provided in response to the MOI being issued by

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

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

(b) (6) (b) (4) (b) (4) (b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 139

EstNbr EstName Task_Code MOI# Date Description

. The establishment is reminded that they are

encouraged to develop and implement systems that ensure

poultry presented for slaughter are treated in a manner that

minimizes accidental injury and/or death and that they die by a

means consistent with Good Commercial Practices.  This

includes an assessment of areas where handling problems may

occur, such as during transport.  When issues are identified, the

establishment is expected to take corrective actions

immediately.  Establishments should have, and implement as

needed, an emergency plan or notification system that

addresses animal welfare in the event an emergency or unusual

circumstances during transport arises.  This concern was

discussed with the establishment in response to another

transport related incident that occurred on 4/24/2017 in which

a large number of birds were killed during a traffic incident and

transported to the official establishment commingled with live

birds.  In regards to that incident, USDA was not notified of the

issue before the truck arrived and the establishment delayed

sorting of the birds.  Noncompliance record

KCC2016044525N/1 was issued.  Copies of this Memorandum

of Interview (MOI) will be distributed to the establishment,

inspection file and District Veterinary Medical Specialist per FSIS

Directive 6100.3. Documented by 

Establishment management response: Pilgrim's Pride is

committed to the human treatment, handling, and processing of

poultry in a manner that is consistent with Good Commercial

Practices and has establishment a comprehensive animal

welfare program to ensure that birds are handled with concern

for animal welfare through all phases of grow out, transport,

and slaughter.  This letter is in response to the above mentioned

LOC where our plant failed to prevent birds from dying by

means other than proper slaughter. On July 18th, 2017 Plant

Management was notified of a deficiency of good commercial

practices.  The conditions observed were as follows: excessive

DOAs in the live hang area and on a cage trailer from 

 Complex Management immediately conducted

an investigation of the event and determined the findings were

due to the following: The use of fans and misting at the farm to

reduce the heat stress for the birds was not in affect at the time

of loading.  The root cause was determined to be that there

were an insufficient number of fan truck drivers at the time of

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

(b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 140

EstNbr EstName Task_Code MOI# Date Description

loading.  This created a shortage of fans/misters at the farm

when the cage trailer was loaded. The Complex Management

team met and discussed the findings.  Measures have been

implemented to ensure that the number of birds per load will be

seasonally adjusted to reduce heat stress.  We have hired

additional fan truck drivers to ensure that a sufficient number of

fan/mister systems are available during the loading of birds.  We

are hiring fan operators for correct fan operation and bird

misting to reduce heat stress on the farms.  Proper fan and

mister operation, in conjunction with reduced stocking density

in the cages will prevent further reoccurrence.  Pilgrim's

management personnel will also be available during catching

operations to ensure best practices are used at all times. 

Complex management is confident that these preventative

measures will correct any potential deficiencies going forward. 

All corrective actions have been implemented as of 7/24/17. 

After the implementation of the above measures, the Live

Operations manager and Complex manager have monitored

several farms at catch verifying that proper fan operation and

misting procedures are being followed.  We are confident that

this issue has been permanently addressed and that there will

be no further incidents of this type.
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 141

EstNbr EstName Task_Code MOI# Date Description

P208 George's

Processing, Inc.

04C05 XIC461801

4621G

2017-01-21 On January 21, 2017 at approximately 1825 hours I observed

the stun/kill process for Kill Line #1.  Over a period of 3 minutes

I observed 12 birds on the line that had been hung by only one

leg.  I noted that because of the way these birds were hung on

the kill line they did not pass through the stunning and kill

machines properly.  As a result the birds were not properly

stunned.  Additionally, I observed that the improper

presentation of these birds through the kill machine resulted in

cut wings/legs and no neck cut.  Because these birds had not

been rendered insensible by the stunning equipment these

improper cuts resulted in excessive thrashing and wing flapping

by the birds, which had to be manually killed by the backup kill

employee. I immediately notified

 of my findings and we discussed the importance of all

birds being hung on the kill line by two legs to help ensure

proper stunning and slaughter.  He immediately assigned a lead

employee to the live hang area to ensure that birds were being

hung properly.  During several additional minutes of monitoring

stun/kill operations I did not observe any more birds hung by

one leg on the kill line.  I discussed my findings with 

 and reiterated to him the importance

of all birds being hung by two legs on the kill lines to help

ensure proper stunning and slaughter.

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 142

EstNbr EstName Task_Code MOI# Date Description

P208 George's

Processing, Inc.

04C05 XIC331905

0322G

2017-05-22 On 5-22-2017 at approximately 1910 hours while walking

through the live hang and receiving areas I noted that the Kill

Line #1 cage dumper was inoperable.  As a result live hang

employees were transferring live birds by hand from the Kill Line

#2 hanging belt to the Kill Line #1 hanging belt, approximately 7

feet away, to be hung on shackles to allow both kill lines to be

utilized for production.  As I observed these activities in the live

hang area I noted that a live hang employee was removing live

birds from the Kill Line #2 hanging belt and throwing them

through the air at a distance of approximately 5 feet to land on

the Kill Line #1 hanging belt.  On two occasions this employee

tossed a live bird far enough to hit live birds that were hung on

the Kill Line #1 shackles and then drop onto the hanging belt

below. I immediately stopped production on Kill Line #1 and

placed U.S. Reject tag #B35619004 on the live hang belt to

denote it as rejected for use.  I contacted N/S Plant Manager

Paul Howell and  informed him that the Kill Line #1 hanging belt

was rejected for use due to improper handling of live birds by

the live hang employee.  After investigating the incident Mr.

Howell and met with me

to discuss corrective actions to prevent improper handling of

live birds by live hang employees.  Mr. Howell held an

immediate meeting with the live hang employees to discuss

proper bird handling.  He also informed me that there would be

a formal training session addressing good commercial practices

and proper bird handling to be held with all live hang personnel

at the end of the night's shift.  He also directed that

a supervisory employee be stationed in the live hang area to

monitor live hang employees until the transfer of live birds

between the two kill lines was discontinued for the night.  At

approximately 1926 hours I removed the U.S. Reject tag and

released the Kill Line #1 live hang belt for use.  The Kill Line #1

cage dumper became operational at approximately 2100 hours

and normal operations for live hang on both kill lines resumed

at that time.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 143

EstNbr EstName Task_Code MOI# Date Description

P208 George's

Processing, Inc.

04C05 XIC511007

3019G

2017-07-19 The following MOI documents my findings during a GCP task on

7/17/17 at P208 and the resulting discussions I had with

establishment management: , and 

 At approximately 1110 I observed the following in the

kill room. Line #1 had been stopped shortly after startup from

break (1000). Birds had been removed from the line in live hang

and stunned birds before the kill machine had their throats cut

by the back-up killer. However, 2 birds were alive and aware at

the entrance into the stunner before the stun plate and had

been hanging this way since the line stopped for over an hour.

These birds were breathing heavily and had some congestion of

blood in their heads consistent with being upside down for an

extended period of time. I was assured the line would be

starting soon and the backup killer was addressing birds left in

the stunner. In my discussion with plant management, they

explained their reasoning for stopping the line with birds still in

the stunner was to stop the birds at the front of the line from

entering the scalders. I was told that in the future, they will

account for the stunner when hanging birds before the line is

stopped for an extended period of time. Continuing my

observations, I proceeded to the picking room to observe birds

for 1 minute birds) before they entered the scalder on line

#2. I observed 1 bird blinking and breathing. The bird had a

small nick high on its throat but no apparent blood loss. The

bird was much shorter than the rest of the flock and also missed

the head puller. I was unable to stop the line or safely remove

the bird before it entered the scalder. After speaking with 

 he had an employee raise the head puller to catch shorter

birds due to variation in size within the flock. Birds left hanging

on the line alive for extended periods of time can have altered

physiology such as respiration and circulation, which can lead to

death on the line or prevent appropriate bleeding out, which

adulterates product. Additionally, killing chickens by means

other than slaughter is not in keeping with good commercial

practices.   Good commercial practices are essential to

producing wholesome, unadulterated product.

(b) (6)

(b) (4) (b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 144

EstNbr EstName Task_Code MOI# Date Description

P208 George's

Processing, Inc.

04C05 XIC231907

1928G

2017-07-28 On July 28, 2017 at approximately 1900 hours, while

monitoring bleed out operations for live birds on both kill lines

at the end of the blood tunnel I observed two live birds on Kill

Line #1.  I was unable to retrieve the live birds but noted that

both were without a neck cut and consequently did not undergo

exsanguination.  Both birds were alert and breathing prior

to entering the scalders. I quickly walked to the stun/kill area

and noted that stunning efficiency for Kill Line #1 was

approximately 85-90%.  I immediately notified 

 of my findings.  Adjustments were quickly

made to the Kill Line #1 stunning machine.  At 1910 hours I

noted that the stunning efficiency for both kill lines was >99%.  

During my discussion with it was determined that the

water supply to the Kill Line #1 stunner had been turned off for

the recent lunch break but had not been turned back on prior to

resuming operations.  Consequently stunning efficiency was

reduced (which also adversely affected kill machine efficiency). 

 informed me that the backup killer had access to an

E-stop button for Kill Line #1 as well as a buzzer to notify plant

management of stun/kill problems.  The backup killer had

become aware of stun/kill issues but had only stopped the line

for a few seconds and had resumed operations

without notifying plant management.  counseled the

backup killer on the importance of stopping the kill line and

notifying management when stun/kill problems arise. Poultry

not slaughtered in a manner that results in thorough bleeding of

carcasses prior to entering the scalder reflects poor commercial

practices and is noncompliant with 9 CFR 381.65(b).

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 145

EstNbr EstName Task_Code MOI# Date Description

P208 George's

Processing, Inc.

04C05 XIC480608

3003G

2017-08-03 The following MOI documents my findings during a GCP task on

8/2/17 at P208 and the resulting discussions I had with

establishment management: . At approximately

1030, while I was performing a GCP task, I observed 2 birds

enter the scalder alive, 1 bird on each line.  Both birds had their

necks cut but were still breathing. Additionally, the bird on line

2, was still conscious—blinking and tucking his head up so that

he missed both head pullers before the scalder, entering the

scalder alive. The bird on line 1 was too small for the head

pullers to be effective. I was unable to safely remove the birds

from the line before they entered the scalder. I immediately

proceeded to the killing area and observed both back up killers

were present and performing their jobs satisfactorily. The

stunners and kill blades on both lines were both effective. I

informed of the issue and

forthcoming GCP MOI. We discussed that the birds were shorter

than the rest of the flock but still had cuts. proceeded

to the killing area to observe the process and reported that the

process appeared to be in control. He instructed the back-up

killers to cut deeply on shorter birds, even when they appear to

have a cut. Poultry slaughtered in a manner that results in

failure of thorough bleeding of carcasses prior to entering the

scalder reflects poor commercial practices, which are essential

to producing wholesome, unadulterated product.

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 146

EstNbr EstName Task_Code MOI# Date Description

P208 George's

Processing, Inc.

04C05 XIC021208

0411G

2017-08-11 The following MOI documents my findings during a GCP task on

8/11/17 at P208 and the resulting discussions I had with

establishment management and . At

approximately 1108, while I was performing a GCP task, I

observed 1 bird enter the scalder alive. The bird had its neck cut

but was still conscious, breathing and blinking. It tucked its head

up so that it missed both head pullers before the scalder.  I was

unable to safely remove the bird from the line before it entered

the scalder. I immediately proceeded to the killing area and

observed the back up killer was present and performing his job

satisfactorily but appeared overwhelmed because the stunner

and kill blades were functioning slightly less than ideal. I

informed of the issue and

forthcoming GCP MOI. We discussed size variability within the

flock and the decision was made to raise the stun plate to

increase both stunning and kill machine effectiveness and

decrease the work load of the back up killer. Poultry

slaughtered in a manner that results in failure of thorough

bleeding of carcasses prior to entering the scalder reflects poor

commercial practices, which are essential to producing

wholesome, unadulterated product.

P208 George's

Processing, Inc.

04C05 XIC151308

4730G

2017-08-30 The following MOI documents a GCP issue I observed on

8/30/2017, while touring the slaughter and dressing process

with a , and the resulting

discussions I had with establishment management: 

and . At approximately 0720, while observing the

scalding and picking process, we witnessed a live, conscious bird

enter the scalder. The bird did not appear stunned and there

was no evidence of a cut anywhere on the neck or head. The

bird tucked its head so it missed both head pullers before the

scalder.  Due to the height and speed of the line, I was unable to

safely remove the bird before it entered the scalder. After

informing management, proceeded to the kill room

and observed the kill process and the backup killer performing

his job. He stated that the backup killer was not being

overwhelmed by unstunned or miscut birds. He also performed

a 3 minute check of birds on the line and saw no additional live

birds entering the scalder. Poultry slaughtered in a manner

that results in failure of thorough bleeding of carcasses prior to

entering the scalder reflects poor commercial practices, which

are essential to producing wholesome, unadulterated product.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 147

EstNbr EstName Task_Code MOI# Date Description

P208 George's

Processing, Inc.

04C05 XIC312208

0131G

2017-08-31 On August 31, 2017 at 2210 hours while walking through the

live hang area I observed a live chicken sitting among 7-8 dead

chickens in the DOA hopper.  This hopper feeds DOA carcasses

into a stainless steel auger which macerates the carcasses

allowing them to be delivered to offal through a pipe system. 

The auger was not operational at this time.  I immediately

notified who removed the live chicken from

the hopper.  I also notified of

my finding.  At 2225 I discussed the finding with 

 stated that to prevent

future occurrences the employee responsible for the live bird in

the DOA hopper was undergoing additional retraining/coaching

on the proper disposition of live birds in the live hang area.  

also stated that the other employees in the live hang

area had received previous training on the handling of live birds.

P21234 Perdue Foods

LLC

04C05 XGI591003

1702G

2017-03-02 On Thursday, March 2nd, 2017, at 0737 Hour, while I was

performing Poultry Good Commercial Practice Verification Task,

I noticed that a number of birds were missing stunning on Line

one, and went conscious through the neck cutting machine,

some of them were still alive after passing the cutting machine,

where the back-up nick cutter was cutting their necks while

they were still conscious, I put my observation to 

, and he told me that he has just

started his position few days ago and he called the management

immediately. I started counting the number of birds who

missed stunning, there were on line 1, two

small birds on line 2, and zero birds on line all for 5 minutes).

The conscious birds were either small birds or hung on the top

of the shackles, which I believe that it was the reason for missed

stunning. The PPIA and Agency regulations do require that live

birds be handled in a manner that is consistent with good

commercial practices ( GCPs), This MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist ( DVMS) in case additional follow up is recommended.

/

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (4) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 148

EstNbr EstName Task_Code MOI# Date Description

P244 Hain Pure

Protein

Corporation -

Plainville Farms

LLC

04C05 GCN21080

94615G

2017-09-15 Plainville Farms, Inc. Hain Pure Protein, P244. From 9/11/17 to

9/14/17 the USDA and the establishment met and discussed 2

cadavers that were diagnosed on 9/11/17 and 9/13/17. On

9/11/17, at approximately 1500 retained a

carcass for veterinary disposition. condemned the

carcass as a cadaver. On 9.13.17 at approximately 0645

 retained a carcass for veterinary disposition.

 condemned the carcass as a cadaver. Meetings

were held with the establishment management on 9/12 through

9/14. The attendees included: Robert Terrell, Plant Manager,

 and 

 We discussed what actions were taken,

investigation into the cause of the deviation and what further

actions will be taken. They are going to improve

communications between evisceration supervisors and upper

management. They checked the knife used by the back-up killer.

They retrained the live hang employees on not hanging DOA’s.

They have been actively monitoring the line since the events.

They have retrained their sorters on hanging back carcasses. The

establishment is aware that preventing cadavers decreases

production of adulterated carcasses.

P2632 Pilgrims Pride

Corporation

04C05 GAA56100

11805G

2017-01-05

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

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 149

EstNbr EstName Task_Code MOI# Date Description

P2632 Pilgrims Pride

Corporation

04C05 GAA14120

61808G

2017-06-08 P-2632 Pilgrim’s Pride, Regulation 381.65b.  1120 hours On

Tuesday June 6, 2017 at 11:20 I, , in the course

of performing the daily Good Commercial Practices task, I

observed  the birds being transported from the Line 1 cage

dump to the live hang area. On the right side of the cage dump

conveyor belt, I observed two birds that had gotten their heads

trapped between the belt and the metal guards that is designed

to prevent this occurrence. At the time I observed this, both

birds were dead and the other birds on the belt were traveling

across the carcasses. I immediately requested that the conveyor

be halted and contacted . He has

the two carcasses removed and made installed a temporary

barrier to allow the process to continue until the end of 1st

shift. At the end of the shift, permanent repairs were made and

the problem appears to have been satisfactorily corrected. I

consider this to be unacceptable since the birds appeared to

have died in a manner other than slaughter and the fact that

this potential point of birds becoming entrapped was brought to

the establishment’s attention during a weekly HACCP meeting

on April 26, 2017. Maintenance had ample opportunity to make

the alteration to prevent the incident I observed on June 6,

2017. Please respond in writing no later than Wednesday June

14, 2017.

P3 Mountaire

Farms of

Delaware, Inc.

04C05 OCG15090

10431G

2017-01-31 Time: 0845 hours Establishment: 00003-P Attendees: 

, Mr. Daniel Rivera Plant Manager A meeting

was held to discuss the following observation in live hang; while

preforming a good commercial practice task, at approximately

0835 hours, I observed one live bird in a dead on arrival barrel

line 2 side. The bird was slowly breathing inside the DOA barrel. 

Establishment employee failed to recognize the live bird and

began to pour denaturant on the bird. I immediately stopped

the employee and notified 

 and had bird removed from barrel and cervical

dislocation performed. The bird was then properly condemned.

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 150

EstNbr EstName Task_Code MOI# Date Description

P320 Sanderson

Farms, Inc.

04C05 MRA23150

23807G

2017-02-07 On Tuesday, February 07, 2017 at approximately 1411 hour, I

observed less than Good Commercial Practices. While

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed a live bird rhythmically breathing

commingled in the dead on arrival bin under several dead birds. 

The bird was visualized in the bin from the live hang room,

immediately I went to the bin to examine the bird closer.  The

bird was weak, laterally recumbent, rhythmically breathing and

alive.  The remainder of the birds in the bin had been manually

decapitated, which is the establishment’s protocol for dead on

arrival birds before they go into the bin.  This bird, however, was

placed in the bin alive and had several birds on top of it, which

would have led to dying by suffocation; death by means other

than slaughter.  The bin was approximately 2.5 feet deep with

dead birds at this time.  At approximately 1411 hour I asked an

establishment employee to radio a supervisor to come to the

area quickly.  The supervisor arrived at 1417 and was made

aware of the issue.  Once the supervisor arrived he euthanized

the bird.  It was explained that live birds comingling with dead

birds can lead to suffocation and death by means other than

slaughter which is less than Good Commercial Practices. 

Establishment management was notified as well of the incident

and informed of the resulting MOI.   As per Federal Register

Notice Docket No. 04-037N dated September 28, 2005,

“Treatment of Live Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good Commercial Practices

(GCPs) as described by industry guidelines. My observations

are consistent with less than good commercial practices. A

copy of this Memorandum of Interview will be forwarded to

appropriate personnel in the District Office.  Respectfully

submitted on February 7, 2017 Cc:

         DDM                 DVMS                 FLS

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 151

EstNbr EstName Task_Code MOI# Date Description

P320 Sanderson

Farms, Inc.

04C05 MRA03220

22722G

2017-02-22 Sanderson Farms, Inc. 

2535 Sanderson , MS. 39440 , At

approximately 2139 hours, while verifying Good Commercial

Practices in Poultry (GCPIP) at P320, Sanderson Farms, Inc., the

following less than GCPIP incident was observed on the back

dock.  One live bird was observed with rhythmic labored

breathing on top of a bin full of DOAs in a plastic combo for

collection of Dead on Arrival (DOAs).  The head of the bird was

buried underneath DOAs in the bin.  The bird was then  removed

from the bin for further examination.  The bird exhibited

rhythmic, albeit labored, breathing, pupillary reflexes, and

upward head movement.   

 was requested to radio for the shift manager.   The

 was notified of a live

bird which had been placed in the DOA bin and observed the

live bird prior to the bird being humanely euthanized by the

.  Per establishment

policy, all birds placed in the DOA bin are to have the head

removed prior to being placed in the bin.  Placing live birds in

the DOA bin can lead to death by suffocation due to entrapment

under other birds in the bin.  This practice in not consistent with

Good Commercial Practices. At approximately 2145 hours, a

meeting was held in the USDA office with 

 and 

.  The incident was discussed regarding

placement of a live bird in the DOA bin and preventative

measures for preventing future incidences.  

proposed placing a additional  employee on the floor in the live

hang area.  This employee would pick up DOAs and remove

the heads.  All decapitated birds will be verified by 

before placement in the DOA bin for a period of 2

weeks. As per Federal Register Notice Docket No. 04-037N

dated September 28,2005, "Treatment of Live Poultry before

Slaughter, " the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to treat poultry humanely and

abide by Good Commercial (GCPs) as described by industry

guidelines. Respectfully, Canton,

MS 9024 1039 W. Fulton St. Canton, MS 39046 cc:  Mr. Perry

Davis, DM        Dr. David Thompson, DDM        Dr. Larry Davis,

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

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

(b) (6)

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

(b) (6)

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 153

EstNbr EstName Task_Code MOI# Date Description

P325 Tyson Foods,

Inc.

04C05 YDM05230

12202G

2017-01-02 On 12/31/16 at 3:30 pm, went to perform

antemortem in live hang. Underneath the bed rollers, she

observed four loose chickens on the ground. One of the chickens

was sitting in a water trough and was soaked with water. It was

55 degrees outside at the time. On the edge of the bed rollers

were three more chickens. demonstrated the birds

to and instructed him to

retrieve the chickens stopped the mule driver to

prevent him from putting more cages on the bed rollers and

injuring the loose chickens. After the chickens were removed,

 allowed the mule driver to continue. The escaped

birds did not appear to be injured. said that one of

the cage doors probably popped open allowing the birds to

escape. informed about the

chickens and told him it was the plant’s responsibility to prevent

the chickens from escaping so that they do not become injured.

 said the plant has been steadily replacing the cages

with new ones, and has observed the new cages. It

is important to treat poultry in a way that minimizes accidental

injury. Employing humane methods of handling consistent with

Good Commercial Practices can help produce an unadulterated

product. FSIS encourages establishments to develop and

implement a systemic approach to ensuring poultry presented

for slaughter are treated in a manner that minimizes

excitement, discomfort, and accidental injury. The initial

component of the approach is to assess the areas where

problems may occur. The second component asks that

establishments 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. The plant is asked to prevent future

occurrences. Copies of this MOI will be distributed to the

establishment, inspection file, and DVMS per FSIS Directive

6100.3.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 154

EstNbr EstName Task_Code MOI# Date Description

P325 Tyson Foods,

Inc.

04C05 YDM59160

11404G

2017-01-04 On 1/4/17 at 3:20 pm, went to perform

antemortem in live hang. She observed a loose chicken sitting in

a water trough, and it was soaked with water. It was 45 degrees

outside at the time. demonstrated the bird to 

 and instructed him to retrieve the

chicken. A plant employee picked up the wet chicken, which did

not appear to be injured. On 12/31/16, observed

seven loose chickens around the bed rollers, one of which was

sitting in the water trough. Another MOI was written about

those birds. During a meeting with Plant Manager Clint

Holsomback, , 

, and , the

plant said they would put a shield on the dumper to prevent

chickens from escaping off the dumper. It is important to treat

poultry in a way that minimizes accidental injury. Employing

humane methods of handling consistent with Good Commercial

Practices can help produce an unadulterated product. FSIS

encourages establishments to develop and implement a

systemic approach to ensuring poultry presented for slaughter

are treated in a manner that minimizes excitement, discomfort,

and accidental injury. The initial component of the approach is

to assess the areas where problems may occur. The second

component asks that establishments 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. The plant is asked to

prevent future occurrences. Copies of this MOI will be

distributed to the establishment, inspection file, and DVMS per

FSIS Directive 6100.3.

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

(b) (6)

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 155

EstNbr EstName Task_Code MOI# Date Description

P341 Golden Rod

Broilers

04C05 YDC191402

0424G

2017-02-24 February 24, 2017, while performing ante mortem and good

commercial practices, I observed several cages on a truck that

were removed from an accident earlier in the day. The cages

appeared to be damaged, with dead and dying chickens pressed

against the cage wire. Some had guts draped on them and all of

the visible cages (three batteries high)had live chickens mixed

with the dead chickens. In one cage, a chicken was pinned

under and surrounded by dead and dying birds. After notifying

the plant manager that an unacceptable situation had occurred

and required immediate action, details of the situation came

out. After monitoring the removal of the cages and the sorting

of live chickens from dead and dying birds, the Deputy District

Manager Larry Davis was contacted. He advised the discussion

and documentation of a MOI during the weekly HACCP meeting,

to get details of the resolution and how to avoid failure to notify

FSIS of situations like this again.
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 156

EstNbr EstName Task_Code MOI# Date Description

P34308 Sanderson

Farms, Inc.

04C05 PHY071501

5706G

2017-01-06 On Tuesday January 3, 2017 while observing the establishment

processes I ) observed the following.    

 At approximately 1548 I was observing the backup cutter on kill

line # 1, I observed him for 3 minutes and 10 seconds and in

that time there were 17 mis-cuts and  in that time and I also

observed 1 uncut  bird enter the scalder. This was no doubt

because the backup cutter had to catch so many mis-cuts.

 was present and once the

uncut bird was identified, it was removed from the line once it

exited the first scalder and inspected for cut marks, there were

no marks present.   I informed QC of my observation and that

it would be documented.   I did a retest and the retest passed

there were nine mis-cut birds.  During the retest, I observed an

uncut bird enter the scalder.  and 

were present during this observation and removed the bird,

after exiting the scalder and inspected the carcass for cut

marks.  The carcass had one cut mark behind the head and none

along the neck. At 1627 I went back to live hang and observed

the establishment process flow I also noticed that the backup

cutter seemed to be having a hard time keeping up with the

process and  all the mis-cuts.  Watching him did make me

concerned. I evaluated the situation and there were 10 mis-cuts

at 3 min and 10 seconds.  I informed 

of my observation. I informed him that I would

evaluate the condition a little later and if he would like to be

present, I did not mind.  At 2015, and I went to

reassess the situation.  I counted 20 mis-cut birds in 3 min and

10 seconds. During this observation I again witnessed another

uncut bird enter the scalder.    I informed the that

this concern was brought to two of establishment management

personnel yesterday, and the CSI informed them that they

needed to get the issue addressed and under control.   My

concern is that the personnel are not able to handle to process

flow, which is resulting in uncut birds entering the scalder. 

Which is failure to comply with 9 CFR 381.65(b)  This MOI will

be forwarded to the Front Line Supervisor, District Office, and

the District Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 157

EstNbr EstName Task_Code MOI# Date Description

P34308 Sanderson

Farms, Inc.

04C05 PHY372202

2828G

2017-02-28 On Tuesday February , 2017 while observing the establishment

processes I ) observed the following.    At

approximately 2139 Hours and 2148 hours while performing a

Humane Handling/Good Commercial Practices Task at the

scalder, I observed the following noncompliance I observed an

uncut bird on Line 1 and Line 2 go into the scalder. 9 CFR

381.65 (b) says that 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. A breathing bird that enters the

scalder dies by drowning. These are cadavers and unfit for

human food. 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. 

P34308 Sanderson

Farms, Inc.

04C05 PHY372202

2828G

2017-02-28 On Tuesday February , 2017 while observing the establishment

processes I ) observed the following.    

 At approximately 2139  I was observing the backup cutter on

kill line # 1, I  observed 1 uncut  bird enter the scalder. I notified

   and once the uncut bird

was identified, it was removed from the line once it exited the

first scalder and inspected for cut marks, there were no marks

present.   At approximately 2148  I was observing the backup

cutter on kill line # 2, I  observed 1 uncut  bird enter the scalder.

I notified     and once the

uncut bird was identified, it was removed from the line once it

exited the first scalder and inspected for cut marks, there were

no marks present    

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 158

EstNbr EstName Task_Code MOI# Date Description

P34308 Sanderson

Farms, Inc.

04C05 PHY220603

2103G

2017-03-03 On Friday March 3. , 2017 while observing the establishment

processes I ) observed the following.  At

approximately 0606 I was observing the backup cutter on kill

line # 2, I observed1 uncut bird enter the scalder. I notified

 and identified to him the shackle of the

uncut bird, he attempted to remove the bird but was unable.  

He then lost the shackle of the bird as it moved further down

the line.  Birds that are incompletely bled out due to

incomplete or missing cuts are considered adulterated and must

be condemned.  Regulation 9 CFR 381.65(b) requires that

poultry must be thoroughly bled out to ensure that breathing

has stopped before scalding, so that the birds do not drown. 

P34308 Sanderson

Farms, Inc.

04C05 PHY211904

3712G

2017-04-12 On this day, 4-12-17, at 1500, I found the following animal

welfare concern. While going out back, where the live birds are

dumped onto conveyer belt, I found where the employee

dumping the birds, did not allow the previous cage of birds, get

out of the way, before dumping another cage. I notified the

employee to wait till the birds get out of the way before he

dumps another cage. I notified of my finding.

P34308 Sanderson

Farms, Inc.

04C05 PHY211606

5309G

2017-06-09 On May 9, 2017 I along with 

 observed the following in Live hang. While perfroming a

good commercial practice task I observed a live hang personnel

attempt to hand off  bird to the live hang supervisor.  The

supervisor was unaware of the employee, so the employee

threw the bird to the supervisor and the bird landed on its

head.  The bird was alive and breathing rapidly.  I informed the

supervisor of  the observation.  I informed him and

 that the observation would be

documented. As stated in 9 CFR 381.65(b) “the establishment

is not following good commercial practices" under the PPIA and

Agency regulations, live poultry must be handled in a manner

that is consistent with good commercial practices, which means

they should be treated humanely. Although there is no specific

federal humane handling and slaughter statute for poultry,

under the PPIA, poultry products are more likely to be

adulterated if they are produced from birds that have not been

treated humanely, because such birds are more likely to be

bruised or to die other than by slaughter. 

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

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 159

EstNbr EstName Task_Code MOI# Date Description

P34308 Sanderson

Farms, Inc.

04C05 PHY342006

5912G

2017-06-12 On Monday June 12, 2017 I was walking to the live receiving

holding area and I observed one bay staged with two trailers of

chickens.  I observed the first trailer to the right, it was closest to

the fans and the mist.  The chickens located in that trailer seem

somewhat comfortable only a minor few were panting.  Then I

observed the trailer on the left and I observed numerous

chickens panting, some were flapping there wings in an attempt

to cool down.  The trailer on the left was not able to benefit

from the fans or the mist due to the trailer on the right blocking

them.   After leaving the area I observed the process at the kill

line and I observed the backup cut employees removing an

excessive amount of Dead on Arrival (DOA) birds from the line. I

verbally notified and . 

 was informed that the observation would be

documented. 

P34668 Simply Essentials

Poultry, LLC

04C05 000521105

2718G

2017-05-18 I understand that this lot was affected with Reo virus.  This site

has had a history of high death loss.  The birds slaughtered were

a clean-out of the barn.  The number of DOA's and disposed

carcasses was very high.  The source barn is located within 25

miles of the plant and the weather was 84 degrees for a high

temperature.  The death loss occurred throughout the day even

with the normal start early in the morning when it was cool. 

The holding barn has fans on the north and south sides and in

between the trucks and is open on the east side.  There are fans

in the holding area of live hang. DOA losses for other sites on

days before and after have been acceptable.

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 160

EstNbr EstName Task_Code MOI# Date Description

P34668 Simply Essentials

Poultry, LLC

04C05 000501106

4713G

2017-06-13 6-12-17 Stressed birds/DOAs At approximately 7:00 on June

12 in the holding shed for Establishment P34668, I observed the

following conditions:  four of six outward exhaust fans on the

side of the building were operating, and of the four “walls” of

fans along the docks within the shed, one wall had four of

twelve fans operating; the other 3 walls had zero fans operating.

 The fans on the opposite (airflow inward) side of the structure

were also non-functional.  The fans that were running were the

only ones that were hooked up to a power source.  No misters

were installed.  A maintenance man who was filling the

generators powering the fans said that no birds were held

overnight and the fans are turned on as soon as birds start

showing up in the early morning hours. At 7:00 it was not too

hot in the shed with all of the bay doors open, but there was a

distinct temperature/airflow difference in the cages directly next

to operating fans and those that had a wall of cages blocking

the breeze.  Additionally, at this time there was still an open

bay – if the shed was full, the bay doors closed, or the

temperatures higher (as they were predicted to be for much of

the week), I anticipate that the shed could rapidly become

dangerously hot. In the CO2 stunning area, there were three of

five fans along the wall running, two bay doors open, and a

large industrial fan opposite the room from the other fans to

move air, but it was nonetheless very warm.  When I was in the

area at 10:45, many of the birds on the truck were panting, and

by the time the last of the birds were being unloaded at

approximately 13:00, nearly all of the birds were panting/visibly

stressed. There were ten trucks from one lot presented today. 

The numbers of deads from each load are as follows, with the

first trucks arriving earliest (first truck approximately 4:00 in

stunning area, last truck approximately 13:00): Truck # 

Deads 1 5 2 18 3 19 4 30 5 41 6 

87 7 244 8 179 9 361 10 389 The issue

of adverse environmental conditions resulting in DOAs has been

raised in two previous MOIs and at the most recent weekly

meeting.  In fact, the establishment acknowledged in response

to the 5-19-17 MOI that the non-functional fans were a

contributing cause to a high mortality day; that response also

stated that the fans would be hooked up promptly. It is

unacceptable for birds to be held in stifling heat due to a

longstanding lack of preparation for what are predictable
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 161

EstNbr EstName Task_Code MOI# Date Description

weather conditions in this part of the country. 

P34668 Simply Essentials

Poultry, LLC

04C05 SFJ391109

3013G

2017-09-13 At approximately 1045, I observed several chickens hanging

over the bleed trough that had not had their necks cut to bleed

out.  These uncut birds extended from the entrance of the

trough to the entrance of the scalding tank, and appeared to be

effectively stunned/ unconcious.  At the time of my observation,

 had the line stopped and

the situation under control.  Maintenance personnel were

examining the killing machine (automated blade that cuts the

necks to bleed out the birds).  had employees

beginning to cut chickens that were hanging above the trough. 

Once the killing machine was repaired, the line was started at a

slow speed so that and another employee could cut

chickens as they were exiting the trough before entering the

scalding tank. I stood in a position to view chickens exiting

Picker 2 before entering the wing scalder.  I counted 98 cadavers

from the time the line was restarted until I a saw a consistency

in normally bled-out carcasses (approximately five to 10

minutes). I expressed my concern to that uncut

chickens filled the shackles between the scalding tank and the

back-up killer, and that I counted approximately ninety cadavers

coming out of the scalding tank.  I informed him that although I

think he had the situation under control and did a good job at

ensuring no chickens entered the scalding tank alive, I was still

going to share my observations with my supervisor. After

discussing the situation with my supervisor, I informed 

 that I would be documenting this

situation in an MOI.

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 162

EstNbr EstName Task_Code MOI# Date Description

P34668 Simply Essentials

Poultry, LLC

04C05 SFJ261009

4020G

2017-09-20 At approximately 0900 hours on 9/19/17 while performing

ante-mortem inspection in the live hang department, I observed

a cage (on the trailer of the 7th trailer load of chickens in lot 1)

with a floor from a subset cage holding chickens collapsed onto

chickens in the subset cage below it.  The cages have 5 levels

with a division down the center which makes 10 subset cages to

the 1 cage.  Each subset has a metal door on one side of the

cage.  These doors are hinged at bottom of each subset and

therefore open from the top.  In this particular cage the first two

(from the top) subset cages on one side of the center divider

were each missing half of their floor.  The floors are constructed

of 2 plastic panels that snap in place on the framework of the

cage.  These first two subsets with the incomplete floors were

not carrying chickens.  The third subset was carrying chickens

and its floor was collapsed down onto the chickens in the fourth

subset cage.  The collapse was located at the end adjacent to

the door.  The fourth subset door was open and resting on the

adjacent cage, making approximately a 45 degree angle

opening.  There were approximately 4 chickens located between

the collapsed floor and the door.  They appeared to be alive.  I

could observe only 1 dead chicken under the collapsed floor at

this time.  There were more alive chickens inside the fourth

subset cage, and all the chickens in the 3rd subset appeared to

be alive.  I tagged the cage with a USDA Rejection

Tag # B41933978 and notified 

 and .  When the

establishment employees removed the cage from the trailer,

they found 7 dead birds inside the fourth subset cage.  Each

subset holds approximately 25 chickens.  At approximately

0920 hours I discussed the situation with Plant Manager Donnie

Peters.  He informed me that the cages are owned by the

establishment itself, Simply Essentials.  He also informed me

that the field manager (of loading the birds at the farms) was on

his way to the establishment to assess the situation.  After

further review and discussion, I removed my tag from the cage

so the live birds could be slaughtered. At approximately 1500

hours, I met with to discuss how damaged cages

were repaired.  There is a facility (shop) in New Hampton, IA

owned by Simply Essentials with Simply Essentials employees

who provide maintenance on the trucks, trailers, and cages. 

Damaged cages are stored in an area on the establishment

(b) (6)

(b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 163

EstNbr EstName Task_Code MOI# Date Description

premises until a full load of approximately 22 cages are

available for repair.  They get transferred to New Hampton and

repaired there. There have been previous discussions with the

establishment management about the conditions of the live bird

cages.  Yesterday I observed a cage with a door missing to one

of the bottom subset cages, with chickens inside of it.  I

discussed with about my

observation, and he informed me that he contacted the person

responsible for loading chickens as soon as he had seen the

cage, himself.  This conversation was not recorded in an MOI.  In

prior weekly meeting discussions (MOI SFJ1006094605E and

SFJ4714091807G), I was informed that cages in poor repair are

marked or kept back to be repaired before being loaded back

onto a truck.  I observed a cage without a door (very likely the

same cage from yesterday’s discussion) loaded onto the very

first truck from today’s production lot 1.  It did not have any

distinctive markings to indicate it was in poor repair.  I also

observed the establishment load a cage with a door that shut

poorly (in fact it would only shut if the floor was buckled) being

loaded back onto Truck #1 this morning.  This cage also did not

have any distinctive markings on it to indicate it was in poor

repair.  In addition to today’s and previous observations, Today I

also observed another cage on the 7th trailer load from lot 1

that was missing a door to a subset cage containing chickens. 

Plant Manager Donnie Peters was informed an Good

Commercial Practices MOI would be documented.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 164

EstNbr EstName Task_Code MOI# Date Description

P34668 Simply Essentials

Poultry, LLC

04C05 SFJ101309

0325G

2017-09-25 At approximately 1240 hours while I was performing

ante-mortem inspection in the Live Receiving Department, I

observed a cage on the trailer of load twelve of the day's

production with a missing door to a subset of the cage with

chickens inside.  All the chickens inside the cage appeared to be

uninjured and in good health.  I informed and showed 

 of my findings.  He summoned

.  I showed the

cage and informed him of my intent to document an MOI.  I

ensured the birds were removed from the subset cage and

placed onto the conveyor belt that moves chickens from the

cage dumper to the for stunning, before

the cage was moved by forklift to the cage dumper. The

establishment must employ humane methods of handling and

slaughtering consistent with Good Commercial Practices in a

way that minimizes injury to poultry.  Poultry are to be handled

in a manner that prevents needless injury and suffering. 

Employing humane methods of handling and slaughtering that

are consistent with good commercial practices increase the

likelihood of producing unadulterated product.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 165

EstNbr EstName Task_Code MOI# Date Description

P39 Pine Manor Inc. 04C05 ULL421202

0807G

2017-02-07 On February 6, 2017, at approximately 1350 hours, while I

 was showing around 

Poultry I observed one (1) live and stressed but sound young

chicken buried under two (2) DOA carcasses in a DOA barrel.

There were twelve (12) dead-on-arrival (DOA) chickens in this

particular DOA barrel in the live hang room at the time of my

observation.  In addition, one (1) module holding birds was

observed to be dumped on the dump conveyor. The

establishment employee did not wait to dump the next cage

before the conveyor was clear, and therefore birds were

dumped on top of other birds which resulted in discomfort and

excitement. I summoned ) and

 to notify them of this finding.  

immediately went through the DOA barrel and the live bird was

immediately removed from the DOA barrel, hung, stunned and

slaughtered and put back into production due to its healthy and

good state. Moreover, the plant’s employee was instructed to

wait to dump the next cage after the conveyor is clear so that

birds are not dumped on top of live birds.  I reminded 

and that the PPIA and Agency regulations

do 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. I recommended that the

plant 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, and provided ) a

copy of this document. I 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. Respectfully, 

P39 Miller Poultry.

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

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

(b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 166

EstNbr EstName Task_Code MOI# Date Description

P39 Pine Manor Inc. 04C05 ULL351402

3008G

2017-02-08 On Wednesday February 8, 2017, at approximately 1358 hours

while performing a poultry good commercial practices task, I,

, observed one (1) sound bright alert and

responsive bird in the condemn barrel with an estimated eight

(8) DOA birds. was observing me

perform my observations and he put the live bird back into

production. I explained that I will document an MOI because it

is not in accordance with good commercial practices, in that

birds should not die from causes other than slaughter. I also

discussed my finding with who explained he will

monitor the barrels more closely. I provided a copy of the MOI

to ) and explained that a copy

of the MOI will be forwarded to the District Office and the

District Veterinary Medical Specialist (DVMS) in case additional

follow-up is recommended.

P40183 Sanderson

Farms, Inc.

04C05 PEH100603

4009G

2017-03-09 Establishment P40183, Sanderson Farms, March 8, 2017, 1115

hours. In attendance: ,

 and This

Memorandum of Interview (MOI) is issued for the following bird

mistreatment in Picking Department; on March 8, 2017 at

approximately 1105 hours while performing Poultry Good

Commercial Practices Task in the live hang room, I observed one

establishment employee picking a live bird from the floor and

throwing it into the drain, I immediately told the employee to

remove the bird from the drain, he removed the green cat walk

and grabbed the bird and hung it on the killing line. I went to

First Processing Manager Office and notified my findings and

discuss the bird mistreatment to , he called 

 and I also notified my findings

to him. The establishment was not following the Animal Welfare

Program. Also, the Poultry Product Inspection Act (PPIA) and

this agency regulation do require that the live poultry be

handling in a manner that is consistent with Good Commercial

Practices (GCP’s), and that they not die from causes other than

slaughter.

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

(b) (6)

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 168

EstNbr EstName Task_Code MOI# Date Description

P40183 Sanderson

Farms, Inc.

04C05 PEH291206

2805G

2017-06-05 Establishment P40183, Sanderson Farms, June 2, 2017, 0855

hours. In attendance:

 and

  This Memorandum of Interview (MOI) is issued

for the following potential mistreatment of a live bird in Live

Haul; on June 2, 2017 at approximately 0845 hours while

performing Poultry Good Commercial Practices Task

accompanied by between the offall and the

truck yard, we observed one live bird inside the USDA

Condemned yellow barrel; a Mighty Foam tag was attached to

the handle of the USDA barrel. stayed with the bird

while I went to Evisceration Office to notify and discuss the issue

with notified of the

issue and we all met at the offall. We discussed the issue and 

asked how this bird got inside the USDA

Condemned barrel, why is sanitation using USDA Condemned

barrel to clean up, and what are you going to do with the bird?

He stated that he will find out how the bird got inside the USDA

barrel and he is going to asked sanitation about why are they

using USDA barrel for cleaning purposes. After the discussion

with management they decided to sacrifice the bird, at

approximately 0900 hours 

disarticulated the chicken’s neck in presence of USDA and once

all movement ceased the establishment elected to condemn the

bird.

(b) (6)

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

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 169

EstNbr EstName Task_Code MOI# Date Description

P40183 Sanderson

Farms, Inc.

04C05 PEH520706

3521G

2017-06-21 Establishment P40183, Sanderson Farms, June 16, 2017, 0930

hours. In attendance

 and 

 This Memorandum of Interview (MOI) is issued for the following

potential mistreatment of live birds in Live Haul; on June 16,

2017 at approximately 0556 hours while performing Poultry

Good Commercial Practices Task inside the offall building, I

observed two live birds inside the USDA Condemned yellow

barrel. I notified and discussed the issue with . After

the discussion with he decided to sacrifice both

birds, at approximately 0615 hours cut the chicken

necks with a knife in presence of USDA and once all movement

ceased the establishment elected to condemn the birds. At

approximately 0930 hours, discussed the issue

with since is not the first time that this happened.

 stated that he will get with sanitation to ask

them, where exactly these birds are being found to try and pin

point where the birds are being left. also stated

that he would get with sanitation to discuss what they are going

to do with the chickens when found during sanitation.

(b) (6)

(b) (6) (b) (6)(b) (6)(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 170

EstNbr EstName Task_Code MOI# Date Description

P40183 Sanderson

Farms, Inc.

04C05 PEH022109

1712G

2017-09-12 On 9/12/2016, at approximately 2145 hours, while conducting

a GCP task in the Live Hang area I made the following

observations: I observed numerous DOA carcasses on the floor

in the Live Hang area. They were piled into two separate piles.

The first pile, near the end of the conveyor belt contained

approximately 20 birds. After further inspection, I observed the

pile moving. I moved several birds on the top of the pile and

noticed that there was a live bird present on the bottom the

pile. The second pile of birds was located between the wall and

conveyor leading to the main exit. It contained about 25 birds.

Because a live bird was found in the first pile, I inspected the

second pile and also found a live bird buried underneath the

dead birds. This bird was alert when retrieved from the pile of

DOAs. and 

 was notified of my

observations and concerns. If the live birds were allowed to

remain in the condition they were found without human

intervention, they likely would have died by asphyxiation due to

being smothered by the dead birds lying on top of them. 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. I recommend that management 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. A copy of this

document can be provided on request. Please provide an

explanation for these incidences. A copy of this MOI 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.

P419 Case Farms

Processing, Inc.

04C05 VDB05010

11618G

2017-01-18 At approximately 2219 hours on 1/17/2017 while performing

Poultry GCP’s, I observed a live chicken and a dead chicken on

the floor in Live Hang.  A plant employee came over and picked

them up and put them both in the DOA barrel.  I notified 

, of this and pointed out that the

live bird should not be in the DOA barrel.  The employee came

back over and removed the live bird.  The bird had not been

harmed.  At approximately 2240 hours, 

 was notified of this with present.

(b) (6)

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

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 172

EstNbr EstName Task_Code MOI# Date Description

P419 Case Farms

Processing, Inc.

04C05 VDB05020

63922G

2017-06-22 Est. P419, Case Farms, 6/22/2017, approximately 0119 hrs.

Present: Mr. Robertson, Assistant Plant Manager, 

nd At

approximately 0115 hrs after administering relief breaks, 

 and observed on the transfer belt a

red bird with its head still attached.  Upon closer examination,

there was no cut mark on the neck indicating that the bird died

by means other than slaughter.  This was brought to the

attention of who

called .  

entered in to the discussion between the

establishment and USDA.  The back-up killer was replaced with

another back-up killer.  No other cadavers were observed on the

line, indicating this was an isolated incident and the situation

was under control.  A similar incident occurred around

5/16/2017. This MOI will be forwarded to the District Office

and the District Veterinary Medical Specialist in case additional

follow-up is recommended. A copy of Federal Register Notice

Vol. 70, No.187, published September 2005 [Docket No.

04-037N] was provided.

(b) (6)

(b) (6)

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 173

EstNbr EstName Task_Code MOI# Date Description

P419 Case Farms

Processing, Inc.

04C05 VDB53210

70928G

2017-07-28 Est. P-419, Case Farms, July 28, 2100 hrs.  

and  At approximately 2050 hrs while

performing GCP's I observed the tractor hooking up to the trailer

loaded with chickens in Bay 12.  As it drove past me, I noticed

one of the cage doors was open and a chicken appeared about

to jump out.  I then observed what appeared to be a dead

chicken in the bay just vacated and left it for further

examination. I followed the trailer to live hang where the open

cage door and bird were attended to.  was

notified of my observations.  I went back to the bay and

examined the dead chicken. There were wet tire marks before

and after the carcass. It appeared popped open.  It appeared to

have just been run over.  PPIA and Agency regulations require

that live poultry be handled in a manner that is consistent with

good commercial practices (GCP's), and that they not die from

causes other than slaughter.  I recommend review of the Federal

Register on Treatment of Live Poultry Before Slaughter

(attached) for FSIS recommendations concerning treatment of

live poultry before slaughter.  This MOI will be forwarded to the

District Office and DVMS in case additional follow-up is

recommended.  Respectfully, P-419 Case

Farms.

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 174

EstNbr EstName Task_Code MOI# Date Description

P419 Case Farms

Processing, Inc.

04C05 VDB31050

84919G

2017-08-19 Establishment: 00419P Case Farms 121 Rand St. Morganton,

NC 28655 The purpose of this memorandum is documentation

of a Good Commercial Practice (GCP) incident involving live

chickens entering the scald tanks. At approximately 09:30 on

Friday, 08/18/17, inspectors on Line 1 reported an unusually

large number of cadavers.  The count for the line was 14 since

the shift had started at 06:00.  Matthew Martin, Plant Manager

was asked to accompany me, , to observe

the scald tank entry point.  During our observation of

approximately 10 minutes two chickens were noted that had

not been slaughtered; one entered the tank and one was

removed from the line just before entering the scald tank.  The

establishment had two backup killers in place.  They found the

backup killers were working right next to each other so they

separated them by several feet.  The problem cleared.   A

similar event occurred on 6/16 during a Good Commercial

Practice verification visit and is documented in MOI number

VDB2605082819G.        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. I recommend management 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. A copy of this federal

register notice can be provided on request. A copy of this MOI

and your response will be forwarded to the District Office and

the District Veterinary Medical Specialist for follow-up

recommendations. Cc Jon Strange, General Manager/VP of

Operations

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 175

EstNbr EstName Task_Code MOI# Date Description

P419 Case Farms

Processing, Inc.

04C05 VDB27050

82819G

2017-08-19 Establishment: 00419P Case Farms 121 Rand St. Morganton,

NC 28655 The purpose of this memorandum is documentation

of a Good Commercial Practice incident involving live chickens

entering the scald tanks. At approximately 13:45 on

Wednesday, 08/16/17, during a Good Commercial Practice

verification visit, 

 observed 5 chickens enter the scald tank alive over a

period of approximately 5 minutes.  The incident occurred on

Line 1.  A regulatory control was taken by stopping the line.  The

establishment adjusted the stunner and placed another backup

killer for the line.  The line was released at approximately

14:15.  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. I recommend management 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. A copy of this federal register

notice can be provided on request. A copy of this MOI and your

response will be forwarded to the District Office and the District

Veterinary Medical Specialist in case additional follow-up is

recommended. Cc Jon Strange, General Manager/VP of

Operations

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 176

EstNbr EstName Task_Code MOI# Date Description

P425 Northern Pride,

Inc.

04C05 MYG08100

50003G

2017-05-03 P425 Northern Pride, Inc 06:35 hours: Plant Manager Warren

Leighton, On Monday May 1, 2017 at

approximately 06:25 hours while performing Good Commercial

Practices Verification, I observed a bird that I suspected was still

breathing on the line.  The bird had passed through the blood

tunnel, and from the point of observation the bird had

approximately 52 seconds of travel time on the line prior to

entering the scalder.  I observed the bird did have a cut on the

neck.  As the bird turned the corner and passed out of view I

proceeded to the post picking area.  Approximately 4 minutes

later a well fleshed bird with diffusely red skin exited the picker. 

This bird was also observed by an establishment employee who

approached the line to remove the bird.  I removed the bird off

the line for further examination.  I observed the cut on the neck

was superficial and did not fully sever the carotid arteries and

jugular veins for adequate exsanguination.  I determined the

bird died from means other than slaughter. I placed US Retain

Tag B35188428 on the carcass. At approximately 06:35 hours I

discussed the findings with Plant Manager Warren Leighton.  I

showed him the carcass and the superficial neck cut.  Manager

Leighton mentioned the establishment has a humane handling

protocol and undergoes multiple audits a year which include

humane handling. Manager Leighton stated that he will discuss

this finding with the sticking employee and document the

conversation.  We discussed the importance of humane

treatment of all birds, which Manager Leighton agreed was

important. I advised Manager Leighton that an MOI would be

written and forwarded to the District Office for the

 and ) to

review, should additional follow-up be needed. Respectfully, 

(b) (6)

 OFO FSIS

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

(b) (6)

(b) (6) (b) 
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 177

EstNbr EstName Task_Code MOI# Date Description

P425 Northern Pride,

Inc.

04C05 MYG40050

51809G

2017-05-09 P425 Northern Pride, Inc 13:37 hours: Plant Manager Warren

Leighton, On Monday May 7, 2017 at

approximately 13:35 hours while performing Good Commercial

Practices Verification, I observed a bird on the line that had

passed the blood tunnel and was headed to the scalder.  The

bird was rhythmically breathing and blinking.  It had an arched

neck and was moving its head dorsally, and then laterally.  I

stopped the picking line, and Plant Manager Warren Leighton

removed the conscious bird from the line.  At this time it was

observed that the bird did have a cut on the neck, but the cut

was superficial and did not sever the carotid artery and jugular

vein for adequate exsanguination.  

  took the bird to the hanging area where he

rehung the bird for subsequent re-stunning and re-sticking. At

approximately 13:45 hours I discussed the findings with Plant

Manager Warren Leighton.  We discussed that this incident was

the second in two weeks.  (On May 1, 2017 a cadaver was

observed on the line after the observation of a possibly

breathing bird was made prior to the scalder).  Manager

Leighton stated there are two sticking employees, they are both

experienced. Each sticking employee has now been on sticking

duty when a bird was observed by USDA IPP to not be

adequately cut.  Manager Leighton stated he would meet with

both sticking employees after slaughter was completed for the

day to discuss sticking.  He noted that the first week of

production there were problems with heads becoming detached

in the picking machine, and the sticking employees were

warned about this.  Manager Leighton agreed he would rather

have a detached head in the picking machine than a live bird

going through the scalder, and he reiterated he would discuss

the importance of this with the sticking employees. I advised

Manager Leighton that an MOI would be written and forwarded

to the District Office for the 

 and , to review and they will

contact us should additional follow-up be needed. Respectfully,

(b) (6)

, OFO FSIS

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 178

EstNbr EstName Task_Code MOI# Date Description

P425 Northern Pride,

Inc.

04C05 MYG08060

61627G

2017-06-27 P425 Northern Pride, Inc 13:10 hours: Plant Manager Warren

Leighton, On Monday June 26, 2017 at

approximately 13:04 hours while performing Good Commercial

Practices Verification, I observed a bird on the line that had

passed the blood tunnel and was headed to the scalder.  The

bird was rhythmically breathing.  The bird’s eyes were closed

and the bird was not moving its head or neck.  I stopped the

picking line, and removed the

breathing, unconscious bird from the line.  At this time it was

observed that the bird did have a cut on the neck, and there was

a large blood clot that had formed cranially to the sticking

laceration.    took the bird

to the sticking area where the bird’s jugular vein was cut a

second time.  The bird continued to breathe from the time of

removal on the line past the time of the second stick, which was

estimated to be a total of approximately 60 seconds.  The bird

expired approximately 3-4 seconds after the second sick was

administered. At approximately 13:10 hours I discussed the

above observations with Plant Manager Warren Leighton.  I

expressed concern that the bird, although unconscious, was

breathing rhythmically for quite a length of time after removal

from the line.  From the location where birds are observed for

signs of consciousness and rhythmic breathing to entering the

scalder is approximately 50 seconds.  It is quite possible that

this bird, if gone unnoticed, would have died by drowning in the

scalder.  I advised Manager Leighton that an MOI would be

written and forwarded to the District Office for the 

, and , to

review and they will contact us should additional follow-up be

needed. Respectfully, , OFO

FSIS

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

(b) (6)

(b) (6)(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 179

EstNbr EstName Task_Code MOI# Date Description

P425 Northern Pride,

Inc.

04C05 MYG30070

71108G

2017-07-08 P425 Northern Pride, Inc 7/8/17 at 06:20 hours: Plant

Manager Warren Leighton, On Friday July 7,

2017 at approximately 11:04 hours while performing Good

Commercial Practices Verification, I observed a bird on the line

that had passed the blood tunnel and was headed to the

scalder.  The bird had an arched neck and was moving its head

back and forth while rhythmically breathing and blinking.  I

stopped the picking line, and Manager Warren Leighton

removed the conscious bird from the line.  The bird was

observed to have a superficial cut on the neck that had incised

the epidermis and subcutaneous tissues only. At approximately

11:10 hours on 7/7/17 I discussed the above observations with

Plant Manager Warren Leighton.  I expressed concern regarding

the trend of breathing unconscious birds and conscious birds

observed on the line thus far this season (one bird observed on

each of the following days: 5/1/17, 5/7/17, 6/26/17). Manager

Leighton agreed and stated he would be discussing the issue

with the establishment management team and the sticking

employees.  I stated that I would follow up with him regarding

corrective actions after these meetings were held. At

approximately 06:20 hours on 7/8/17 Manager Leighton

informed me that he had spoken to the sticking employees after

the end of shift on 7/7/17.  Manager Leighton stated that the

sticking employees have been the same two individuals for

multiple years.  Establishment records show that three cadavers

have been identified thus far this year by establishment

employees, and all the cadavers were identified during the

month of May.  Manager Leighton stated that to date under his

management this is the most birds identified as being conscious

or breathing on the line in one season.  It was discussed that

there has been no change to line speed in the sticking area this

year, and that plant management has ensured the sticking

employees are supplied with well-maintained knives.  Due to

concern for adequate lighting in the sticking area, plant

management will be installing an additional “spot light” type

light source to illuminate the sticking area without adding

significant additional light to the area to cause excitement to

the birds.   In addition, will alternate with

 in monitoring birds per

hour on the line for signs of breathing and consciousness.  This

will double the number of birds per hour monitored by the

(b) (6) (b) (6) (b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 180

EstNbr EstName Task_Code MOI# Date Description

establishment.  The establishment will continue to not maintain

written records of the GCPs at this time. I advised Manager

Leighton that an MOI would be written and forwarded to the

District Office for the 

and to review and they will contact us should

additional follow-up be needed. Respectfully, 

, FSIS OFO

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

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 182

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

04C05 000511001

0219G

2017-01-19 MOI for Sanderson Farms, Inc., P45910, St. Pauls, NC, 1215

hours.  In attendance at the meeting were Mr. Paul Smith, Plant

Manager, and . At approximately 9:30

am, 

was observing conditions in the live hang area during a

scheduled visit to observe good commercial practices at the

establishment.  She noticed that there was a live bird in the

dead on arrival (DOA) barrel.  She notified 

 of her findings.  had the

bird removed from the barrel and hung on the kill line.  I

notified of these findings.  I reminded him that it

is important that birds be handled in a manner consistent with

good commercial practices.  Preventing mistreatment of poultry

decreases the production of adulterated carcasses. I also

notified him that an MOI would be documented and sent to

District Office.  On Thursday, January 19, 2017, upon further

discussion with and , I

was informed that 2 establishment personnel involved in this

incident had been terminated.  Planned actions include lowering

the lights to enable better visualization of the birds, and

increasing the training for personnel in the live hang area.

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

(b) (6)

(b) (6) (b) (6)(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 183

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

04C05 000341605

4910G

2017-05-10 While I was conducting Poultry Good Comercial Practice Task at

around 4:00pm, I observed a bird on the live hang belt on it's

back struggling to breathe. During this time plant employees

had gone on their break, thus leaving the birds in live hang

unattended. I explained during my weekly meeting with the

establishment management, 5/10/2017, that birds on their

backs can not properly ventilate, which would eventually lead to

suffocation. As I continued to walk down the line, I noticed a

bird with a mutilated left rear leg. The bird was panting, had

pale wattles and comb, and it's eye were closed and neck

extended. The left leg had no feathers or paw remaining and the

skin had been de-gloved (removed). Lying adjacent to this bird

was another leg from a different bird that had been completely

amputated, with the same presentation (no skin, feathers, or

paw). I was not able to identify which bird this leg had come

from, but addressed my findings with 

 He informed me that there was an issue with the

cage dumper belt and the live hang belt and he will take care of

this situation promptly. NOTE* There was an error uploading

establishment's response, so it will be copied and pasted below;

Sanderson Farms, Inc. 2076 NC Hwy 20 • St. Pauls, North

Carolina 28384 Telephone (910) 674-4777 • Facsimile (910)

802-4686 June 26, 2006 Memorandum Subject: 

Response to MOI on Good Commercial Practices from

5/10/2017  Date:  5/11/2017 To:      The

management team met on the issues addressed in the MOI to

discuss a further plan of action and assess the corrective actions

implemented on 5-10-17.  The root cause of the incident was a

gap in the divider causing birds to get caught or pinched in

between the divider and the belt.  Maintenance lowered the

divider down to eliminate the gap in between the divider and

belt.  Also, maintenance added removable stabilizers to ensure

the divider is properly adjusted before the next production run. 

We will also have personnel monitoring the live hang belt during

all breaks for the next 30 days to ensure the problem has been 

eliminated.

                                                                                                             

                                                     Respectfully, . 

 Sanderson Farms, Inc. 2076 NC Hwy 20 St. Pauls, NC

28384 P-45910

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 184

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

04C05 000082105

2110G

2017-05-10 On May 10, 2017 at 1830 hours while performing a Good

Commercial Practice task, I observed the following condition at

the live hang belt:  At the very beginning of lunch break and as

the live hang employees were leaving the belt area for their 30

minute break, I observed a live hanger toss one of five

remaining birds that was not hung in a shackle back onto the

belt with the bird landing onto his back and remaining in that

position (birds that remain on their back can not properly

ventilate which would eventually lead to suffocation). The

employee then turned to leave for break. 

 stopped the employee and explained to him about

leaving birds on their backs. Also while looking at the live hang

belt, I observed approximately 2 to 3 poultry legs that were

wedged by their feet in a approximately 1-1/2 inch gap that had

developed between the belt and the Teflon partition. The legs

were completely severed at the junction of the Tibia and Femur

with the muscle, skin and feathers still attached. I then took

regulatory control of the live hang belt by applying USDA

Rejected tag # B37028513 and then showing

, and 

 the noncompliance. at 1833 hours. The live hang belt

was released after being repaired by maintenance and

re-inspected by USDA at 1926 hours. There was previous

discussion concerning Good Commercial Practices concerning

the same issues in a plant meeting on May 10, 2017 at 1630

hours.

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 185

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

04C05 000060505

3111G

2017-05-11 Establishment P 45910, Sanderson Farms, Inc.  May 8, 2017,

0615 hours.  In attendance: and .

. At approximately 6:15

am on May 8, 2017, I went to live hang and observed Good

Commercial Practices.  I saw that the birds were piled up at the

end of the live hang table.  The live hangers was having difficulty

getting the birds out of the pile up, having to tug on the birds to

dislodge them.  Also while observing this pile up, there were 3

birds with their legs stuck underneath the end panel where the

birds were piled up.  Live hang workers cleared the pile up and

removed the birds that had their legs under the panel.  I notified

 of my concerns

that the birds must not be mishandled; he stated that he would

address the issues.  Later in the shift, I also notified 

, of these same observations.  A copy of this

MOI will be submitted to the District Veterinary Medical

Specialist in the Raleigh District Office.

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 186

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

04C05 000572005

4018G

2017-05-18 On May 18, 2017 at 1815, the following condition was observed

in the Live Hang room:  At the end of the shift, a live hang

employee was observed picking several birds off the floor, two

of which were very much alive, flapping and kicking vigorously

and placing them into a stainless steel Dead on Arrival (DOA)

bin. The birds did not appear to have received cervical

dislocation. Seeing that USDA personnel and

), was observing the employee as he was walking up

to the DOA bin with the live birds, 

, started yelling for the employee to stop and not put

the birds into the container. The employee apparently, not

hearing, continued to place the birds into the container

immediately ran over to the employee and had him remove the

birds from the container and place them on the floor.  USDA,

 performed further ante-mortem inspection

confirming the live condition of the birds. He assessed

consciousness, by performing palpebral reflex on both of the

suspected birds. Palpebral reflex is assessed by gently tapping

along the inner edges of the eyelids with a fingertip. A positive

response is indicated by the animal blinking. The birds had a

positive response to palpebral reflex by blinking their eyes and

even opening their eyes immediately afterwards. Another

indication that the birds were alive was miotic (constricted)

pupils. A properly euthanized bird will have mydriatic (dilated)

and fixed pupils. According to the animal welfare plan from the

establishment, DOA birds will have cervical dislocation

performed by trained personnel, prior to being placed into the

DOA bin.  explained to that the birds had not

been properly euthanized and were still alive. 

 arrived shortly after the incident and 

 explained his findings and informed him that this would

be documented in an MOI.

(b) (6)

(b) (6)

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

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

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 187

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

04C05 000271006

3412G

2017-06-12 This MOI is to document the meeting held on June 12, 2017, at

11:00 am, between Mr. Dane Beall, Plant Manager at Sanderson

Farms, Inc. (P 45910) and , USDA FSIS.   The

meeting was held to discuss the concern that there have been

four recent incidents of mistreatment of live birds at the

establishment.  At the times of occurrence, these incidents were

brought to management’s attention and documented in

MOI’s.    Per the establishment, there have been issues with the

conveyor belts and also with employee training.  Raleigh District

Office is aware of these mishandling incidents and is monitoring

the situation.  It is important that the management of

Sanderson Farms, Inc. be proactive in ensuring that Good

Commercial Practices are followed when handling live poultry. 

Continued incidents of mistreatment could lead to the issuance

of a Letter of Concern.

P45910 SANDERSON

FARMS, INC

04C05 000231407

1214G

2017-07-14 This MOI is to document what was observed while conducting a

Poultry Good Commercial Practices on 07/13/2017. At

approximately 1800 hours I entered the Live Hang area

and observed approximately 1500 dead birds in the area. I

approached  and questioned him about the amount of

DOA's. He stated that he had multiple cages of mainly

dead birds. Upon further investigation at the trailer staging area

I observed in the 1st bay one fan not operating. The next 4 bays,

the trailers loaded with birds were approximately 10-12' away

from the fans and misters and in the final bay a empty trailer

with no birds parked beside the fans with a loaded trailer with

birds parked beside that. The empty trailer was blocking the air

flow from the fans and misters. I alerted 

 of my findings.  immediately notified Live Haul

supervisors and trailers were rearranged so that all loaded

trailer were parked in front of fans and misters. This has been a

on going issue and addressed in several USDA and establishment

meetings.

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 188

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

04C05 000060708

1915G

2017-08-15 This MOI is to document the discussion between Mr. Dane Beall,

Plant Manager, Sanderson Farms, Inc. (P45910), and 

, on August 15, 2017 at 7:00 am.   Last

Tuesday, following a power outage on second shift, the

establishment carried over approximately 6 1/2 trailers of birds

to be slaughtered on first shift.  Of the birds in the flock,

3768 were DOA's (dead on arrival birds).  This information was

discovered by while he was reviewing

establishment paperwork.  The establishment failed to notify

USDA of this failure of Good Commercial Practices.  Through

discussions with establishment management last week and this

week, I was informed that the DOA rate was attributed to

the birds being held overnight.  I was also informed that there

was no plan in place to account for birds being held overnight

on the trailers.  Establishment management could not be

determine whether the fans and misters, used to help keep the

birds cool, were off or on.  Going forward, stated that

when birds were held overnight,  both second shift and third

shift offal personnel would monitor that the misters and fans

were on during hot weather.   I advised of the

importance of handling the birds consistent with Good

Commercial Practices, as is required by Agency regulations and

the PPIA.  I also informed him that a copy of this MOI would be

submitted to the District Veterinary Medical Specialist in Raleigh

District Office.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (4) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 189

EstNbr EstName Task_Code MOI# Date Description

P46091 Ozark Mountain

Poultry, Inc.

04C05 000350205

5709G

2017-05-09 On calendar date 5/9/17, at 0026 and 0031 hours respectively, I

 while performing a routine Good Commercial

Practice (GCP) task observed the following deviations.  AT 0026

hours, line #2 in the pinning room department had 28 miss-cuts

from the automatic knife cutter (kill machine).  The

establishment lead person in that department had previously

performed routine maintenance to re-set the machine due to a

change in lots of young poultry carcasses and released said

machine as acceptable to flow of slaughter.  At 0031 hours, line

#1 had 8 miss-cuts from the automatic knife cutter (kill

machine), 6 of which appeared to be a result of miss-hung (hung

by only one leg) young poultry carcasses.  Establishment

46091P has incorporated a process control check into their

prerequisite program, stating that the automatic knife cutter

will be timed in accordance to 500 birds, approximately 4

minutes, at the line speed of birds per minute. No more

than 5 birds can be missed to be in process limits.  This is the

same guidelines followed by IPP while performing GCP’s.  I

immediately informed supervisor in training, 

, and

 of my finding and the forthcoming MOI report,

and the possibility of coming noncompliance record.  At this

time, took control of the situation by having the

automatic knife cutter readjusted.  Good Commercial Practice

were periodically monitored, kill machine in particular,

throughout the remainder of the production shift.

P46091 Ozark Mountain

Poultry, Inc.

04C05 FAA222309

5928G

2017-09-28 On calendar date 9/28/17, while performing a routine Good

Commercial Practice (GCP) task I, , observed two

obvious cadavers on kill/pinning line # 2.  At 2030 hours, I

positioned myself at a point in the process line between the

final picker, and before the pre-sorter station.  At 2032 hours I

observed, simultaneously, two young poultry carcasses that

were obvious cadavers.  Neither carcass had been cut, both still

had their heads, and each were the bright red color indicative of

a cadaver.  The pre-sorter on line # 2 promptly removed said

carcasses from the process line as required. FSIS rules are very

clear in 9CFR, that breathing must be stopped prior to scalding

to prevent death by means other than slaughter.  I informed

, of my findings and of the

forthcoming MOI.  I also informed that any further

findings may result in a possible noncompliance record.

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

(b) (6)

(b) (6) (b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 190

EstNbr EstName Task_Code MOI# Date Description

P468 Peco Foods, Inc. 04C05 JVD321705

0106G

2017-05-06 Est P468, Peco Foods, May 6th 2017, 17:13 hours. In

attendance: and 

 At approximately 17:13 hours,

while observing conditions in the 1st processing room, just prior

to the scalder on line 2, I observed a single bird still breathing

before entering the scalder. I immediately reported my findings

to , who then slowed the line to

bpm. I verified again that no birds were entering the scalder

breathing. At approximately 17:58 hours requested

the line speed be increased to bpm with the replacement of

the current back up killer; I had approved of his request. I

reminded that the PPIA and the agency regulations do

require that live poultry be handled in a manner that is

consistent with good commercial practices (GCP's), and that

they not die from causes other than slaughter. I provided 

 a copy of the Treatment of Live Poultry Before Slaughter,

published September 2005, and recommended he review it. I

notified that this MOI will be forwarded to my front

line supervisor as well as the districts District Veterinary Medical

Specialist (DVMS) in case additional follow-up is recommended.

Respectfully, P468 Peco

Foods.

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

(b) (6)

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

(b) (6)

(b) (6) (b) (4) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 191

EstNbr EstName Task_Code MOI# Date Description

P46826 SHENANDOAH

VALLEY

ORGANIC

04C05 BOK50140

92021G

2017-09-21 On 9/21/2017 at approximately 1:30 pm, I, 

, and the plant manager Bob Bahr, while inspected

the cutting knife in the live hang area, discovered approximately

80 loose birds on the upper catwalk in the hangers’ area, and

approximately 100 loose birds under the cat walk.  I

immediately told the live hang supervisor to stop hanging birds

and collect all of the loose birds.  Upon closer inspection,

three recentlly dead birds were discovered.  The birds were

warm to the touch and blood had not coagulated or dried on

the birds.  Two of the three dead birds were found on the lower

level of the live hang area.  One of these birds was decapitated,

the other died of trauma to its chest cavity.  The other recently

dead bird was found on the upper level, under the beginning

portion of the bird crate conveyer.  This bird was dismembered,

but again recently dead due to the uncoagulated blood, and

warm body condition.    I notified the plant manager, Bob Bahr

of my intension of writing an MOI.  I also explained that I would

be contacting , of the incident.  

was at P46826 yesterday performing a routine Good

Commercial Practices assessment.   These findings are not

consistent with Poultry Good Commercial Practices.  Measures

should always be taken to ensure that poultry are handled and

kept in conditions that will not result in death or injury

unnecessarily.  In addition, “employing humane methods of

handling and slaughter that are consistent with good

commercial practices increases the likelihood of producing

unadulterated product”.  Establishment P46826 is hereby

advised to address the above observations and take preventative

measures to reduce the likelihood of occurrence.   

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 192

EstNbr EstName Task_Code MOI# Date Description

P46897 IHSAN FARMS,

IIC

04C05 000580806

3727G

2017-06-27 An observation was made  of  the live hang employees were

grabbing and lifting the birds by their wings totransport them

from a conveyor belt into cones (a distance of approx. 3 feet). I

immediately intervened to prevent the chickens from being

handled in this manner and establishment management

instructed the employees on how to properly pick up and move

the chickens. During the time of observation, the employees

began using proper handling techniques to move the live

chickens after using a translater to help them understand. I had

never seen the birds handled in this manner prior to this date, I

found the two employees were new and once they were

instructed they began to do the job properly. During this

observation even though the handling was questionable no

birds resulted in  dying by means other than slaughter or that

the handling prevented the birds from being properly bled out

before entering the scalder. These  employees behavior was

discussed..  It was found that all birds were appropriately cut

and appeared to have been properly bled out by the time they

reached the scald tank. Also observed was that no birds were

breathing when they entered the scalder.

P46897 IHSAN FARMS,

IIC

04C05 000150508

0416G

2017-08-16 At approximately 1305 while on the line at the USDA inspection

station giving a break, I observed a bird on the line with the

head still attached and no kill cut. I immediately notified .

) of the concern. Due to the

fact  that birds are manually slaughtered on a cone line and

then removed by hand to the scalder line, it is clear that human

error was the cause in this case.Poultry good commercial

practices require that all birds be slaughtered, fully bled out,

and no longer breathing prior to entering the scalder.

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 193

EstNbr EstName Task_Code MOI# Date Description

P481 Tyson Foods,

Inc.

04C05 VHF30030

73511G

2017-07-11 On 7/10/17 at approximately 0252 hours the 

 observed the following good commercial

practice failure. The cull basket affixed to the end of the

livehang belt was piled up with numerous small birds. The

chickens in the basket were primarily small and or sick birds

that were piled two deep. The basket was filled with culled birds

and the mesh at the bottom was not visible. During observation

multiple gasping birds were seen pressed to the bottom of the

pile. I notified , of the

issue and plant management was then notified. 

immediately started culling the birds via the cervical dislocation

and placing their carcasses in the condemn barrels located at

the end of the line, as is normal for this establishment.

, approached at this point

and assisted him in the culling of the birds, expediting the

process. I observed multiple dyspneic birds, but none that

appeared to have died by suffocation. FSIS observation

continued until all the birds were euthanized and placed in

condemn barrels. I then left the live hang area and spoke with

. I

explained the condition I observed and the corrective actions

taken by . It was explained to me that this area of

the plant had been understaffed at the time of the incident and

those that were present were new employees. had

instructed an employee to stand by the cull basket and

euthanize birds as needed, but the instruction has been

misunderstood. Instead the employee had culled the birds that

were currently in the basket and returned to his duties on the

line hanging birds. These factors coupled with the high numbers

of culled, small birds that night lead to the incident listed above.

It is not within the standards of good commercial practice to let

birds asphyxiate, as was the potential outcome of this incident,

and as such is concerning to the USDA. This is the third

occurrence of birds piling up at the cull basket this year. The

previous incidents occurred during day shift on 8/25/16 as

outlined in MOI VHF1907082509G and during night shift on

11/11/16 as outlined in MOI VHF0105110811G. Repeated

incidences such as these are an issue and can result in further

action being taken by FSIS personnel.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 194

EstNbr EstName Task_Code MOI# Date Description

P481 Tyson Foods,

Inc.

04C05 VHF42040

83321G

2017-08-21 On 8/21/17 at approximately 0249 hours while conducting a

routine Good Commercial Practice verification task the 

 observed the following GCP failure. While

monitoring empty trailers in the holding shed noted

one small bird in the 8th cage back from the windbreak on the

top level of trailer 186. The cages on this trailer were all secured

indicating the trailer was ready to be taken to another farm and

loaded with more birds. Based on this information it was

determined that this bird had been left on the trailer as an

oversight by plant personnel. immediately alerted

, of this issue

and accompanied both ,

and to the receiving shed. and

 confirmed that there was a bird in the otherwise

empty trailer. This trailer was returned to the unloading area,

the affected cage was unloaded, and the bird was removed from

said cage to be reintroduced into the slaughter process. 

 stated that due to staffing shortages that night the

both the dumper and backup dumper were unavailable and as

such the plant employee dumping the cages was relatively

inexperienced. The employee was retrained and it was

emphasized that cages are to be checked after dumping to

insure no birds are overlooked and reloaded onto the trailers. It

is not in good commercial practice to cause a bird undo stress

through transportation only to forgo slaughter or euthanasia.

Repeated shipping coupled with food and water withholding are

a great cause of stress and as such should be avoided. It should

also be noted that comingling birds from different growers

could potentially lead to disease transmission between farms. 

No other similar MOIs have been issued for birds being left on

outgoing cages within the last year.

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 195

EstNbr EstName Task_Code MOI# Date Description

P510 House Of

Raeford Farms

04C05 RHB28100

31713G

2017-03-13 On 03/09/2017 at approximately 0730 hours I was conducting

part of the good commercial practice verification task in the

evisceration department. I was observing the birds going by on

the line from the bleed out area before they entered the scalder.

 I noticed that one bird going by had his head up and was

looking around. So I stopped the line before the bird reached

the scalder. I then notified ,

and , of my findings.

Per 9 CFR 381.65 (b) 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. used a knife to

decapitate the bird.  stationed a second back up

killer at a point on the line prior to the scalder.  He discussed

that he was having the kill machine blade adjusted to assist with

the issue.  The line was restarted.  I monitored the line at

multiple times during the day and did not see any live birds

enter the scalder. A copy of this MOI will be forwarded to the

 and to the

circuit .  If you have any questions you can

contact me or the .

(b) (6)(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 196

EstNbr EstName Task_Code MOI# Date Description

P51179 Sanderson

Farms, Inc.

04C05 000101901

5509G

2017-01-09 On January 6, 2017 at approximately 1544 hours I informed

 of an increase in cadavers

being presented to inspectors since the start of the shift (2 hours

prior). said he would follow up with 

. At approximately 1549 hours

while performing a Good Commercial Practices task at the

scalder entrance on line 1, a live bird was observed to enter the

scalding tank. The bird had an un-cut neck and was still

breathing as it was conveyed into the scalder. When the bird

exited the scalder I confirmed the neck was not cut. and

 both observed the

cadaver. I discussed with that I had seen an increased

incidence of cadavers over the previous 2 hours, especially on

line 1. As immediate corrective actions to prevent more bird

suffering said he would investigate the cause and

counsel the employee working as the backup cutter on line 1. 

It is important to treat poultry in a way that ensures they are

not breathing and are properly bled out when they enter the

scalder. Employing humane methods of handling consistent

with Good Commercial Practices and 9 CFR 381.65(b) can help

produce an unadulterated product. A similar incident was

observed on October 25, 2016 and documented on MOI

#0005913101026G (

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 197

EstNbr EstName Task_Code MOI# Date Description

P51179 Sanderson

Farms, Inc.

04C05 000201401

2310G

2017-01-10 On January 9, 2017 at approximately 1800 hours while

performing a Good Commercial Practices task at the scalder

entrance on line 2, a live bird was observed to enter the scalding

tank. The bird had an un-cut neck and was still breathing as it

was conveyed into the scalder. When the bird exited the scalder

I confirmed the neck was not cut. 

 observed the cadaver. As immediate corrective

actions said he would discipline the employee

responsible. At approximately 1810 hours I discussed my

findings with plant manager Mr. Larry Gatewood. I informed Mr.

Gatewood of the live bird entering the scalder and that a similar

incident was observed the previous working day, Friday January

6, 2017. It is important to treat poultry in a way that ensures

they are not breathing and are properly bled out when they

enter the scalder. Employing humane methods of handling

consistent with Good Commercial Practices and 9 CFR 381.65(b)

can help produce an unadulterated product. The similar incident

on January 6, 2017 was documented on MOI

#0001019015509G ( )

P51179 Sanderson

Farms, Inc.

04C05 000351501

4431G

2017-01-31 On January 30, 2017 at approximately 2048 hours while

performing a Good Commercial Practices task at the scalder

entrance on line 1, a live bird was observed to enter the scalding

tank. The bird had an un-cut neck and was still breathing as it

was conveyed into the scalder. When the bird exited the scalder

I confirmed the neck was not cut. 

 and both

observed the cadaver. As corrective actions stated that

he counselled the employee stationed at the back up cutter. It

is important to treat poultry in a way that ensures they are not

breathing and are properly bled out when they enter the

scalder. Employing humane methods of handling consistent

with Good Commercial Practices and 9 CFR 381.65(b) can help

produce an unadulterated product. A similar incident was

documented on January 9, 2017 and documented on MOI

#0002014012310G 

(b) (6)

(b) (6)

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 198

EstNbr EstName Task_Code MOI# Date Description

P51179 Sanderson

Farms, Inc.

04C05 000291503

4901G

2017-03-01 On February 28, 2017 at approximately 1757 hours while

performing a Good Commercial Practices task at the scalder

entrance on line 2, a live bird was observed to enter the scalding

tank. The bird had an un-cut neck and was still breathing as it

was conveyed into the scalder. When the bird exited the scalder

I confirmed the neck was not cut. 

 observed the cadaver. As immediate corrective

actions said he would train the employee

responsible. It is important to treat poultry in a way that

ensures they are not breathing and are properly bled out when

they enter the scalder. Employing humane methods of handling

consistent with Good Commercial Practices and 9 CFR 381.65(b)

can help produce an unadulterated product. The similar incident

on January 30, 2017 was documented on MOI

#0003515014431G 

P51179 Sanderson

Farms, Inc.

04C05 000021404

4524G

2017-04-24 On April 21, 2017 at approximately 1909 hours while

performing a Good Commercial Practices task at the scalder

entrance on line 2, a live bird was observed to enter the scalding

tank. The bird’s neck was not cut; its head was up, and was still

breathing as it was conveyed into the scalder. When the bird

exited the scalder I confirmed the neck was not cut. 

 observed the cadaver. As

immediate corrective actions said he would counsel

the responsible employee. He believed the employee was

focusing too much on rehanging the birds that were hung by

one leg and needed to focus more on ensuring all birds were

slaughtered. It is important to treat poultry in a way that

ensures they are not breathing and are properly bled out when

they enter the scalder. Employing humane methods of handling

consistent with Good Commercial Practices and 9 CFR 381.65(b)

can help produce an unadulterated product. 

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 199

EstNbr EstName Task_Code MOI# Date Description

P51179 Sanderson

Farms, Inc.

04C05 000341905

4911G

2017-05-11 On Wednesday May 10, 2016 at approximately 2135 hours

while performing a GCP task in the live hang room a chicken

was observed crushed underneath a belt at the end of the live

hang belt. The chicken was crushed between the belt and the

roller at the end of the live hang belt and was obviously dead.

The carcass was shown to the .

When attempted to remove the carcass it ripped

apart. I asked what he was going to do to prevent

further bird suffering and he said he would increase monitoring

of the area. On Thursday May 11, 2017 was

informed that an MOI about the incident would be

documented. Processing equipment must be maintained in a

manner that will not cause bird injury and suffering. It is

important to treat poultry in a way that ensures they do not die

by means other than slaughter. Employing methods of handling

consistent with Good Commercial Practices and 9 CFR 381.65(b)

can help produce and unadulterated product. 

(b) (6)

(b) (6) (b) (6)(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 200

EstNbr EstName Task_Code MOI# Date Description

P51179 Sanderson

Farms, Inc.

04C05 000171505

4731G

2017-05-31 On Tuesday May 30, 2017 at approximately 2003 hours while

performing a GCP task in the live hang room a weak bird was

sorted off the live hang belt by an employee and placed onto

the floor. picked up the bird by

its head and tossed it onto a small pile of dead birds on the floor

at the end of the belt. The bird was obviously still alive and

breathing. was asked why he picked up the bird by

its head and tossed it. He said he did not know that the bird was

alive. When I asked what he was going to do with

the bird he responded that he was going to wait for it to die. 

was informed that it is unacceptable to pick up live

birds by the head and toss them onto the floor. The bird was

collected by another supervisor and placed onto the kill line.

The incident was discussed with the shift manager Mr. Larry

Gatewood later in the evening. On Wednesday May 31, 2017

the incident was also discussed with 

 and Plant Manager Mr. John Stedman at the weekly

establishment exit meeting. and Mr. Stedman were

informed that a GCP MOI would be documented. 

stated that he would provide retraining to to

prevent more bird suffering. Picking up live birds by the head

and tossing them onto the floor is not consistent with Good

Commercial Practices because it resulted in needless bird

suffering. It is important to treat poultry in a way that ensures

they do not die by means other than slaughter. Employing

methods of handling consistent with Good Commercial

Practices and 9 CFR 381.65(b) can help produce and

unadulterated product. 

(b) (6)

)

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 201

EstNbr EstName Task_Code MOI# Date Description

P51179 Sanderson

Farms, Inc.

04C05 000571406

0301G

2017-06-01 On May 31, 2017 at approximately 1732 hours while

performing a Good Commercial Practices task at the scalder

entrance on line 1, a live bird was observed to enter the scalding

tank. The bird’s neck was not cut; its head was up, and was still

breathing as it was conveyed into the scalder. When the bird

exited the scalder I confirmed the neck was not cut. 

 observed the cadaver. As

immediate corrective actions to prevent ongoing bird suffering

 said he would discipline the responsible employee. 

It is important to treat poultry in a way that ensures they are

not breathing and are properly bled out when they enter the

scalder. Employing humane methods of handling consistent

with Good Commercial Practices and 9 CFR 381.65(b) can help

produce an unadulterated product. 

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 202

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO06000

21527G

2017-02-27 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS 1301

James St. Hattiesburg, MS 39401 Mr. Monroe, At

approximately 2300 hours on February 26. 2017, while verifying

Good Commercial Practices (GCPIP) at P517, Mar-Jac Poultry,

MS, the following less than GCPIP incident was observed on the

back dock in the live hang area.   One live bird was observed

with rhythmic breathing in a pile of 4 Dead on Arrival (DOAs) at

the end of the conveyor for the South picking line.  The bird was

removed from the pile for further examination.  The bird, albeit

weak, assumed a sternal posture, exhibited pupillary reflexes,

and uplifted head.   was

notified.  The bird was humanely euthanized by rapid cervical

disarticulation.  and 

 were also notified.  

Comingling live bird(s) with DOAs can lead to suffocation and

death.  This practice is not consistent with Good Commercial

Practices. At approximately 2345 hours, a meeting was in the

USDA office with and 

The incident was discussed regarding placement of

a live bird in a pile of DOAs and preventative measures for

preventing future incidences.  placed an employee

on the floor to pick up DOAs and live birds which may drop onto

the floor.   indicated this is standard practice prior

to this incident. As per Federal Register Notice Docket No.

04-037N dated September 28,2005, "Treatment of Live Poultry

before Slaughter," the Food Safety Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by Good Commercial (GCPs) as described by industry

guidelines. Respectfully, ,

Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046 cc: 

Mr. Perry Davis, DM        Dr. David Thompson, DDM        Dr.

Larry Davis, DDM        Mr. Don Coley, DDM        

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

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

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 203

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO01000

33801G

2017-03-01 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS 1301

James St. Hattiesburg, MS 39401 Mr. Monroe, At

approximately 2345 hours, while performing the Good

Commercial Practices in Poultry (GCPIP) verification task at

P519, Mar-Jac Poultry, MS on February 28, 2017, the following

less than GCPIP incident was observed.  One (1) live young

chicken with rhythmic breathing, pupillary reflexes, and uplifted

head entered the scald tank on the South picking line.  

 was notified of the incident.  Birds entering

the scald tank while still breathing results in adulterated

product and is not in accordance with Good Commercial

Practices.   Birds must be handled in manner which is humane

and does not cause unnecessary suffering prior to slaughter.  A

second verification of approximately 500 birds prior to the scald

tank had no live birds entering the scald tank.  This incident was

determined to be an isolated incident and not a loss of process

control. A meeting was held with and 

 at office at approximately 2400

hours.   The incident was discussed and stated the

stunning and kill equipment would be checked prior to starting

up after the regularly scheduled lunch break as a preventative

measure. As Per Federal Register Notice Docket No.

04-037N, "Treatment of Poultry Prior to Slaughter", the Food

Safety and Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely and abide by Good

Commercial Practices (GCPs) as described in industry guidelines.

Respectfully, , Canton, MS 9024 

1039 W. Fulton St. Canton, MS 39046 cc:  Mr. Perry Davis, DM

Dr. David Thompson, DDM Dr. Larry Davis, DDM Mr. Don

Coley, DDM 

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

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 204

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO08210

43003G

2017-04-03 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS, LLC 1301

James St. Hattiesburg, MS 39401 Mr. Monroe, At

approximately 2347 hours on April 2, 2017 while verifying the

PHIS Good Commercial Practices (GCPIP) verification task, the

following less than GCPIP incidences were observed at P519,

Hattiesburg, MS.   One young chicken, from an approximate 500

bird random sample subgroup, with uplifted head, pupillary

reflexes, rhythmic breathing, and no cut to the neck entered the

scald tank on the north picking line which feeds evisceration line

#2.  and

 were notified.   A

second verification from an approximate 500 bird random

sample subgroup had one live young chicken with uplifted head,

pupillary reflexes, rhythmic breathing, and no cut to the neck

entering the scald tank on the north picking line at

approximately 0025 hours on April 3, 2017.    and

 were notified of the 2nd incident.   A third

verification from an approximate 500 bird random sample

subgroup did not have any live bird(s) entering the scald tank

at approximately 0040 hours on April 3, 2017.  The first two

incidences were determined to be isolated events and

not repetitive or multiple demonstrating a trend or loss of

process control.   Live bird(s) entering the scald system live is

a less than GCPIP and results in adulterated product.  The

establishment is responsible for ensuring that birds under their

control on the official premises are treated in a humane manner

that will minimize excitement, discomfort, injury and/or death

by means other than slaughter.  A meeting was held at 

 office at approximately 0005 hours on April  3, 2017. 

 and were

present.   The incidences and measures to correct the less than

GCPIP incidents were discussed.  said he would be

in communication with 

 and the maintenance department.   A

brief meeting was held at office with 

 and after the 2nd incident.  

was present during the 3rd verification and notified by 

that the establishment was slaughtering birds in accordance

with GCPIP. As per Federal Notice Vol. 70, No. 187, Docket No.

04-037N dated September 28, 2005, "Treatment of Live Poultry

Prior to Slaughter", the Food Safety and Inspection Service (FSIS)

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

(b) (6)

(b) (6)

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 205

EstNbr EstName Task_Code MOI# Date Description

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

Relief, Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046

cc:  Mr. Perry Davis, DM        Mr. Don Coley, DDM        Dr. David

Thompson, DDM        Dr. Larry Davis, DDM        

        

P517 Mar-Jac

Poultry-MS

04C05 QOO15140

60615G

2017-06-15 Good Commercial Practices MOI: On June 15,

2017 @ approximately 1034 hours, I observed a less than good

commercial practice while performing an Ante-mortem and

Good Commercial Practices (GCP) check at P-17766. While

performing the GCP, I noticed that a trailer under the unloading

shed had numerous birds that were breathing rapidly and

gasping with outstretched necks (distressed).  The outside

temperature was 82°F.  The fans surrounding the bird trailers

were blowing at full speed, but no misters were installed

throughout the unloading shed.  

 stated that the misters are only located under the

holding shed.  A survey of the holding shed revealed that the

misters were powered on; however, they had very little output. 

This could only be observed when the fans were not powered. 

In the on state, there was no mist observed or felt in any house. 

The holding shed was free of trailers for the remainder of the

day since the last truck had been transported to the unloading

shed.  was also notified of

this unacceptable practice.  In accordance with FSIS Docket No.

04-037N, Treatment of Live Poultry before Slaughter, live

poultry must be handled in a manner that is consistent with

good commercial practices. In order for this to occur, poultry

must be treated in a manner that will minimize excitement,

discomfort and accidental injury throughout processing.  A copy

of this Memorandum of Interview will be sent to the Jackson

District Office for further review.  Thanks for your attention to

this matter. Respectfully, 

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 206

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO04020

74104G

2017-07-04 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry LLC, MS 

1301 James St. Hattiesburg, MS 39401                 Mr. Monroe, 

                At approximately 2038 hours on July 3, 2017, while

verifying Good Commercial Practices (GCPIP) at P 517, Mar-Jac

Poultry LLC, MS, the following less than GCPIP incident was

observed on the back dock in the live hang area. One live bird

was observed with rhythmic breathing in a pile of 3 Dead on

Arrival (DOAs), inside the DOA bin. The bird was removed from

the pile for further examination. The bird, albeit weak, assumed

a sternal posture, exhibited pupillary reflexes, and uplifted head.

and were notified.

The bird was humanely euthanized by rapid cervical

disarticulation. Comingling live bird(s) with DOAs can lead to

suffocation and death. This practice is not consistent with Good

Commercial Practices. At approximately 2230 hours, a meeting

was in the Evisceration Manager office with 

 and 

 The incident was discussed regarding placement of a

live bird in a pile of DOAs and preventative measures for

preventing future incidences. stated that the

establishment would provide a designated employee on how to

properly perform rapid cervical disarticulation. If the number of

DOAs was higher than normal they would add an additional

employee to prevent this from happening in the meantime. Jeff

Delia also stated that they would get with upper management

on a solution to this problem to prevent future reoccurrences. 

As per Federal Register Notice Docket No. 04-037N dated

September 28, 2005, “Treatment of Live Poultry before

Slaughter, “the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to treat poultry humanely and

abide by Good commercial Practices (GCOs) as described by

industry guidelines Respectfully, CC:

Mr. Don Coley, DM Dr. Larry Davis, DDM Dr. Don Thompson,

DDM 

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 207

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO25040

70124G

2017-07-24 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS, LLC 1301

James St. Hattiesburg, MS 39401 Mr. Monroe, At

approximately 0300 hours while verifying the PHIS

GoodCommercial Practices (GCPIP) verification task, the

following less than GCPIP incidences were observed at Mar-Jac

Poultry, LLC, MS, P517, Hattiesburg, MS. One live young

chicken, from an approximate 500 bird random sample

subgroup, with uplifted head, pupillary reflexes, rhythmic

breathing, and no cut to the neck entered the scald tank on the

north picking line which feeds evisceration line #1.  A bird

consistent with a cadaver exhibiting pooling of blood in

the lower breast, neck, and head was verified after the first

picker.    requested the hanger on

evisceration line#1 to remove the bird from the line at

approximately 0305 hours.  

was called to the evisceration department and notified

at approximately 0308 hours of a bird entering the scalder while

still breathing.  A second verification from an approximate 500

bird random sample subgroup on the north picking line at

approximately 0309 hours had one live young chicken with

uplifted head, pupillary reflexes, rhythmic breathing, and no cut

to the neck entering the scald tank at approximately 0312

hours.  A bird consistent with a cadaver exited the 1st picker at

approximately 0316 hours.  requested the hanger on

evisceration line #1 to remove the bird from the line at

approximately 0317 hours.   was called to the

evisceration department and notified of a second bird entering

the scalder on the north picking at approximately 0320 hours.

 A third verification from an approximate 500 bird random

sample subgroup on the north picking line did not have any live

bird(s) entering the scald tank at approximately 0322 hours. 

The first two incidences were determined to be isolated events

and not repetitive or multiple events demonstrating a trend or

loss of process control. Live bird(s) entering the scald system live

is a less than GCPIP and results in adulterated product. The

establishment is responsible for ensuring that birds under their

control on the official premises are treated in a humane manner

that will minimize excitement, discomfort, injury and/or death

by means other than slaughter. A meeting was held in the

USDA IIC office with and 

  The incidences and measures to correct the less

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 208

EstNbr EstName Task_Code MOI# Date Description

than GCPIP incidents were discussed.  said he would

be in communication with the back up cutters regarding the

uncut birds entering the scalder.   also stated the

equipment was checked by maintenance, the stunning

equipment and the killing machine were working within normal

tolerances, and birds were being slaughtered in accordance with

GCPIP.  advised a Memorandum of

Information would be documented and issued to plant

management pending review by 

. As per Federal Notice Vol. 70, No.

187, Docket No. 04-037N dated September 28, 2005,

"Treatment of Live Poultry Prior to Slaughter", the Food Safety

and Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely and abide by Good

Commercial Practices (GCPs) as described in industry guidelines.

Respectfully, , Canton, MS 9024 

1039 W. Fulton St. Canton, MS 39046 cc:  Mr. Don Coley

acting DM       Dr. David Thompson, DDM       Dr. Larry Davis,

DDM       

(b) (6)       

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 209

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO26030

84409G

2017-08-09 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS, LLC 

1301 James St. Hattiesburg, MS 39401 Mr. Monroe,     At

approximately 0513 hours on August 8, 2017 while verifying the

PHIS Good Commercial Practices (GCPIP) verification task, the

following less than GCPIP incidences were observed at Mar-Jac

Poultry, LLC, MS, P517, Hattiesburg, MS. One live young

chicken, from an approximate 500 bird random sample

subgroup, with uplifted head, pupillary reflexes, rhythmic

breathing, and no cut to the neck entered the scald tank on the

north picking line which feeds evisceration line #1. A bird

consistent with a cadaver exhibiting pooling of blood in the

lower breast, neck, and head was verified after the first picker. 

 was present in the

picking room and observed the cadaver as the bird exited the

first picker.  A second verification from an approximate 500 bird

random sample subgroup on the north picking line had one live

young chicken with uplifted head, pupillary reflexes, rhythmic

breathing, and no cut to the neck entering the scald tank at

approximately 529 hours. A bird consistent with a cadaver

exited the 1st picker at approximately 533 hours.  

 was notified at

approximately 0536 hours. A third verification from an

approximate 500 bird random sample subgroup on the north

picking line had no live bird(s) entering the scald tank at

approximately 0539  hours. The first two incidences were

determined to be isolated events and not repetitive or multiple

events demonstrating a trend or loss of process control. Live

bird (s) entering the scald system live is a less than GCPIP and

results in adulterated product. The establishment is responsible

for ensuring that birds under their control on the official

premises are treated in a humane manner that will minimize

excitement, discomfort, injury and/or death by means other

than slaughter.     A meeting was held in the USDA IIC office

with  and at

approximately 0330 hours on August 9, 2017. The incidences

and measures to correct the less than GCPIP incidents were

discussed. said he would be in communication with

the back up cutters supervisor regarding the uncut birds

entering the scalder.  advised a

Memorandum of Information would be documented and issued

to plant management pending review by ,

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 210

EstNbr EstName Task_Code MOI# Date Description

District Veterinary Medical Specialist.     As per Federal Notice

Vol. 70, No. 187, Docket No. 04-037N dated September 28,

2005, "Treatment of Live Poultry Prior to Slaughter", the Food

Safety and Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely and abide by Good

Commercial Practices (GCPs) as described in industry

guidelines. Respectfully, ,

Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046 cc: 

Dr. David Thompson, acting DM Mr. Don Coley, DDM Dr. Larry

Davis, DDM 

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 211

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO37080

82709G

2017-08-09 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS 1301

James St. Hattiesburg, MS 39401 Mr. Monroe,     At

approximately 0703 hours on August 9, 2017, the following less

than Good Commercial Practices in Poultry (GCPIP) incident was

observed in the live hang pen at Mar-Jac Poultry, LLC, MS,

Hattiesburg, MS.  Dead on Arrival (DOAs) were piled up on the

crossover conveyor and at the end of the South picking line. On

further observation, 

removed 2 live birds from the crossover conveyor and returned

the birds to the picking line.   then removed a live

bird from the pile of DOAs at the end of the South picking line

and returned the bird to the picking line.  The live birds were

comingled with the DOAs and could not be identified until

removed from the piles.  was notified of the less

than GCPIP at the time of the incident.  

 was notified at approximately 0707 hours. 

Mr. Jeff Monroe Plant Manager was requested at approximately

0707 hours.     Comingling live birds with DOAs can cause

suffocation and death by means other than slaughter resulting

in adulterated product.  The establishment must ensure that

birds under their control on the official premises are treated in a

manner that will minimize excitement, discomfort, injury and or

death by means other than slaughter.     A meeting was held in

the USDA IIC office at approximately 0715 hours

 and Mr. Monroe were present.   The less than GCPIP

incident was discussed along with findings related to the

establishment’s sorting practices of DOAs and preventative

measures including the head puller prior to the DOA bin which

had been put in place, but not fully implemented.   Mr. Monroe

was advised that a GCPIP Memorandum of Information (MOI)

would be issued to plant management pending review by

 

    As per Federal Notice Vol. 70, No. 187, Docket No. 04-037N

dated September 28,2005, “Treatment of Live Poultry Prior to

Slaughter”, the Food Safety and Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

, Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046 

cc:  Dr. David Thompson, acting DM        Mr. Don Coley, DDM 

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

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 212

EstNbr EstName Task_Code MOI# Date Description

       Dr. Larry Davis, DDM        

(b) (6)        
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 213

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO27040

81316G

2017-08-16 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS 1301

James St. Hattiesburg, MS 39401 Mr. Monroe, At

approximately 0234 hours on August 16, 2017, the following

less than Good Commercial Practices in Poultry (GCPIP) incident

was observed at the transfer belt on the north picking line at

Mar-Jac Poultry, LLC, MS, Hattiesburg, MS. 

Approximately 250-300 birds were piled up on the transfer belt

approximately 8 feet along the belt and 3-4 birds deep causing

birds to be trapped underneath other birds on the belt.   

 was notified of the less than

GCPIP.  After the belt was cleared, one bird was observed

trapped between the dumper belt and the side of the dumper.  

The bird had an abrasion to the left side of the breast.   A plant

maintenance employee removed the injured bird from the

entrapment and placed the bird on the transfer belt. Piling on

of birds can cause discomfort, injury, and suffocation resulting

in death by means other than slaughter and adulterated

product. The establishment must ensure that birds under their

control on the official premises are treated in a manner that will

minimize discomfort, injury and or death by means other than

slaughter. A meeting was held in the Quality Assurance office

at approximately 0245 hours.  

 and were

present.   The establishment’s handling practices of live birds

was discussed along with repetitive findings of overcrowding of

birds on the dumper belts.   and were

advised that a GCPIP Memorandum of Information (MOI) would

be issued to plant management pending review by 

 As per

Federal Notice Vol. 70, No. 187, Docket No. 04-037N dated

September 28,2005, “Treatment of Live Poultry Prior to

Slaughter”, the Food Safety and Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

 Canton, MS 9024 1039 W. Fulton St. Canton, MS

39046 cc:  Dr. David Thompson, acting DM        Mr. Don

Coley, DDM        Dr. Larry Davis, DDM        

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

(b) (6)

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 214

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO15060

81324G

2017-08-24 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS 1301

James Street Hattiesburg, MS 39401 Mr. Monroe,  At

approximately 0526 hours on August 24, 2017, the following

less than Good Commercial Practices in Poultry (GCPIP) incident

was observed in the live hang pen at Mar-Jac Poultry, LLC, MS,

Hattiesburg, MS.  Approximately 12 Dead on Arrival (DOAs)

were piled up on the crossover conveyor  and approximately 8 

DOAs at the end of the south picking line conveyor. 

 then removed 3 DOAs from under the end

of the north picking line conveyor and 1 live bird. The live bird

was comingled with the DOAs and could not be identified until

removed from the pile.  The bird had a deep bruise to the right

wing and abrasions with feathers missing on the left side of the

body. The bird was hung on the picking line and returned to

production. was notified of the less than GCPIP at

the time of the incident.  

 was notified at approximately 0531 hours.  Mr. Jeff

Monroe Plant Manager and 

were notified at approximately 0544 hours. Comingling live

birds with DOAs can cause suffocation and death by means

other than slaughter resulting in adulterated product.  The

establishment must ensure that birds under their control on the

official premises are treated in a manner that will minimize

discomfort, injury and or death by means other than slaughter. 

A meeting was held in the Plant Manager's office at

approximately 1000 hours.  , 

 Mr. Monroe, , and

Mr. Joel Williams Vice President, Mar-Jac Poultry, MS  were

present.   The less than GCPIP incident was discussed along with

findings related to the establishment’s sorting practices of DOAs

and the placement of an employee to pickup the DOAs in a

timely manner and properly dispose of the carcasses.  Mr.

Monroe stated that an employee would be designated to pickup

DOAs.  Comingling of DOAs is a repetitive finding as

documented in GCPIP MOI Q0002704081316G dated

08/16/2017.  Mr. Monroe was advised that a GCPIP

Memorandum of Information (MOI) would be issued to plant

management pending review by

 As per Federal Notice

Vol. 70, No. 187, Docket No. 04-037N dated September

28,2005, “Treatment of Live Poultry Prior to Slaughter”, the

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

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

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 215

EstNbr EstName Task_Code MOI# Date Description

Food Safety and Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely and abide by Good

Commercial Practices (GCPs) as described in industry guidelines.

Respectfully, , Canton, MS 9024 

1039 W. Fulton St. Canton, MS 39046 cc:  Dr. Larry Davis, DM

       Mr. Don Coley, DDM        Dr. David Thompson, DDM       

(b) (6)        

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 216

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO08120

82130G

2017-08-30 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS 1301

James Street Hattiesburg, MS 39401 Mr. Monroe, At

approximately 1058 hours on August 30, 2017, the following

less than Good Commercial Practices in Poultry (GCPIP) incident

was observed at P517 Mar-Jac Poultry, MS, Hattiesburg, MS.  

One (1) live young chicken with uplifted head, rhythmic

breathing, pupillary reflexes, and no cut to the neck from an

approximate 500 bird random subgroup sample entered the

scald tank on the north picking line which feeds evisceration line

#1.   A carcass with head attached consistent with a cadaver

exhibiting ventral pooling of blood to the neck and head  and a

reddish hue exited the 1st picker on the north picking line at

approximately 1102 hours.  The bird was removed from the

evisceration line at approximately 1104 hours by a plant

employee and retrieved by 

as notified at

approximately 1106 hours and given an opportunity to examine

the cadaver.  

was notified at approximately 1108 hours, and Mr. Jeff Monroe

Plant Manager, , and 

 were notified at

approximately 1110 hours.  A second verification check of an

approximate 500 birds random subgroup sample on the north

picking line at approximately 1134 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. Allowing bird(s) to enter the scald tank while

still breathing is a less than GCPIP and causes needless suffering

and death and resulting in adulterated product.   Poultry

slaughter establishments must take every precaution to ensure

poultry under their control on the official premises are treated

in a humane manner, subjected to minimal excitement, and not

subjected to discomfort, injury, or death by means other than

slaughter. A meeting was held in the USDA IIC office to discuss

the less than GCPIP at approximately 1145 hours.  and

Mr. Monroe were present.  The incident and planned action to

prevent recurrence were discussed. Mr. Monroe stated he would

be in contact with the contract firm that provides ritual

slaughter for the establishment regarding the uncut bird

entering the scalder.  Mr. Monroe was advised a GCPIP

Memorandum of Interview would be issued to management

(b) (6)

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 217

EstNbr EstName Task_Code MOI# Date Description

pending review by As per Federal

Notice Vol. 70, No. 187, Docket No. 04-037N dated September

28,2005, “Treatment of Live Poultry Prior to Slaughter”, the

Food Safety and Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely and abide by Good

Commercial Practices (GCPs) as described in industry guidelines.

Respectfully, , Canton, MS 9024 

1039 W. Fulton St. Canton, MS 39046 cc:  Dr. Larry Davis, DM 

       Dr. David Thompson, DDM        Mr. Don Coley, DDM       

        

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 218

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO45100

93704G

2017-09-04 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS 1301

James St. Hattiesburg, MS 39401 Mr. Monroe, At

approximately 1007 hours on September 4, 2017, the following

less than Good Commercial Practices in Poultry (GCPIP) incident

was observed in the live hang pen at P517 Mar-Jac Poultry, LLC,

MS, Hattiesburg, MS.  Approximately 8-10 Dead on Arrival

(DOAs) were piled up at the end of the south picking line

conveyor.  One bird, comingled in the pile of DOAs was

observed with the head buried and the body visible, breathing

albeit labored   A plant employee was requested by 

 to remove the bird from the pile.  The bird

was hung on the picking line and returned to production.  

 was notified at

approximately 1012 hours. Comingling live birds with DOAs can

cause suffocation and death by means other than slaughter

resulting in adulterated product.  The establishment must

ensure that birds under their control on the official premises are

treated in a manner that will minimize discomfort, injury and or

death by means other than slaughter. A meeting was held in

the USDA IIC office at approximately 1030 hours.  and

Mr. Jeff  Monroe Plant Manager were present.   The less than

GCPIP incident was discussed along with findings related to the

establishment’s sorting practices of DOAs and preventative

measures including the head puller prior to the DOA bin which

had been put in place, but not fully implemented.  Mr. Monroe

stated that the live hang supervisor had been instructed to place

an employee on the floor to pick up DOAs and live birds which

has fallen to the floor at the start of the shift.  Mr. Monroe was

advised that a GCPIP Memorandum of Information (MOI) would

be issued to plant management pending review by 

. As per

Federal Notice Vol. 70, No. 187, Docket No. 04-037N dated

September 28,2005, “Treatment of Live Poultry Prior to

Slaughter”, the Food Safety and Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

 Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046 

cc:  Dr. Larry Davis, DM        Mr. Don Coley, DDM        Dr. David

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

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 219

EstNbr EstName Task_Code MOI# Date Description

Thompson, DDM        

(b) (6)        
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 220

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO50070

93505G

2017-09-05 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS 1301

James Street Hattiesburg, MS 39401 Mr. Monroe, At

approximately 0533 hours on September 5, 2017, the following

less than Good Commercial Practices in Poultry (GCPIP) incident

was observed at Mar-Jac Poultry, MS, Hattiesburg, MS.   One (1)

live young chicken  with uplifted head, rhythmic breathing,

pupillary reflexes, and no cut to the neck from an approximate

500 bird random subgroup sample  entered the scald tank on

the north picking line which feeds evisceration line #1.   A

carcass with head attached, consistent with a cadaver,

exhibiting ventral pooling of blood to the neck and head ,and a

reddish hue exited the 1st picker on the north picking line at

approximately 0537 hours.  The bird was removed from the

evisceration line at approximately 0539 hours by a plant

employee and retrieved by .  

 was notified at

approximately 0542 hours and given an opportunity to examine

the cadaver.  A second verification check of an approximate 500

birds random subgroup sample on the north picking line at

approximately 0547 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. 

Allowing bird(s) to enter the scald tank while still breathing is a

less than GCPIP and causes needless suffering and death and

resulting in adulterated product.   Poultry slaughter

establishments must take every precaution to ensure poultry

under their control on the official premises are treated in a

humane manner, subjected to minimal excitement, discomfort,

and injury, or death by means other than slaughter. A meeting

was held in the Plant Manager's office to discuss the less than

GCPIP at approximately 0800  hours.  and Mr. Jeff

 Monroe Plant Manager were present.  The incident and

planned actions to prevent recurrence of this event were

discussed.  Mr. Monroe stated he would be in contact with the 

 to ensure equipment

was properly setup  and functioning and personnel were present

in the kill room  at the beginning of the shift.  Mr. Monroe was

advised a GCPIP Memorandum of Interview would be issued to

management pending review by . As

per Federal Notice Vol. 70, No. 187, Docket No. 04-037N dated

September 28,2005, “Treatment of Live Poultry Prior to

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 221

EstNbr EstName Task_Code MOI# Date Description

Slaughter”, the Food Safety and Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046

cc:  Dr. Larry Davis, DM        Dr. David Thompson, DDM        Mr.

Don Coley, DDM        

(b) (6)        

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 222

EstNbr EstName Task_Code MOI# Date Description

P517 Mar-Jac

Poultry-MS

04C05 QOO54090

95207G

2017-09-07 Mr. Jeff Monroe Plant Manager Mar-Jac Poultry, MS 1301

James St. Hattiesburg, MS 39401 Mr. Monroe, At

approximately 0656 hours on September 7, 2017, the following

less than Good Commercial Practices in Poultry (GCPIP) incident

was observed in the live hang pen at P517 Mar-Jac Poultry, LLC,

MS, Hattiesburg, MS.   Approximately 4-5 Dead on Arrival

(DOAs) were piled up at the end of the south picking line

conveyor.  One bird, comingled in the pile of DOAs was

observed with the head buried and the body visible, breathing

albeit labored   A plant employee removed the bird from the

pile and returned the bird to production.  

 was notified at approximately 0657 hours,

and was

notified at approximately 0700 hours. Comingling live birds

with DOAs can cause suffocation and death by means other

than slaughter resulting in adulterated product.  The

establishment must ensure that birds under their control on the

official premises are treated in a manner that will minimize

discomfort, injury and or death by means other than slaughter. 

A meeting was held in the USDA IIC office at approximately

0715 hours.  and Mr. Jeff Monroe Plant Manager were

present.   The less than GCPIP incident was discussed along with

findings related to the establishment’s sorting practices of DOAs

and preventative measures, which were not fully implemented

or ineffective.   This is a repeated incident similar to the incident

documented in GCP Memorandum of Interview (MOI)

Q0044100094701 dated September 4, 2017.  Mr. Monroe had

stated previously the live hang supervisor had been instructed to

place an employee on the floor to pick up DOAs and live birds

form the floor at the start of the shift.  Mr. Monroe was advised

that a GCPIP Memorandum of Information (MOI) would be

issued to plant management pending review by 

 As per

Federal Notice Vol. 70, No. 187, Docket No. 04-037N dated

September 28,2005, “Treatment of Live Poultry Prior to

Slaughter”, the Food Safety and Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

, Canton, MS 9024 1039 W. Fulton St. Canton, MS

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

(b) (6)

(b) (6)

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 224

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

04C05 KMH59230

21326G

2017-02-26 Wayne Farms, LLC 525

Wayne Drive Laurel, MS 39440 , At

approximately 2139 hours, while verifying Good Commercial

Practices in Poultry (GCPIP), the following less than GCPIP

incident was observed at the live receiving area.  A young

chicken was entrapped in a hole in the floor of the cage on the

top right hand compartment.  The cage was located on the 5th

row, bottom cage on a company transport trailer.  The leg of the

chicken was bloody, and the chicken was not able to extricate

itself from the floor of the cage.   

 was notified and was requested to remove the cage from

the trailer.   The cage was removed, set to the side, and the bird

was removed from the hole in the floor of the compartment. 

The bird had bloody abrasions to the right leg above the hock. 

The bird was placed into production.   

 was also notified of the incident.  

Allowing birds to become entrapped in damaged equipment can

cause injury and/or death and is not consistent with Good

Commercial Practices.   The establishment must ensure birds on

the official premises be treated humanely while under the

establishment's control. A meeting was held in the Evisceration

Superintendent's office at approximately 0230 hours on

February 27, 2017.  

, and were present.  

The incident and preventative measures to prevent future

equipment failure and entrapment of birds were discussed.  

 stated damaged cages are routinely set aside for repair

when identified. As per Federal Register Notice Docket No.

04-037N dated September 28, 2005, "Treatment of Live Poultry

before Slaughter, " the Food Safety Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by Good Commercial Practices (GCPs) as described by

industry guidelines. Respectfully, 

Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046

cc:  Mr. Perry Davis        Dr.  David Thompson, DDM        Dr.

Larry Davis, DDM        Mr. Don Coley, DDM        

        

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

(b) (6)

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

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 225

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

04C05 KMH49200

51901G

2017-05-01 Wayne Farms, LLC,

P519 525 Wayne Dr. Laurel, MS 39401 , At

approximately 0327 hours on April 28, 2017 while performing

the PHIS Good Commercial Practice in Poultry (GCPIP)

verification task, the following less than GCPIP incident was

observed in the live hang are of P519, Wayne Farms, LLC, Laurel,

MS.   A young chicken was observed at the end of the live hang

conveyor belt in a red container, with chicken manure and

feathers which had collected from the belt.   Only the back of

the bird was visible.  When the manure and feathers were

removed, the bird raised its head.  The bird was viable but had

its head buried under the manure and feathers.   Six live young

chickens were observed at the end of the belt on the floor of the

live hang area.  The bird was removed from the red container by

a plant employee and placed back into production along with

the six other live birds. 

 and 

and back dock supervisor were notified.    Allowing birds to

become entrapped under debris can cause suffocation and

death by means other than slaughter.  The establishment has a

responsibility to ensure that all birds on the official premises be

treated in a humane manner to prevent unnecessary suffering,

injury, or death by means other than slaughter while under their

control. A meeting was held briefly with and

 at the time of notification.   A meeting was held with

 and 

 at approximately 2300 hours on April 30, 2017.  

was unavailable at the time of the incident on April 28, 2017.  

 stated any forthcoming response to the GCPIP

Memorandum of Information would be addressed by 

, Wayne Farms, LLC,

Laurel, MS. As per Federal Register Docket Notice 04-037N,

dated September 28,2015, “Treatment of Live Poultry Before

Slaughter”, the Food Safety and Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely prior

to slaughter and abide by Good Commercial Practices (GCPs) as

described in industry guidelines. Respectfully, 

, Canton, MS 9024 1039 W. Fulton St. 

Canton, MS 39046 cc:  Mr. Perry Davis, DM        Mr. Don Coley,

(b) (6)

(b) (6)

(b) (6)

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

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 226

EstNbr EstName Task_Code MOI# Date Description

DDM        Dr. Larry Davis, DDM        Dr. David Thompson, DDM 

       (b) (6)        

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 228

EstNbr EstName Task_Code MOI# Date Description

Thompson, DDM                 

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 229

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

04C05 KMH20220

51703G

2017-05-03 Wayne Farms, LLC, P519 

525 Wayne Drive Laurel, MS 39401 , At

approximately 2047 hours while verifying the PHIS Good

Commercial Practices in Poultry (GCPIP) verification task at

Wayne Farms, LLC, Laurel, MS, P519, 3rd shift, the following less

than GCPIP incident occurred.  

 and observed a

live bird with labored breathing and with the head covered in a

pile of Dead on Arrivals (DOAs) outside the live hang pen.  The

DOA bin was not in place and the live birds and DOAs had been

piled on the sidewalk.  requested a plant employee to

summon a supervisor.  Per request, a plant employee

removed the birds from the one by one from the pile.  The DOAs

were decapitated and placed in the DOA bin.   While the plant

employee was removing the birds from the pile, another bird

with labored breathing was removed from the pile of DOAs.  The

moribund birds were euthanized by rapid cervical

disarticulation.  

 and 

 were notified.   Birds

entrapped in a pile of DOAs are subject to die by suffocation or

means other than slaughter.   The establishment has a

responsibility to handle birds in their care on the official

premises in a humane manner that will prevent unnecessary

suffering, injury, or death by means other than slaughter. A

meeting was held in the USDA office at approximately 2115

hours.  , and

 were present.   The less than GCPIP incident and

the contributing factors leading up to the incident, including the

DOA bin not being in place and comingling live birds with DOAs,

were discussed. and were advised a

GCPIP MOI would be issued documenting the incident. As per

Federal Register Docket Notice 04-037N, dated September

28,2005, “Treatment of Live Poultry Before Slaughter”, the Food

Safety and Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely prior to slaughter and

abide by Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

, Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046 (b) (6)

(b) (6)

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

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

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 230

EstNbr EstName Task_Code MOI# Date Description

cc:  Mr. Perry Davis, DM        Mr. Don Coley, DDM        Dr. Larry

Davis, DDM        Dr. David Thompson, DDM        

        

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 231

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

04C05 KMH47040

63805G

2017-06-05 Wayne Farms, LLC Complex Manager 

525 Wayne Drive Laurel, MS 39440 At

approximately 2227 hours on June 4, 2017, while verifying the

PHIS Good Commercial Practices in Poultry (GCPIP) verification

task at P519, Wayne Farms, LLC, Laurel, MS, the following less

than GCPIP incident was observed.   One live young hen chicken

from an approximately 500 bird sample subgroup entered the

first scald tank exhibiting rhythmic breathing, pupillary reflexes,

uplifted head and no cut to the neck.   Verification was made at

the exit of the last picker at approximately 2230 hours.   The

carcass was bright red in appearance, with pooling of blood in

the head, neck, and upper breast consistent with a cadaver.  

 requested the cadaver be removed at

rehang by a plant employee. 

 was notified and observed the cadaver

removed from the evisceration line.   A second verification prior

to the first scalder of an approximate 500 bird sample subgroup

had no bird(s) entering the scalder at approximately 2237

hours.   A visual check of the kill room evidenced the birds were

being stunned properly with an occasional bird bypassing the

kill machine.  This was determined to be an isolated incident

and not a loss of process control.   Bird(s) entering the scalder

while still breathing is not consistent with GCPIP and results in

adulterated product.  Establishments are responsible for birds

entering the official premises and must employ GCPIP to

prevent unnecessary suffering, injury and death. A meeting was

held in the office of at approximately 0430 hours

on June 5, 2017.   , and 

were present.  discussed the incident and further

findings with was advised a GCPIP

Memorandum of Information (MOI) would be issued to the

plant.   stated any forthcoming response would be

made by . As per

Federal Register Notice Docket 04-037N, dated September

28.2005, “Treatment of Live Poultry Prior to Slaughter”, the

Food Safety Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to abide by

Good Commercial Practices (GCPs) as described in industry

guidelines. Respectfully, ,

Canton, MS 39046 1039 W. Fulton St. Canton, MS 39046 

Cc:  Mr. Perry Davis, DM         Mr. Don Coley, DDM         Dr.

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

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 232

EstNbr EstName Task_Code MOI# Date Description

Larry Davis, DDM         Dr. David Thompson, DDM         Dr.

Harvey Kermit, DDM         

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 233

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

04C05 KMH01050

64129G

2017-06-29 Wayne Farms, LLC Complex Manager 

525 Wayne Drive Laurel, MS 39440 , At

approximately 2356 hours on June 28, 2017, while verifying the

PHIS Good Commercial Practices in Poultry (GCPIP) verification

task at P519, Wayne Farms, LLC, Laurel, MS, the following less

than GCPIP incident was observed.   One live young chicken

from an approximately 500 bird sample subgroup entered the

first scald tank exhibiting rhythmic breathing, pupillary reflexes,

uplifted head and no cut to the neck.   Verification was made at

the exit of the last picker at approximately 0101 hours.   The

carcass was bright red in appearance, with pooling of blood in

the head, neck, and upper breast consistent with a cadaver.  

 requested the cadaver be removed at rehang

by a plant employee. 

was notified at approximately 0104 hours and

observed the cadaver removed from the evisceration line.   A

second verification prior to the first scalder of an approximate

500 bird subgroup had no bird(s) entering the scalder at

approximately 0106 hours.  A visual check of the kill room at

approximately 0110 hours evidenced the birds were being

stunned properly and the automatic kill machine was operating

properly.  This was determined to be an isolated incident and

not a systemic loss of process control.   Bird(s) entering the

scalder while still breathing is not consistent with GCPIP and

results in adulterated product.  Establishments are responsible

for birds entering the official premises and must employ GCPIP

to prevent unnecessary suffering, injury and death. A meeting

was held in the office of at approximately 0130 hours

on June 28, 2017.  

, and were present.  

discussed the incident and further findings with .  

 stated that a check of the stunner and kill machine by 

 was

within normal operating parameters. was advised a

GCPIP Memorandum of Information (MOI) would be issued to

the plant.   stated any forthcoming response would be

made by . As per

Federal Register Notice Docket 04-037N, dated September 28,

2005, “Treatment of Live Poultry Prior to Slaughter”, the Food

Safety Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to abide by

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

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

(b) (6)

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

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

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 235

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

04C05 KMH25070

94327G

2017-09-27 On September 25, 2017 at approximately 1250 hours, I

observed less than Good Commercial Practices while performing

an Ante-Mortem Inspection and Good Commercial Practices

check at P-519.  I observed 3 live birds entering the scald tank.

The birds were not cut and were breathing with the eyes open

and blinking. I was being shadowed by who

also observed the live birds entering the scald tank. 

 was in the area during my

inspection and took immediate action by adding a second back

up killer and called a maintenance employee to adjust the kill

machine. was informed while in the picking

room at approximately 1300 that a GCP MOI documentation of

our meeting and discussion of the observed deficiency would be

forthcoming. In addition, these findings were observed on

Sunday night, September 24, 2017 on 3rd shift.  At

approximately 2300 hours, notified that

she had identified 6 cadavers, with 5 of them in rapid succession

at station #4.  A total of 9 cadavers had been identified by IPP

by break time of 2311.  and proceeded to

the kill room and scalders and found no evidence of live birds

entering the scalder or concurrent loss of process control.  

 was notified of the issue and he

immediately assigned a back-up neck cutter to the line.  Several

checks throughout the remainder of the shift at the scalder

revealed no live birds entering the scalder.  However, by the end

of the shift, a total of 32 cadavers, some of which were DOAs,

had been identified by IPP.  was informed at a

meeting in the USDA office at approximately 0525with 

 and that a GCP MOI documentation of our

meeting and discussion of the observed deficiencies would be

forthcoming. FSIS Docket No. 04-037N, Treatment of Live

Poultry before Slaughter, states that under the Poultry Products

Inspection Act (PPIA) and Agency regulations, live poultry must

be handled in a manner that is consistent with good commercial

practices. In order to ensure that poultry is handled and

slaughtered in a manner that is consistent with good

commercial practices, poultry should be treated in such a

manner as to minimize excitement, discomfort, and accidental

injury throughout processing. A copy of this Memorandum of

Interview will be forwarded to appropriate personnel in the

Jackson District Office. Thank you, 

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

(b) (6)

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

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 236

EstNbr EstName Task_Code MOI# Date Description

P522 Sanderson

Farms, Inc.

(Processing Div)

04C05 IKB291902

2802G

2017-02-02 Today, February 2nd, 2017, at approximately 1908 hours, while

conducting a Good Commercial Practices task, the following was

observed in the live hang area. There was an accumulation of

approximately 35 carcasses at the end of the live hang belt and

on the adjacent metal table. The carcasses were piled 3 birds

high. There were approximately 5 carcasses on the floor, lying in

a puddle, and there was one carcass hanging by one leg off the

side of the belt. As I observed, two more carcasses fell to the

floor. I observed the carcasses on the table carefully and

observed 2 birds within the pile that were breathing, as

evidenced by rhythmic movements of the chest. I alerted an

area employee and asked him to get a supervisor. I continued to

observe as the employee began sorting, disarticulating the neck,

and decapitating the carcasses. 

 appeared and began participating in the process. 

After the carcasses had been disposed of, I verbally notified 

), of my findings which would be

documented in a Good Commercial Practices MOI. I expressed

concerns about carcasses piling up in live hang during the

weekly meetings on January 20, 2017 and February 2, 2017. I

also informally discussed this issue with and 

 last night, February 1st, 2017. Poor process

control in live hang may result in the pile up of Dead On Arrival

(DOA) carcasses. Weak or injured birds may become trapped

under DOAs and may be smothered, resulting in suffering and

death by means other than slaughter. The establishment is

encouraged 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.   Respectfully, 

(b) (6)

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

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(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 237

EstNbr EstName Task_Code MOI# Date Description

P522 Sanderson

Farms, Inc.

(Processing Div)

04C05 IKB510804

2706G

2017-04-06 P-522 On April 6, 2017 at

approximately 0515 while performing a GCP task in the Picking

Room, I observed less than Good Commercial Practices.  I

observed a live bird lying on its back in a drain pan located

under the picking line which runs prior to the kill machine.  The

bird could not right itself.  Water from other birds hung on the

picking line which had just exited the stunner cabinet and

passing over the top of this bird was observed pouring down

onto the front of this bird’s head and body.  The bird was lying

in water collected by the drain pan.       

 with me at the time of this observation

removed the bird from the drain pan.  The bird was breathing

with open eyes and appeared lethargic and/or fatigued as there

was very little movement from the bird when picked up.  The

Picking Room Supervisor placed the bird back on the picking

line at a point in the process that caused the bird to re-enter the

slaughter process for a second time.     I discussed my

observation with Kevin Montgomery,  Plant Manager, and 

.  I reminded management

this was now the third occurrence of finding birds displaced

from the picking line. Two previous findings were discussed in

weekly meetings with plant management of finding birds

located at the stunner exit (one live and one dead bird). 

Discussions with plant management were documented in the

weekly meeting minutes on 3-24-17 and 3-31-17.  Additionally,

I had a separate discussion with of my concern of

allowing the bird to go through the entire slaughter process a

second time.      As per Federal Register Notice Docket No.

04-037N dated September 28, 2005, “Treatment of Live Poultry

before Slaughter,” the Food Safety Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines. Respectively, Cc Mr.

Don Coley, DDM  

(b) (6)

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

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 238

EstNbr EstName Task_Code MOI# Date Description

P522 Sanderson

Farms, Inc.

(Processing Div)

04C05 IKB180704

5511G

2017-04-11 : On April 10, 2017 at

approximately 0556 hours while performing a GCP task in the

Live Hang Room, I observed less than Good Commercial

Practices.  When I walked into the room I noted a pile up of

birds (these birds were not decapitated) on the slatted

decapitation table that sits at the end of the live hang belt.  No

one was addressing the pile up of birds when I entered the

room.  I observed one breathing bird lying on this table located

at a point where the moving live hang belt was repeatedly

striking the bird.  ,

walked up to the table.  He began removing the birds from the

table and placing the birds on the floor.  Twenty one (21) birds

were removed from the table.  As the birds were removed, I

observed one breathing bird located at the bottom of the pile,

lying on its back.  The bird’s head had falling down between the

slatted bars of the decapitation table.  I showed these birds to

.  I notified 

, Mr. Kevin

Montgomery, First Shift Plant Manger, and 

of the forthcoming MOI.  This issue has been

discussed with plant management on multiple occasions.  1. 

As documented in the weekly meeting dated 1-27-17, I

discussed with ,

and on 1-23-17 at

approximately 0535 hours, the issue of allowing birds to pile up

on the slatted decapitation table next to the moving live hang

belt.  2.  As documented in the weekly meeting dated 2-17-17,

at approximately 0550 hours, I discussed with Mr. Gary

Delancey, First Shift Plant Manager the observation at 0541

hours by of a pile of birds at the end of the

live hang table next to the metal grate.   observed

one bird lying on its back trying to right itself as birds were

piling on top of this bird.  She immediately notified 

, and lifted the

bird upright.  3.  As documented in the weekly meeting dated

2-24-17, on 2-23-17 at approximately 0539 hours, I had a

meeting with

 and Mr. Gary Delancey, First Shift

Plant Manger, concerning birds piling up at the end of the live

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 239

EstNbr EstName Task_Code MOI# Date Description

hang belt.    Two live birds were observed on their backs unable

to right themselves as other birds were beginning to pile up on

these birds at the end of the moving live hang belt.      4.  On

2-28-17, at 0707 hours I discussed with 

 and Mr. Kevin Montgomery, First Shift

Plant Manger, birds piled up on the table at the end of the

rehang belt with one bird lying on its back.  Mr. Montgomery

stated a meeting on animal welfare would be conducted at the

end of the day and promised this issue would be corrected.     

As per Federal Register Notice Docket No. 04-037N dated

September 28, 2005, “Treatment of Live Poultry before

Slaughter,” the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines. Respectively, Cc Mr.

Don Coley, DDM 

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 240

EstNbr EstName Task_Code MOI# Date Description

P522 Sanderson

Farms, Inc.

(Processing Div)

04C05 IKB581805

5025G

2017-05-25 The following less than good commercial practices were

observed yesterday at P-522, Sanderson Farms, Collins,

Mississippi: I was informed by my CSIs that the picking line was

down, so I proceeded to the live hang area to observe the

condition of the live birds. Upon entering the live hang area at

approximately 1412 hours, I observed that the outside line was

not moving and there were no birds in the shackles on that line

in live hang. There were approximately 15 dead birds on the

metal table at the end of the line. Within the pile of dead birds I

observed a live bird: The head of the bird was buried beneath

dead birds, but the vent area of the bird was clearly moving in

and out in a rhythmic manner as the bird breathed. 

, was notified of this finding and

informed that live birds buried beneath dead birds may

suffocate, dying from means other than slaughter. This issue

was discussed at second-shift weekly meetings with the

establishment on 1/20/17, 2/2/17, 2/10/17, 4/7/17, 4/21/17,

and 5/4/17. Additionally, Good Commercial Practice MOI's have

been issued for this same problem on 4/11/17 (First Shift) and

2/2/17 (Second Shift). I proceeded to the platform adjacent to

the dumper, where I observed that most of the shackles were

empty. However, there were still live birds hanging in the

shackles in three locations (at the time of my observation the

birds had been hanging on the line for approximately 10

minutes): There were two live birds (one of which was hanging

by one leg only) suspended in the shackles beneath the

push-down bar. I asked area employees why these birds had not

been removed from the line and they stated that the birds could

not be removed from the line because the metal bar was in the

way. There were 2 live birds suspended in the shackles near

where the line makes the first a 90-degree turn as it exits live

hang and proceeds towards the stunner. I asked the employees

why these birds had not been removed since there was nothing

obvious obstructing access to these birds. Area employees

stated that the birds were stuck and could not be removed from

the shackles. There were 10-15 live birds suspended in the

shackles above the catwalk, located just prior to the entrance to

the stunner. I immediately notified Mr. Barry Sparks, Plant

Manager, and ,

of my findings. I proceeded to the front office and informed

, of my findings, and asked if the

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 241

EstNbr EstName Task_Code MOI# Date Description

establishment’s animal welfare program includes a protocol for

dealing with live birds in the shackles in the event of a line

stoppage. stated that live birds were to be

removed from the line in the event of a line stoppage. This

issue was previously discussed at the weekly meeting 3/2/17, at

which time stated that birds are to be removed

from the line in the event of a breakdown lasting more than 3-4

minutes. I subsequently reviewed the establishment’s written

animal welfare protocol titled, “Animal Welfare Plan for

Disruption of Processing” and confirmed that removal of live

birds from the line prior to the stunner is included in the

protocol, although a time frame is not specified. The treatment

of live birds before slaughter is an important animal welfare

concern. Live birds buried beneath dead birds may suffer and/or

suffocate, dying by means other than slaughter. Live birds left

suspended upside down in the shackles for a prolonged period

of time in the event of a line stoppage may suffer and/or die;

this is especially true of birds improperly hung in the shackles or

birds that are already in a compromised state due to disease or

injury. Establishment management is encouraged to review

Federal Register Notice Docket No. 04-037N (dated September

28, 2005) for FSIS recommendations concerning treatment of

live poultry before slaughter. Establishments are strongly

encouraged to abide by Good Commercial Practices.   The

aforementioned observations were discussed today with 

 Respectfully, CC:

 

Mr. Don Coley, Deputy District Manager 

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 242

EstNbr EstName Task_Code MOI# Date Description

P522 Sanderson

Farms, Inc.

(Processing Div)

04C05 IKB341405

1526G

2017-05-26 Yesterday, May 25th, 2017, at approximately 2143 hours, I

observed the following at P-522, Sanderson Farms, in Collins,

Mississippi: The backup cutter on the outside line (the line

closest to the exit door) appeared to miss a live bird that had

itself been missed by the neck cutting machine. I exited the

area and went to the scalder entrance. I observed one live bird

enter the scalder on the outside line. Prior to entering the

scalder the bird was craning it’s neck, flapping it’s wings, and

appeared to be bright and alert. There was no evidence of blood

or a cut on the bird’s neck. I proceeded to the hot rehang area

of the evisceration department and observed a cadaver on Line

One at approximately 2154 hours. The bird was removed from

the line by an area employee and I inspected the carcass: It was

brick red and the head was swollen and fully attached. There

was no evidence of a cut on the neck. I immediately informed

Barry Sparks, Plant Manager, of my findings. Birds that enter

the scalder alive die by drowning rather than by slaughter.

Establishment management is encouraged to review Federal

Register Notice Docket No. 04-037N (dated September 28,

2005) for FSIS recommendations concerning treatment of live

poultry before slaughter. Establishments are strongly

encouraged to abide by Good Commercial Practices. Today,

May 26th, I discussed my findings with 

 Respectfully, CC: 

 Mr. Don

Coley, Deputy District Manager 

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 243

EstNbr EstName Task_Code MOI# Date Description

P522 Sanderson

Farms, Inc.

(Processing Div)

04C05 IKB521906

0430G

2017-06-30 The following less than good commercial practices were

observed today at P-522, Sanderson Farms, Collins, Mississippi: 

Upon entering the live hang area at approximately 1925 hours, I

observed that there were 15 carcasses on the metal table at the

end of the line. Within the pile of dead birds I observed one live

bird: The head of the bird was buried beneath dead birds, but

the side/breast area of the bird was clearly moving in and out in

a rhythmic manner as the bird breathed. 

 was notified of this finding and informed that

live birds buried beneath dead birds may suffocate, dying from

means other than slaughter. extracted the live bird

from the pile and hung it on the line. The bird was clearly alive

as its eyes were open and it had normal muscle tone and head

movement. This issue was discussed at second-shift weekly

meetings with the establishment on 1/20/17, 2/2/17, 2/10/17,

4/7/17, 4/21/17, and 5/4/17. Additionally, Good Commercial

Practice MOI's have been issued for this same problem on

5/25/17 (Second Shift), 4/11/17 (First Shift) and 2/2/17 (Second

Shift). The treatment of live birds before slaughter is an

important animal welfare concern. Live birds buried beneath

dead birds may suffer and/or suffocate, dying by means other

than slaughter. Establishment management is encouraged to

review Federal Register Notice Docket No. 04-037N (dated

September 28, 2005) for FSIS recommendations concerning

treatment of live poultry before slaughter. Establishments are

strongly encouraged to abide by Good Commercial Practices. 

The aforementioned observations were discussed today with

Mr. Barry Sparks, Plant Manager. Respectfully, 

 CC:      

 Mr. Don Coley, DDM 

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 246

EstNbr EstName Task_Code MOI# Date Description

P529 Pilgrim's Pride

Corporation

04C05 ODE17100

74213G

2017-07-13 At approximately 6:35am on July 13, 2017, I was alerted by an

on-line USDA food inspector that they had condemned four

cadavers in approximately the last 20 minutes. I looked in the

condemn barrels and saw many bright red birds with no

evidence of a cut on their neck. I reviewed the other lot tally

sheets at each inspection station and found that there had been

13 cadavers condemned during the day shift. Day shift starts

inspection at 5:45am. I then went out to the live hang area to

investigate further. I noted that the stunning and cutting

machinery appeared to be working properly and the back-up

cutter did not appear to be overworked. At approximately

6:50am I met with the establishment 

 and . I

informed them of my observations, asked them what happened

and how they were going to correct the situation. 

 stated he was putting salt in the line two stunner and he

noticed his back-up cutter was working more than usual. In

response he raised both the stunner and the automatic neck

cutter. During this time noticed that the water was

off supplying the line one stunner. This caused the water level in

the stunner to decrease to the point where it was no longer

effective. Once the water was turned back on, the stunner

operated correctly. I asked what caused the water to be turned

off supplying the stunner and what they would do to ensure the

water is on during production in the future. 

answered that he was not sure how the water got turned off but

he suspected night shift could have turned it off or the valve was

bumped. He informed me in the future he will check the valves

during shift change to ensure proper operation. Finally, I asked if

the back-up cutter alerted them to the problem or stopped the

line in response to the problem. said that the

back-up cutter did not notify them or stop the line. He said he

would have a conversation with them to remind them to stop

the line when they cannot keep up with the amount of birds

they have to cut.

(b) (6)

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 247

EstNbr EstName Task_Code MOI# Date Description

P533 Hain Pure

Protein

Corporation -

FreeBird East

04C05 AKB500402

3514G

2017-02-14 On February 13, 2017 at approximately 10am a trailer of

poultry on the way to slaughter at establishment Hain Pure

Protein 533P overturned.  The trailer arrived to the

establishment at approximately 2pm.  At approximately 2:15pm

I went to live receiving to observe the unloading and sorting of

poultry.  In the live hang room the lights were on to assist with

the sorting.  There was a large pile of approximately 50 dead

birds on the floor next to the belt.  As the hangers were sorting

the birds I noted one of the birds that was put in the dead pile

was alive.  I alerted the hanger who picked the bird back up and

hung it on the kill line. I saw another live bird in the dead pile.  I

notified , of the

situation.  I stopped the sorting until the dead pile was cleaned

up and all birds were verified to be dead.  In total there were 5

live birds placed in the dead pile. Once the pile was cleared,

sorting and hanging resumed.  performed the rest

of the sorting and controlled the belt speed.  I observed the rest

of the sorting and hanging.  No other live birds were placed in

the dead pile on the floor. I discussed with that it is

unacceptable to place live birds in the dead pile.  Live poultry

must be handled in a manner that is consistent with good

commercial practices (GCPs), and that they not die from causes

other than slaughter stated in response:          In

regards to the incident on Monday in live receiving with having

to deal with the accident and having to process those birds.

Should something unusual as this occur again we will slow the

process down as much as necessary to keep ensure no live birds

are going to the floor to be mixed with the dead. I will make it

clear to the lead in live receiving that this must happen to abide

by our GMP’s. During a GCP Verification visit on 12/13/2016,

 observed a live bird on the floor with its head

under the wing of a dead bird and discussed her

concerns about the situation with establishment management

at the time.  also spoke with 

who stated the establishment was hoping on

installing a table for dead/dying birds by the end of January

2017.  At this time there is no table.

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 248

EstNbr EstName Task_Code MOI# Date Description

P544 Jennie-O Turkey

Store Sales

04C05 KXJ310403

5023G

2017-03-23 At approximately 1:35 AM I was down stairs by where the birds

enter the scalder monitoring the plant's Commercial

Practices in the stun and kill department.  I observed a bird

going into the scalder alive.  (I knew that it was alive because I

could see it holding its head up.)  I then went over to the point

where the birds exit the last picker, just prior to where they

enter the hock cutter.  During the time that I was there I did not

see a cadaver come out of the pickers.  However, I then moved

to the live hang area and noticed two birds in the ante

mortem condemn barrel that had their feathers removed

and were cadavers.  I then went upstairs to look for 

 so that I might show him the cadavers in

the condemned barrel.  While upstairs I heard an inspector ring

the bell to summon me and found that 

had retained a bird for my disposition.  It was a cadaver, and I

condemned it as such.  I encountered both and 

, showed them the cadaver behind

, and asked them to accompany me back

downstairs.  While downstairs, I showed them the cadavers in

the ante mortem condemned barrel. and

both began an investigation as to how two cadavers ended up in

the ante mortem condemned barrel.  

) explained that he had seen these two cadavers

and brought them back to the blood tunnel to alert his back up

kill person that there were birds going through scalder alive.  He

explained further that once he had his back up kill person's

attention, he found that the handiest condemned barrel

to dispose of the two cadavers in was this ante mortem

condemned barrel. The lot or flock being slaughtered at the

time had been started about one hour prior to the 12:30 AM

lunch break.  Counting the two carcasses that were found in the

ante mortem condemned barrel and six carcasses recorded as

cadavers on the inspectors' lot tally sheets, by 2:00 AM there

were a total of eight cadavers produced by the plant.  This is

considerably more cadavers than normal, and I said to 

 and that it looks like there is something going

on that is resulting in cadavers.  They said to me that they were

two people short in live hang and, therefore, they only had one

backup kill person in the blood tunnel.  said that,

although one backup kill person should be able to handle

it, they would prefer to have two backup kill persons.  They said

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 249

EstNbr EstName Task_Code MOI# Date Description

they instructed  to adjust the kill blade of the auto kill

machine, in hopes that there would be fewer missed cuts that

the lone backup killer would have to act on.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 250

EstNbr EstName Task_Code MOI# Date Description

P544 Jennie-O Turkey

Store Sales

04C05 KXJ310004

4906G

2017-04-06 P544-Jennie-O Turkey Store, Melrose, MN 4th April-03:00am:

), 

 5th April-22:45pm:

), 

 Poultry Mistreatment

Memorandum of Interview (MOI): The following is a

documentation of observations and discussions with

00544P/Jennie-O Turkey Store, Melrose, MN establishment

personnel regarding the observations of two instances were live

birds were run over by trailers in the live haul area during two

nights of production, the 3rd and 4th of April 2017. During the

1st shift on the 3rd of April 2017 at approximately 03:00am

while performing a Good Commercial Practice (GCP) verification

in the live haul rehang area, a trailer had just exited the live haul

area when the live haul foreman was observed to pick-up the

crushed carcass of a single turkey.  The carcass was placed in a

condemned barrel and denatured.  I spoke with the live haul

foreman, as the area supervisor was not available, that live birds

need to be handled consistent with good commercial practices. 

During the 1st shift on the 4th of April 2017 at approximately

02:45am while performing a GCP verification in the live haul

rehang area, I observed truck pulling trailer 1301M exit the

rehang area.  Approximately 2 feet from the outside overhead

door, there was a single turkey with head lifted, wings flapping,

vocalizing, and the back end was crushed.  The live haul foreman

performed a cervical dislocation of the affected bird and placed

the carcass in the condemned barrel and denatured the

contents.  I located and 

 outside of the evis

department at 03:00 and spoke with them regarding the

observations tonight and the previous night as not being

consistent with good commercial practices, as the birds had

died by means other than slaughter.  and left

to speak with the live haul foreman and crew.  On the 5th of

April 2017, was observed to be speaking to the live

haul foreman and monitoring the live haul area at 1st shift

start-up 20:00.  Discussion that day during the 22:45pm weekly

meeting (MOI KXJ2800040806I), reported

preventative measures including advising the live haul crew

hangers to be notifying the area leads if birds fall.  The leads are

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 251

EstNbr EstName Task_Code MOI# Date Description

to be monitoring areas, watching for fallen birds, and assisting

the foreman when fallen birds are identified.  Birds are to be

retrieved at the time of identification.  The live haul foreman is

to be illuminating the areas with flashlight and assisting the

leads with retrieving birds before the trucks move. I notified 

and that this MOI would be forwarded to the

District Office and to the 

 and should the need for

follow-up be recommended. Respectfully, 

 P544-Jennie-O Turkey

Store

(b) (6)

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 252

EstNbr EstName Task_Code MOI# Date Description

P544 Jennie-O Turkey

Store Sales

04C05 KXJ590605

2502G

2017-05-02 United States Department of Agriculture Food Safety and

Inspection Service 123 S. 5th. Av. E. 

Melrose, MN. 56352 320-256-3311 

                                                                                                      

           Date: 5/1/2017 TO: and 

 FROM:  

 SUBJECT:  MOI-Good Commercial Practice     

At 0745 hours I was on the north side of the Hang and Kill bay

observing Good Commercial Practices. There were three trailers

staged to enter Hang and Kill. The trailer numbers were 9821,

1402 and 0706. All three trailers belonged to flock, Buysee

Plainview, which  is 125 miles from the Jennie-O-Turkey Store,

Melrose facility. The outside temperature was 32 degrees and a

heavy mist, at the time of my Good Commercial Practices

observations. I observed the back of the three staged trailers

and noted that the back trailer axels and frame work was

packed with snow. The back coops were wet. The turkeys in the

back cages were wet, listless and shivering . The bottom 2 cages

that I could observe well had 1-3 DOAs per cage. There was no

panel protection on the back of the trailers. I observed the sides

of the three trailers which had staggered side panels in place.

The turkeys in the side cages were dry and the cages were drier

then the cages in the back of the trailer. I did not observe any

turkeys shivering in the cages on the trailer’s side. The back of

the trailers did not have any panels. It appears that during the

125 mile haul from the farm to the Melrose facility that the

snow, mist swirled up behind the trailer and made the back

cages and turkeys wet and some of the turkeys were

hypothermic.      I demonstrated the three 

trailers to and 

. The two gentlemen said a

further investigation into the wet conditions of the back cages

of the trailers would be performed.      After I entered the

establishment I reviewed the DOA numbers for the Buysee

Plainview flock. The numbers were: Trailer                  

DOAs                                             Trailer                 DOAs 

1304                        19                                                  

1101                    15 0706                 

      38                                                  1402                     47 1406  

                     20                                                   0705                      

5 9821                        13 The average number of DOAs per

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 253

EstNbr EstName Task_Code MOI# Date Description

load for was 22.4 carcasses.        The next lot

of turkeys processed was from which is 27

miles for the Jennie-O-Turkey, Melrose processing facility. The

average number of DOAs per load for was 2.75.

 were similar size birds to .

                Sincerely, .

P544 Jennie-O Turkey

Store Sales

04C05 KXJ450405

2405G

2017-05-05 At approximately 3:10 I was down in the live hang area

observing Good Commercial Practices.  I saw the plant trying to

retrieve a live bird off the hoist before trying to pull an

empty trailer out of the live hang bay.  It took some time to get

the bird out.  When they got the bird out, the live hang lead

person checked for birds on the hoist from the front end of the

truck once more with the flashlight on the driver's side and once

more with the flashlight on the passenger's side before pulling

the truck out.  When the truck was pulled out, however, there

was a bird lying in the wheel tracks on the passenger's side at

the rear end of the hoist.  The bird was bloody and

was convulsing, revealing that it had just been run over. I met

with after the incident, and we initiated discussion

about preventive measures, such as: Ways to prevent birds from

getting down on the hoist where they can get run over, such as

by decreasing the space between the live hang mezzanines and

the live haul trailers. Ways to increase

personnel awareness about birds that do end up down on the

hoist so they can be retrieved without being run over, such as by

checking with the flashlights from both ends of the truck.

P544 Jennie-O Turkey

Store Sales

04C05 KXJ280405

2831G

2017-05-31 While down in the live hang area doing ante mortem on a new

lot of birds, I observed a DOA carcass in the Condemned barrel

exhibiting signs of abuse, such as the skin over the breast of the

bird being torn open, fully exposing the breast meat.  I discussed

with ) that birds should not be

coming off the trucks looking abused like that, and that that

message should be relayed to the live hang and loading crew(s). 

Later I discussed the same with 

.  He said he had already heard about my

conversation with and that they were in agreement that

they don't want their birds being abused either. As of July 6, I

have not seen any more carcasses exhibiting such injuries.

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

(b) (6)

(b) (6) (b) (6) (b) (4) (b) (4)(b) (4) (b) (4) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 254

EstNbr EstName Task_Code MOI# Date Description

P544 Jennie-O Turkey

Store Sales

04C05 KXJ280307

3620G

2017-07-20 At about 22:45 I began performing a Good Commercial

Practices verification task, standing right by the entrance to the

scalder, watching the birds go by on the last three feet of the

kill line before their descent into the scalder.  After nearly two

full minutes of observation, I saw a live bird go into the scalder. 

It was holding its head up and its eyes were wide open just

before it rounded the bend and went into the scalder.  I

immediately came up stairs and met with 

  His immediate response was that he was

going to remove the chairs in the blood tunnel that the back up

neck cutters have been sitting on, and that he was going to have

one of the manual back up neck cutters go back out to live hang

and bring a more experienced back up neck cutter back into the

blood tunnel.  A subsequent review of the lot tally sheets on

that lot of birds revealed that there had been one cadaver

identified in the lot. During a later meeting with  , at

about 01:15, we discussed that the plant may need to get the

kill line running at a more steady speed.  In other words, instead

of the plant letting the transfer table get empty and

running the kill line real fast to catch up with product flow, and

then letting the transfer table get too full and running the kill

line real slow to let the accumulated product clear out, the plant

needs to observe product flow more closely and avoid the need

for large swings in kill line speed.  By running the kill line at a

more steady, appropriate speed they would avoid running it at

excessively high speeds.  This would result in the live hangers

being more able to hang the birds properly so that they would

go through the kill machine in a better position to have their

necks cut properly.  Likewise, the manual back up killers would

have less work load to keep up with at a more reasonable

speed to keep up with it at.  Hence, they would be more able to

make effective neck cuts when needed.    added that he

will be bringing the lead floor person from day shift live hang

onto night shift to act as the kill supervisor on the night shift

until the incumbent kill supervisor reports back for duty.  He

was confident that that person's skill would even out the kill line

speed a lot.

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 255

EstNbr EstName Task_Code MOI# Date Description

P544 Jennie-O Turkey

Store Sales

04C05 KXJ050409

0805G

2017-09-05 Shortly after 3:30 AM I began Good Commercial Practices

verification activities in live hang.  I was standing off the

passenger's side and just in front of the truck that was nearly

empty of its turkeys.  Recognizing that the truck was almost

empty and ready to be pulled out of the live hang bay to make

room for another full load of turkeys, I waited and watched.  No

one came to the passenger side of the truck to check for loose

birds on the floor on my side of the truck.  At about 3:35 the

truck pulled out of the live hang bay.  Once the truck had pulled

out, the bay remained void of any more trucks, because the

trailing truck driver sat waiting for live hang floor personnel to

walk out into the bay and pick up a bird that was laying in

the path of the left wheels of trucks.  I was able to see

clearly that the bird had just been run over by the truck that had

just left the live hang bay, because it was quivering, and its

abdomen had ruptured and was laying open.  I saw hurry

out into the bay, pick up the bird, and bring it to and place it

into the "USDA Condemned" barrel that was right next to me. 

He immediately removed the barrel to the offal room where it

would be denatured and elevated onto the offal trailer. I began

a search for and found him upstairs.  When I began

telling him what I had observed, he told me that had

just called him and told him that they had run over a bird.  I told

him that I had been on that very side of the truck, watching for

a few minutes before the truck pulled out, and that I had not

seen anyone checking for birds under that side of the truck

before the truck pulled out.  During our ensuing discussion we

talked about the panels that are stored underneath the trailers

and how they obstruct the vision of those who check for birds.  I

questioned the need for even having those panels with the

trucks this time of year, because their only purpose is to be put

on the sides of the trucks to keep birds warm during the cold

months of the year.  Will's response was that they don't have

anywhere else to store the panels for the time being (due to the

construction project where they would normally be stored this

time of year), and that in just a few more months they will be

absolutely necessary to keep the birds warm any way.  Will did

agree that, panels or no panels under the trailers, plant

personnel must check thoroughly enough for birds under the

trailers that they don't run over any birds when they pull the

trucks out of the live hang bay.

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 256

EstNbr EstName Task_Code MOI# Date Description

P544 Jennie-O Turkey

Store Sales

04C05 KXJ590509

3328G

2017-09-28 At 05:03am on the 27th of September 2017 while performing a

Good Commercial Practice (GCP) verification at the start-up of

production, I observed the following in the lower evisceration

department. After the scalders and pickers, I observed two

carcasses-five carcasses apart, coming through the turn point to

the hock cutter to rehang table.  These two carcasses were

uncut, dark red to purple in color from head through the body

and legs.  These two carcasses where from a “heavy hen” lot,

toms, well-muscled with no visible skin damage (processing or

scabs) and did not have any external evidence of disease.  These

carcasses demonstrated evidence of dying by means other than

slaughter.  I was observing the picking line with 

 at the time of the event. I notified the live

hang lead and observed the mechanical

cutter and back-up establishment cutters, who manually cut

four carcasses during the two-minute monitoring. At 05:10am,

I notified plant manager Mr. Jason Reuss regarding the

observations of the uncut cadavers. At 05:15am-05:30am, I

was in the evisceration department monitoring production and

arrival of the aforementioned carcasses.  The two cadavers did

not arrive at the USDA inspection stands during this time. 

Further discussion of the incident was held during the weekly

meeting (27th September 2017: MOI  KXJ5511091027G). 

Respectfully submitted by 

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 257

EstNbr EstName Task_Code MOI# Date Description

P550 Simmons

Prepared Foods,

Inc.

04C05 XWN29120

73617G

2017-07-17 Today, July 17, 2017 at approximately 1050 hours, while

performing a Good Commercial Practices check in the cooling

shed area, I observed that two trailers full of chickens were not

parked in the cooling shed but instead were sitting outside in

the sun. I observed that the birds were panting and appeared to

be distressed by the heat. The temperature was approximately

89 degrees F, with a heat index making it feel like 94 degrees. I

notified of the situation and informed him that

if there were no bays available for the chickens to be pulled into

the cooling shed, the trucks needed to be driven around to keep

the air moving through the cages until space could be found to

pull them in. On Tuesday, July 18 2017 I also discussed this

situation with and emphasized that in the

extreme summer heat we are having at this time, leaving

chickens sitting in the sun is not an acceptable Good

Commercial Practice. A copy of this Memorandum of Interview

will be provided to establishment management and a copy

placed in the official USDA file. 

(b) (6)

(b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 258

EstNbr EstName Task_Code MOI# Date Description

P559 Tyson Foods,

Inc.

04C05 UWC42210

11624G

2017-01-24 On Tuesday, January 24, 2017 at approximately 1500 hour, I

observed less than Good Commercial Practices. While

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed several loose birds on the roadway in

the truck unloading area, between the trailer currently being

unloaded and where cages were being unloaded onto the dump

belts.  One of the birds was run over by the forklift driver and

had its leg pinned under the rear wheel of the forklift.  The

driver stopped to get the loose birds with the one remaining

pinned under the tire.  The free birds were caught and placed

back in the coop that was currently on the forklift.  The forklift

was reversed to allow the pinned bird to become free at which

time the driver then got out to catch the bird which was

vigorously flapping and trying to get away.  This bird was also

placed back in the cage on the fork lift.  Just prior to this event a

bird was observed stuck in one of the cages by its toe that had

just been emptied.  The dump cage operators proceeded to

remove the bird from the cage and placed it on top of a full cage

further down the belt.  The bird remained on top of this cage

loose for several minutes.  It also remained on top of the cage as

the cage was moved down the belt to be dumped, creating a

hazard in which the bird could become crushed.  The supervisor

was immediately informed of these issues and concerns. 

Establishment management was notified as well of the incident

and informed of the resulting MOI.   As per Federal Register

Notice Docket No. 04-037N dated September 28, 2005,

“Treatment of Live Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good Commercial Practices

(GCPs) as described by industry guidelines. My observations

are consistent with less than good commercial practices. A

copy of this Memorandum of Interview will be forwarded to

appropriate personnel in the District Office.  Respectfully

submitted on January 24, 2017    Cc:

         DDM                 DVMS                 FLS

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 259

EstNbr EstName Task_Code MOI# Date Description

P559 Tyson Foods,

Inc.

04C05 UWC30200

64607G

2017-06-07 At approximately 18:40 hours while giving breaks to Food

Inspectors on Evisceration Line 1, had a bird

presented to him that had a rubber band around its body. The

band was located just behind the wings and encircled the entire

body. It was deeply embedded in the back and breast muscles.

Its long term presence was demonstrated by a heavy band of

fibrous scar tissue proximal and distal to the area where the

band had grown into the tissues. There was also a large area of

inflammatory tissue in the breast muscles proximal to the

banded area. This bird was from the same flock of birds as one

found on day shift with a rubber band similarly located around

its body. Plant is able to identify flock/grower from which this

bird originated.  The bird was turned over to Plant Manager Tim

Peters for his correlation with grow-out personnel. He stated

that this grower had recently replaced nipple waterers in the

house and the rubber bands probably dropped during their

installation.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 260

EstNbr EstName Task_Code MOI# Date Description

P5787 Pilgrim's Pride

Corporation

04C05 DEB051204

0805G

2017-04-05 On April 4, 2017 at approximately 1223 while performing a

Good Commercial Practices check in the live hang area, I

observed a bird on line that had been hung in the shackle

by both legs and its head. The plant employee immediately

stopped the line and the bird was removed.  The bird’s neck was

bleeding and it was dead.  This bird had died by means other

than slaughter.  During this Good Commercial Practices check I

also observed 2 birds had been hung by both legs in one shackle

and another bird hung by one leg.    When I located

, I informed him about the bird

I had observed that was hung by its head/neck as well as by

both feet resulting in the bird dying by means other than

slaughter.  Hanging any chicken by its head/neck is not

appropriate and USDA takes the humane handling of the

chickens very seriously.         told me

they were training about 4 new hires in the live hang area and

would go back there to see that they were moved to a part of

the line where more supervision would be given to their proper

hanging of the birds.  He assured me that he would make sure

they all understood that hanging any of the birds by the head

will not be tolerated.   This is a reminder that any mistreatment

of birds during processing is a major non-conformance.  A copy

of this MOI will be forwarded to and 

 in the Dallas

District Office and .   

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 261

EstNbr EstName Task_Code MOI# Date Description

P5787 Pilgrim's Pride

Corporation

04C05 DEB071406

4228G

2017-06-28 On Wednesday June 28, 2017 at approximately 12:34 PM I was

in the live receiving area performing a Good Commercial

Practices task.  I noted one of the cages had been set aside and

several of the birds had blood on them.  I asked the 

of the area, , why the birds had fresh blood on

them and pointed out birds to be removed so that I could

determine which one was injured.  The first bird had fresh blood

on it but I ascertained it did not have any wounds.  The second

bird with blood on it had a severely bruised wing but again no

site for the bleeding was found.  However, the third bird they

removed was actively bleeding from a large gaping wound on its

left breast.  The skin had been torn away and was a hanging flap

of skin.  The wound was approximately 4 x 4 inches in

width/length. There were several plant employees including 

and present but no one was

taking any steps to alleviate the pain and suffering of this

injured bird.  I then told them the injured bird needed to be

immediately euthanized to alleviate any further pain, suffering

and distress. The bird was still alive and not moribund.  The

plant then euthanized the bird.  I later spoke with

 and about the

importance of taking action when they observe birds with blood

on them.  Also, that they needed to be more vigilant in the

future and take immediate action so that injured birds are not

left to suffer in pain and distress.       USDA expects all birds to

be treated in a manner that causes the least amount of distress,

discomfort and excitement.  It is expected that all plant

employees will use all due diligence to ensure birds are treated

in the least stressful manner possible.  Therefore, being

proactive in identifying possible instances where harm and or

distress/discomfort may be inflicted upon the birds should be

followed.    A copy of this MOI will be entered into PHIS,

forwarded to the Front Line Supervisor and the Dallas District

Veterinary Medical Specialist. P5787 

Natchitoches, LA

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

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 262

EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO551204

4725G

2017-04-25 At approximately 0530 hours on April 20, 2017, I spoke with

 regarding information that

 told me. She told me that

at approximately 0510 hours, she arrived in Live Hang to see live

hang employees cutting the necks of birds coming out of the

CO2 tunnel and putting them in the DOA bin. I asked 

how he ensured these birds were dead in the tank and he said

he couldn’t verify this information. I spoke with Plant Manager

Jody Long that day and the following day (April 21, 2017 during

the 1030 weekly meeting). Mr. Long looked into the issue and

told me that he looked at the video of the area and birds whose

necks were cut were obviously stiff and in rigor mortis. I

looked at the video with Mr. Long and on April 25,

2017 at approximately 0940 hours. The birds who were

obviously stiff and not moving were put in the DOA bin after a

neck cut. A conscious bird came out of the conveyer who was

sitting upright and occasionally flapping its wings. We saw an

employee reach for it with his knife and withdraw his knife

without cutting the bird. said that was when she

entered the area. Mr. Long said that employees know not to cut

conscious birds. The conscious bird was shackled and sent to the

electric stunner, to be slaughtered as the birds usually are.

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO001406

4507G

2017-06-07 I spoke to at 0915 hours regarding

three cadavers that were presented to USDA inspection between

0800 and 0915 hours. The birds had dark purple splotchy skin

that extended up the neck and inadequate cuts to the neck. Two

of the three birds had only a skin cut without a neck muscle cut

and the third bird had a cut trachea without any neck muscle

cut. was notified about the inadequate cuts and

bleeding. told me at 0915 hours that the auto-killer

was adjusted to make a deeper cut, employees would check the

auto-killer at least , and the issues will be

addressed with the backup neck cutter.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 263

EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO490706

5613G

2017-06-13 While performing antemortem inspection this morning, I spoke

with at approximately 0405 hours

regarding a bird stuck in a truck cage door. This bird had his

head, part of his neck, part of a wing, and part of a leg stuck

outside the cage in a manner such that he could not pull these

body parts back in the cage. No swelling, bleeding, or abnormal

breathing patterns were observed. While this bird was loaded

poorly, the truck had been parked in the shed for some time

and had not been noticed by plant employees. and I

discussed Good Commercial Practice procedures. Not only was

this bird not secured in a manner that minimized discomfort,

this bird could potentially have had breathing difficulties or

severe bruising. USDA employees will continue to monitor the

holding sheds.

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO191307

1620G

2017-07-20 I spoke to Plant Manager Jody Long at approximately 0850

hours while performing a Good Commercial Practice Verification

task today. Out of approximately 150 birds I looked at in the

blood tunnel, I observed one bird with a fresh, full-thickness skin

wound approximately 3” * 4” in width and length. The visible

muscle was moist. I showed Mr. Long the wound. Mr. Long said

the establishment would be more vigilant in watching for these

wounds on the truck and evaluating the live hang department

for areas that potentially injure the birds. Mr. Long and I had

recently talked about this in a weekly meeting on July 17, 2017

(MOI # UIO2811070119G). At that meeting, Mr. Long said that

he would talk to the Live Haul Manager and I received no further

updates.

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 264

EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO470907

0325G

2017-07-25 I spoke to at approximately 1015

hours regarding two cadavers presented to USDA inspection

between 0730-0745 hours. had observed those

cadavers at the inspection stands when they were presented.

The two cadavers today bring the total of cadavers this week to

four.  One cadaver had a superficial cut in the neck, intact neck

vessels, and wide, splotchy, purples patches all along the neck.

The other cadaver had similar patches all along its neck, but the

vessels could not be examined since the neck was ripped as the

carcass was removed from the line. Approximately 1⁄2 cup of

blood dripped out of the neck after it was removed from the

line. When  we spoke at 1015 hours, said that they

are checking the auto killer hourly and there is an employee

acting as a backup neck cutter to the auto-killer. He is not sure

why this issue keeps happening and he plans to monitor neck

cuts himself intermittently. We discussed issues of Good

Commercial Practice and unacceptability of the cadaver trend.

We have discussed this trend before (GCP MOI dated

6/7/2017 # UIO0014064507G and during the recent USDA

meeting on 6/17/2017 # UIO1913071620G).

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 265

EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO021308

2307G

2017-08-07 At approximately 0605 hours, I was in the blood tunnel for a

Good Commercial Verification check and I observed the carbon

dioxide stunner was not functioning properly. Some birds were

exiting the stunner conscious. The establishment was using an

electric stunner, their backup stunning mechanism. I stood at a

location and observed the production line that was located

approximately 75 seconds from the scalder.  While I stood

there, an establishment employee removed approximately ten

conscious birds in five minutes. At approximately 0610 hours,

an inspector removed a carcass from the line that was suspected

to be a cadaver. This carcass would have already been in the

scalder at the time that I was in the blood tunnel. I examined

the carcass and observed a shallow neck cut, intact neck

arteries, and splotchy, red marks on the neck skin. The carcass

was condemned as a cadaver. I spoke to 

 and he said he would investigate. At approximately

0900 hours, I spoke to and he told me that the

carbon dioxide filter was clogged and was changed. At that

time, the carbon dioxide tunnel appeared to be functioning

properly. I did not see any more cadavers or conscious birds on

the line for the remainder of the shift. This has been an

ongoing issue in this establishment. The trend of cadavers was

discussed in a weekly meeting on June 11, 2017 (MOI

UIO2811070119G) and documented in a GCP MOI on July 25,

2017 (UIO4509072125I).

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 266

EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO360708

5310G

2017-08-10 At approximately 0630 hours, a USDA food inspector hung back

a carcass for me to review. I observed a carcass with a purple

head and two skin cuts, with no knife cut into the underlying

neck. I condemned the carcass as a cadaver and showed it to

 did not have an

explanation as to how this miscut occurred, though we did

discuss his efforts of checking equipment, monitoring

employees, and observing neck cuts. Even with ’

corrective actions, the trend of cadavers has been an ongoing

issue in this establishment. Yesterday, I condemned a carcass as

a cadaver due to reddish-purple marks in the neck skin, a

shallow neck cut, and intact jugular and carotid vessels. Like the

cadaver today, did not have an explanation as to how

this miscut occurred.   The cadaver trend has been discussed

with the establishment before, in a weekly meeting June 11,

2017 (Memorandum of Interview [MOI] #UIO2811070119G)

and in Good Commercial Practice (GCP) MOIs on July 25, 2017

and August 8, 2017 (MOIs #UIO5412081607I and

UIO4509072125I, respectively). Since June 7, 2017, 33 carcasses

were condemned as cadavers for both of the two slaughter

shifts. Some of those carcasses were DOA cadavers, but a large

majority of the 33 carcasses were carcasses that were not

slaughtered properly. Throughout this trend, plant management

have informed me that they are taking actions, such as

increased observations and employee discipline, though the

establishment has not been able to ensure that birds are

slaughtered according to good commercial practices

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 267

EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO251309

4507G

2017-09-07 At approximately 1030 hours, I spoke with Plant Manager Jody

Long regarding five cadavers that were presented for USDA

inspection at approximately 0745-0755 hours this morning. All

had reddish-purple splotches in the neck skin extending from

the head and mostly up the neck. Two of the carcasses had only

a skin cut, and three of the carcasses had shallow neck cuts that

did not sever carotid or jugular vessels. I let Mr. Long know that

after the five carcasses were presented, I observed carcasses in

the blood tunnel prior to the chiller and noted several shallow

cuts. I observed no conscious birds at that time. Mr. Long and I

discussed the difficulty in making a cut deep enough for

slaughter but not so deep that presentation issues would arise.

Mr. Long investigated to see if he could learn from other

establishments, but reported to me that 579P is slaughtering

carcasses similar to other establishments. He did identify a

particular employee issue that may have played a role, and this

will be addressed. The cadaver trend has been discussed with

the establishment before, in a weekly meeting June 11, 2017

(Memorandum of Interview [MOI] #UIO2811070119G) and in 

Good Commercial Practice (GCP) MOIs on July 25, 2017, August

8, 2017, and August 10, 2017 (MOIs #UIO5412081607I,

UIO4509072125I, and UIO3407085210I respectively). In all

cases, the establishment reviewed slaughter practices, reviewed

potential employee issues, and increased monitoring. However,

this issue appears to recur.
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 268

EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO401409

1918G

2017-09-18 At approximately 1705 and 1815, two cadavers were presented

to USDA inspection with shallow neck cuts over the mandibular

area.  The heads and necks of both birds were reddish/purple,

splotchy, and the major vessels appeared intact.  While on the

evisceration floor viewing the second cadaver at approximately

1820 the issue with cadavers was discussed with the 

 and he stated that the blade that cuts

necks had been adjusted. The cadavers were also discussed with

 and it was discussed

that he would re-train the back-up neck cutter employee. 

During my further observations in the live hang area

immediately prior to where the carcasses enter the scalder, at

several times throughout the night, neck cuts appeared

adequate and no live birds were observed entering the scalder. 

This has been an ongoing issue at P579 as documented on

9/7/2017 in a Good Commercial Practices Memorandum of

Interview (UIO5406093307I) for 5 cadavers presented on day

shift as well as in several Good Commercial Practices MOIs

documented on July 25th, August 7th, and August 10th

(UIO4509072121I, UIO5412081607I, and UIO3407085210I).

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 269

EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

04C05 UIO211309

3325G

2017-09-25 At approximately 0840 on September 21, 2017, I spoke with

 regarding a cadaver presented to

the USDA station on September 20, 2017. This cadaver had a

purple-red head and upper neck, and had only a skin cut. No cut

was present in the underlying muscle or fascia of the neck.

There has been a cadaver trend at 579P, and has been

documented in MOIs and weekly discussions June 11, 2017/

MOI#UIO2811070119G,  July 25, 2017/UIO5412081607I, 

August 8, 2017/ UIO4509072125I, and August 10, 2017/

UIO3407085210I, September 7, 2017/UIO5406093307I, and

September 8, 2017/UIO4014091918G). shared my

concern and let me know that they evaluated the situation, and

saw that a wings were being caught in the automatic neck

cutter, thus preventing the neck cutter from fully cutting the

neck. The establishment installed a guide bar, which will

hopefully prevent future cadavers. The cadaver in question was

a small bird, and the guide bar will hopefully be helpful for small

birds. We discussed that employee on duty verifying the

automatic neck cuts is considered to be a very reliable

employee. I shared my concern that that even with a reliable

employee verifying, there was still a cadaver. Is there a system

error in the backup monitoring? said he would follow

up on this.

P6164A Foster Poultry

Farms

04C05 OIJ580904

5305G

2017-04-05 On April 4, 2017, at approximately 0925 hrs, I, 

 of P6164A, while on a GCP inspection observed a

fully-awake bird hanging in the shackles, having passed the

automatic slitter and back-up slitter, passed the head puller, and

progressing toward the scalding tank Before entry into the

tank, , removed the bird

from the line.  Upon examination, I found the bird’s throat was

only superficially cut, insufficient for slaughter as the bird was

fully alert and ambulatory.  then returned the bird

to the live-hang belt-trough for re-hang. In a meeting

immediately thereafter with , I described the event

and my findings with .  

proposed some corrective actions.  I asked him to notify

me of the establishment's final corrective actions, when they

were complete.This event is associated with a similar awake and

un-cut bird on shackles event on February 21, 2017,

documented in the establishment meeting MOI of February 23,

2017.

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 270

EstNbr EstName Task_Code MOI# Date Description

P622 Tyson Foods 04C05 NLB201807

0517G

2017-07-17 Present at meeting: USDA: 

  Tyson Management:

 P622 Tyson Foods Monroe

NC.   On 7/14/17 at approximately 2040 while performing a

Good Commercial Practices task, I observed that at the end of

the conveyor belt for line 1 there was a large pile of DOA birds,

up to the level of the conveyor belt approximately 2.5-3 feet

high and spread out over perhaps a 5 foot semicircle.  There

were also DOA birds about 1-3 birds deep on the concrete

behind the live hang platform, all along the length of it and

extending out perhaps 3 to 4 feet.  There were a couple of

employees trying to keep up by putting DOAs on racks and take

them out to the DOA bins outside, but it was clearly an

insufficient response to the level of problem.  Management was

contacted and I asked that the huge pile of birds at the end of

the conveyor belt be immediately sorted out to be sure there

were no live birds in that pile.  We saw one bird clearly alive at

the edge of the pile; it did not have any birds on it but was in a

spot where DOAs certainly could have fallen on it.  However,

after approximately 10 birds or so were removed, a live bird was

recovered which had been completely buried under dead birds.

Both this bird and the bird that was seen at the edge of the pile

were deemed healthy enough to go on to slaughter and were

put on the line.   Line 2 had numerous DOAs around it, but not

nearly as many as Line 1 and all of these birds were single layer

deep.  There were two live birds that I saw in this group, but

they were not in locations that it was likely that DOAs would fall

on them. Due to the extreme heat, stopping the line entirely

was not a humane thing to do and there were not many more

cages to finish the shift.  Management did bring in more

employees and made sure all the DOA birds were single layer

deep as they then collected them to take outside. I spoke to

 and

 about the situation and informed them that a

GCP MOI would be written because of the live bird found buried

under so many DOAs, and this bird could have could have

suffocated and died by means other than slaughter.  It is the

establishment’s responsibility to ensure that birds are

slaughtered in accordance with 9 CFR 381.65(b).  ,

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

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 271

EstNbr EstName Task_Code MOI# Date Description

 who was present while the birds were

sorted at live hang came by the USDA office about 30 minutes

later and said the total count was 626 DOAs collected off the

live hang floor. This MOI will be forwarded to the District

Office and the District Veterinary Medicine Specialist (DVMS) in

case additional follow up is recommended. If you have any

questions or concerns regarding this MOI, please feel free to

contact myself or . 

Respectfully, 

P646 JCG Foods of

Georgia, LLC

04C05 XAA01230

50130G

2017-05-30 On May, 29, 2017 at approximately 1453 hours, 

 while performing good commercial practice task in the

live hang area observed team member pick up DOA from the

floor and throw it in the red bin.  The bin was full and the team

member began to pull it to be dumped in the offal drain.  As the

team member started to dump the bin she asked him to stop so

she could observe the birds in the bin.  The team member began

to hand pick up the birds one by one and throw them in the

drain.  Halfway down in the bin observed a live bird

breathing hard, this bird had dead birds piled on top of it and

would have been dumped in the drain alive.  This establishment

had a similar incident that occurred and had put in place that

they would remove the heads of birds prior to placing them in

the DOA bin, they failed to do this.  Their failure to remove the

heads prior to putting them in the DOA bin has been discussed

with management as recently as 2 weeks ago when they were

observed throwing them in the bin without removing their

heads.  The bird was removed from the red bin and hung on the

line to be slaughtered.  Management, specifically 

 and 

was notified of their failure to comply with good

commercial practices.  They stated that they had a new

employee in live hang performing this job.   stated

that training would be completed with the supervisor

concerning putting new personnel on these duties.  The PPIA,

Agency Regulations, and Federal Register do require that live

poultry be handled in a manner that is consistent with good

commercial practices.  I notified that this issue would

be documented in a MOI and will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended.

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 272

EstNbr EstName Task_Code MOI# Date Description

P646 JCG Foods of

Georgia, LLC

04C05 XAA24190

71504G

2017-07-04 On July 3, 2017 at approximately 1515 hours, I, 

 while performing good commercial practice task

in the boiler room where they condemn DOA’s observed team

member taking DOA’s from the red condemn buggy and

throwing them in the ditch that goes to offal.  At this time I

walked over to the red buggy and he observed that he had got

to the bottom with a few birds left in the bottom.  I observed a

live bird sitting in the red condemn buggy.  I also observed 2

more DOA’s in the bin, one had the head on the other one the

head had been removed.  At this time I got the live bird out of

the condemn buggy and he stated that he had seen it and he

was returning it to live hang.  I took the bird to the supervisor so

he could observe that there was a live bird in the red condemn

buggy, I also told him about the head on others not being

removed.  stated that he disciplined the employee

and the employee stated that these birds had come from

dayshift and had been left over.  This establishment had a

similar incident that occurred and they had put in place that

they would remove the heads of birds prior to placing them in

the DOA bin, they failed to do this.  Their failure to remove the

heads prior to putting them in the DOA bin has been discussed

with management as recently as 2 weeks ago when they were

observed throwing them in the bin without removing their

heads.  This issue was also documented on 5/29/2016 again

where management were not removing the heads, on this issue

they stated that they had a new employee in live hang

performing this job.   stated that training would be

completed with the supervisor concerning putting new

personnel on these duties.     The PPIA, Agency Regulations,

and Federal Register do require that live poultry be handled in a

manner that is consistent with good commercial practices.  I

notified that this issue would be documented in a

MOI and will be forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case additional

follow-up is recommended.

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 273

EstNbr EstName Task_Code MOI# Date Description

P646 JCG Foods of

Georgia, LLC

04C05 XAA38020

93030G

2017-09-30 On September 27, 2017 at approximately 1610 hours, I,

, observed a pile of DOAs in the floor

that was 8 foot by 3 foot and piled 2 foot high, a live bird was

observed in this pile of DOAs with other birds piled on top of it. I

notified to stop hanging

and address the DOAs. The establishment stated the DOAs had

all come off of a trailer that had been arrived  in early in the

shift on dayshift.  I went to the live shed and observed that there

were birds that were sitting on trucks in the sun with no

aeration at all, the shed was full and there were four loads that

were not in the live shed.  I also observed that there were no

misters on for the birds in the live shed.    The PPIA, Agency

Regulations, and Federal Register do require that live poultry be

handled in a manner that is consistent with good commercial

practices.  I notified that this issue would be

documented in a MOI and will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended.

(b) (6)(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 274

EstNbr EstName Task_Code MOI# Date Description

P6504 Peco Foods, Inc. 04C05 CHK33120

65809G

2017-06-09 At 1215 hours on Friday 9 June 2017 during a routine

antemortem check and GCP verification, the following issues

were discovered during the course of inspection: 1.)  The

individual in charge of the dumper was dumping birds too early,

leading to birds being dumped on top of birds on the transverse

belt.  This was the 3rd time I have witnessed this in 2 weeks. 

The establishment was warned about this behavior and was told

that all birds had to be off of the transverse belt before dumping

a fresh cage to minimize injury and violation of GCPs. 

Premature dumping can cause suffocation, broken wings,

broken legs, and bruising, which, unrelated or not, has been

seen in post-mortem inspection at an increased rate in the 3

weeks I have been detailed to this plant.  2.)  There was 1

trailer remaining in the holding sheds.  The fans were off

because maintenance was replacing the water nozzles.  It is

close to the hottest part of the day with the ambient

temperature being recorded by The Weather Channel at 80

degrees F. 3.)  The individual running the bar in live hang that

controls the advance of the belt allowed birds to back up at the

end of the belt.  One bird's head was stuck under the partition

at the end of the belt and was trapped between the rolling belt

and the partition while the belt was rolling and was left there

for several minutes until I drew the individual's attention to this

problem and he removed the bird.  Further, the individual

controlling the speed of the belt forcefully jerked the bird from

under the partition even while the belt was still rolling.  This

could be construed as "egregious."  The plant has been warned

about birds piling up at the end of the belt and being pulled

under and into the partition without being hung on the shackles

in a timely manner by me last week (the week of 28 May 2017).
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 275

EstNbr EstName Task_Code MOI# Date Description

P6505 Norman W.

Fries, Inc.

04C05 BBA310805

4111G

2017-05-11 Est. P-6505, Norman W. Fries Inc.,May 10,2017, 1100 hours. In

attendance:

 At

approximately 1040 hours while performing A scheduled

Poultry Good Commercial Practices procedure in the Cage

Dump Area, I observed one live chicken with it's leg hung on the

right side of the Cage Dump Belt. The other birds were rolling off

this belt over this chicken. I also observed a dead chicken with

it's leg hung on the left side of the of the same belt. This bird

had been dead so long that it was stiff when removed from the

belt. I notified and this finding.I

reminded and that the PPIA and the

Agency regulations do require that live poultry be handled in a

manner that is consistent with good commercial

practices(GCPs), and that they do not die from causes other

than slaughter

P6505 Norman W.

Fries, Inc.

04C05 BBA280805

5011G

2017-05-11 Est. P6505, Norman W. Fries Inc., May 10, 2017, 1040 hours. In

attendance:

 At approximately 1040 hours, while performing

a routine Poultry Good Commercial Practices, and

myself observed a chicken with it's leg hung on the right side of

the Cage Dump Belt. This was causing the other chickens to

travel over this chicken. I informed of this finding. I

reminded that PPIA and Agency regulations do

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. I informed 

 and that I would be documenting this

incident on an MOI. At approximately

1300 hours, I was informed that repairs had been made to the

Cage Dump Chute to prevent the chickens from getting their

legs caught at the edge of the belt. also informed

me that he had ordered two mirrors that will be hung to enable

the operators to check the belt to ensure no birds were hung in

the future.

(b) (6)

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 276

EstNbr EstName Task_Code MOI# Date Description

P6510 Peco Foods Inc 04C05 WED19170

33513G

2017-03-13 Mr. Ronnie Tolbert Plant Manager Peco Foods, Bay Springs, MS

95 Commerce Drive Bay Springs, MS 39422 Mr. Tolbert,      At

approximately 1454 hours, while performing the Good

Commercial Practices in Poultry (GCPIP( verification task at

P6510, Peco Foods, Bay Springs, MS, the following less than

GCPIP incident was observed.   One (1) live young chicken from

an approximate 500 bird random sample with uplifted head,

rhythmic breathing, pupillary reflexes, and no visible cut to the

neck entered the scald tanks while still breathing.  The incident

was verified at the exit of the 2nd picker.  The carcass was red in

appearance with ventral pooling of blood in the neck, head, and

breast and no cut to the neck.  

 was notified.   A second verification

check of an approximate 500 bird random sample prior to the

scald tanks had no live birds entering the scalder.  This incident

was determined to be an isolated event.  Allowing bird(s) to

enter the scald tank while still breathing is not consistent with

GCPIP and results in adulterated product.  Poultry must be

handled and treated in a humane manner while under the

establishment's control on the official premises. A meeting was

held at approximately 1800 hours in the USDA office to discuss

the less than GCPIP incident.  

, and

 were in attendance.  

described the less than GCPIP incident stated the

kill machine was adjusted and the voltage to the stunner was

increased.  also stated that in addition to the

adjustments made to the equipment, a backup cutter would be

placed after the kill machine on the 2nd shift for a period of 1

week. As per Federal Register Notice Docket No. 04-037N,

dated September 28, 2005, "Treatment of Live Poultry Prior to

Slaughter", the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to abide by Good Commercial

Practices (GCPs) as described in industry guidelines. 

Respectfully, Canton, MS 1039

W. Fulton St. Canton, MS 39046 cc:  Mr. Perry Davis, DM       

Mr. Don Coley, DDM        Dr. Larry Davis, DDM        Dr. David

Thompson, DDM               

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 277

EstNbr EstName Task_Code MOI# Date Description

P6510 Peco Foods Inc 04C05 WED25210

74031G

2017-07-31 Today, July 31, 2017, at approximately 1855 hours, the

following was observed at P-6510, Peco Foods, while

conducting the Good Commercial Practices Task: There was a

yellow 'USDA Condemn' can in the live hang room. Within this

can there were approximately 11 poultry carcasses. One carcass

on the top was positioned so that the head of the bird was

within the DOAs underneath, and only the vent/tail area was

visible. I observed that the vent/tail area was moving

rhythmically. I pointed to the bird and an area employee

removed it from the can. The bird was alive- it was blinking,

moving it's head and wings, and had muscle tone that appeared

to be normal. The area employee used one hand to lift the bird

by it's tail as he showed it to me. He then placed the bird on the

belt of live birds to be hung on the line. I informed 

, of my findings, and

showed him the bird in question which was now on the belt. 

The treatment of live birds before slaughter is an important

animal welfare concern. Live birds buried beneath dead birds

may suffer and/or suffocate, dying by means other than

slaughter. Establishment management is encouraged to review

Federal Register Notice Docket No. 04-037N (dated September

28, 2005) for FSIS recommendations concerning treatment of

live poultry before slaughter. Establishments are strongly

encouraged to abide by Good Commercial Practices. 

Respectfully, 

 CC: 

 Mr. Don Coley, Deputy

District Manager 

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 278

EstNbr EstName Task_Code MOI# Date Description

P6616 Peco Foods of

Mississippi

04C05 IRE440902

0411G

2017-02-11 On February 11, 2017 at 0922 hours while verifying the plant's

Good Commercial Practices in Picking Room # 2 I, 

 observed one of the five hundred birds observed for

this task alive and conscious as it entered the scalder. The plant

otherwise exercised good control of their slaughter process. I

notified of this incident.  FSIS Docket No.

04-037N, Treatment of Live Poultry before Slaughter, states that

under the Poultry Products Inspection Act and Agency

regulations, live poultry must be handled in a manner consistent

with good commercial practices. In order to ensure that poultry

is handled and slaughtered in a manner consistent with Good

Commercial Practices, poultry should be treated in such a

manner as to minimize excitement, discomfort, and accidental

injury through processing. A copy of this memorandum of

interview will be forwarded to appropriate personal in the

Jackson District Office. Thank You, 

CC:  Mr. Don Coley, DDM

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 279

EstNbr EstName Task_Code MOI# Date Description

P6616 Peco Foods of

Mississippi

04C05 IRE511204

4026G

2017-04-26 On April 26, 2017 at approximately 1108hrs. , I, 

observed less than Good Commercial Practices while

performing a Good Commercial Practices check at P-6616. I

observed a live bird entering the scalder on picking line#2 ; the

bird had it's head up and was looking around ; there wasn't a

cut on the neck and it did not go through the head-puller. I

completed the check and did not see another live bird enter the

scalder but did manage to pull the one bird off the line once it

cleared the scalder for a closer examination. I concluded that

the system was not out of control and this was an isolated

incident.

and 

 were notified and made aware of my observation.

They were then informed that a GCP MOI document would be

generated from this incident. FSIS Docket No. 04-037N,

Treatment of Live Poultry before Slaughter , states that under

the Poultry Products Inspection Act (PPIA) and Agency

regulations , live poultry must be handled in a manner that is

consistent with good commercial practices. In order to ensure

that poultry is handled and slaughtered in a manner that is

consistent with good commercial practices, poultry should be

treated in such a manner as to minimize excitement, discomfort,

and accidental injury throughout processing. A copy of this

Memorandum of Interview will be forwarded to appropriate

personnel in the Jackson District Office. Thank you

 CC: Mr. Don Coley , DDM 

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 280

EstNbr EstName Task_Code MOI# Date Description

P6616 Peco Foods of

Mississippi

04C05 IRE381309

4505G

2017-09-05 On Sept. 5, 2017 at approximately 1114 hours, I, 

 observed less than Good Commercial Practices' while

performing a GCP check at P-6616. I observed a live bird enter

the scalder on picking line #2: the bird had its head up and was

looking around. After pulling the bird off the line after the

scalder tanks, I observed that there was not a cut or incision on

neck of the bird in question and it did not go through the head

puller. I completed the check for a total of five minutes and did

not see another live bird enter the scalder. I observed the

stunners and saw no issues there, but the backup kill employee

did not appear to be very attentive. I concluded that the system

was not out of control, and this was an isolated incident. 

, was in the picking

room at the time and I notified him of my observation and

handed him the bird I found. I then later notified 

; I also informed

them that a GCP MOI documentation of the observed deficiency

would be forthcoming. FSIS Docket No. 04-037N, Treatment of

Live Poultry before Slaughter, states that under the Poultry

Products Inspection Act (PPIA) and Agency regulations, live

poultry must be handled in a manner that is consistent with

good commercial practices. In  order to ensure that poultry is

handled and slaughtered in a manner that is consistent with

good commercial practices, poultry should be treated in a

manner as to minimize excitement, discomfort, and accidental

injury throughout processing. Thank you 

(b) (6) (b) (6) (b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 281

EstNbr EstName Task_Code MOI# Date Description

P6651 Tyson Foods Inc. 04C05 MSO01180

54409G

2017-05-09 On Tuesday May 9, 2017 at approximately 1423 hour while

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed a large (approximately two foot) pile

of feathers and filth densely packed at the end of the live hang

belt leading to the dead on arrival transfer belt.  Last night I

spoke with a supervisor after finding a live bird in this pile and

expressed my concern that this could lead to birds becoming

crushed and dying by means other than slaughter which would

result in a Good Commercial Practices MOI.  This area needed to

be kept free of debris to prevent birds from being trapped in

debris and becoming crushed/suffocating.  Today when I saw

the pile of debris I again expressed my concerns to the live hang

supervisor at which time I was told that it would be cleaned out

at break time.  I took my flash light and looked closer and saw a

breathing bird buried in the feathers and filth that was in

imminent danger of dying by suffocation.  I notified the

supervisor that there was a live bird in the pile and it needed to

be cleaned immediately.  The supervisor and an additional

employee cleaned out about half of the pile and a second live

bird was removed from deep in the debris.  I checked the pile

again and there was a third live/breathing bird towards the

bottom of the pile that I asked them to get out as well.   I had

them remove the rest of the debris under the belt to verify there

were no more live birds in the pile.  I explained at this time that

the USDA FSIS takes treatment of birds prior to slaughter very

seriously.  If the birds would have been allowed to remain in the

pile of debris until it was cleaned out at break they would have

died by means other than slaughter, which is unacceptable. 

This area needs to be cleaned and monitored for live birds at all

times.  Once the incident occurred today supervision was

informed that an MOI would result from these issues. As per

Federal Register Notice Docket No. 04-037N dated September

28, 2005, Treatment of Live Poultry before Slaughter, the Food

Safety Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely and abide by the Good

Commercial Practices (GCPs) as described by industry

guidelines. My observations are consistent with less than good

commercial practices. A copy of this Memorandum of

Interview will be forwarded to appropriate personnel in the

District Office. Respectfully submitted on May 9, 2017. 

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 282

EstNbr EstName Task_Code MOI# Date Description

 Cc: Dr. David Thompson, DDM 

P6651 Tyson Foods Inc. 04C05 MSO18210

62528G

2017-06-28 On Wednesday June 28, 2017 at approximately 1931 hour

while performing an Ante Mortem inspection and a Good

Commercial Practice Check with ,

I observed a live bird intermingled in a pile with six other dead

birds at the end of the belt that exits the live hang area.  An

additional large dead bird exited the belt landing on top of the

live bird pinning it in the pile of dead birds putting it in

imminent danger of becoming crushed/suffocating and dying by

means other than slaughter.  The establishment employee that

normally disposes of the dead birds and monitors for any live

birds walked by the pile, glanced over and continued to walk

into live hang with the door closing behind him.  Shortly

thereafter was walking by

the area about to exit to the live dock area when I motioned for

him and pointed out the live bird under the dead ones in the

pile.  He retrieved the live bird and put it back into production. 

A meeting was held with at that time

discussing Good Commercial Practices in depth.  I explained that

live birds should not comingle with the DOA birds as this puts

them at risk for suffocation / becoming crushed.  Once the

incident occurred was informed that an

MOI would be issued. As per Federal Register Notice Docket

No. 04-037N dated September 28, 2005, Treatment of Live

Poultry before Slaughter, the Food Safety Inspection Service

(FSIS) strongly encourages all establishments engaged in the

slaughter of poultry to make every effort to treat poultry

humanely and abide by the Good Commercial Practices (GCPs)

as described by industry guidelines. My observations are

consistent with less than good commercial practices. A copy of

this Memorandum of Interview will be forwarded to appropriate

personnel in the District Office. Respectfully submitted on June

28, 2017. Cc: Dr. Larry Davis, DDM 

Mr. Donald Coley, DDM 

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 283

EstNbr EstName Task_Code MOI# Date Description

P6651 Tyson Foods Inc. 04C05 MSO38180

95502G

2017-09-02 At approximately 2132 hours on September 1, 2017 while

performing the Good Commercial Practices verification task, the

following was observed at the entrance to the scald tank that

feeds evisceration line two (B line).  One young chicken was

seen entering the scald tank with an uplifted head, pupillary

reflexes, rhythmic breathing, and no cut to the neck.  The bird

was removed from the line just prior to exiting the picking room

and was notified of the incident and

shown the cadaver.  A second verification at the same scald tank

entrance was started at 2138 and immediately one live young

chicken with an uplifted head, pupillary reflexes, rhythmic

breathing, and no cut to the neck (there was a cut skinning the

very top aspect of the chicken’s head) entering the scald tank. 

This bird was removed and shown to in the

same manner.  A third verification from an approximate 500

bird random sample subgroup did not have any live bird(s)

entering the scald tank at approximately 2148 hours. Live

bird(s) entering the scald system live is a less than Good

Commercial Practices and results in adulterated product. The

establishment is responsible for ensuring that birds under their

control on the official premises are treated in a humane manner

that will minimize excitement, discomfort, injury and/or death

by means other than slaughter. As per Federal Register Notice

Docket No. 04-037N dated September 28, 2005, “Treatment of

Live Poultry before Slaughter,” the Food Safety Inspection

Service (FSIS) strongly encourages all establishments engaged in

the slaughter of poultry to make every effort to treat poultry

humanely and abide by the Good Commercial Practices (GCPs)

as described by industry guidelines.  A copy of this

Memorandum of Interview will be forwarded to appropriate

personnel in the District Office.  Respectfully submitted on

September 2, 2017 Cc: Mr. Donald

Coley, DDM Dr. David Thompson, DDM 

(b) (6)

(b) (6) (b) (6) (b) (6)
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P6651 Tyson Foods Inc. 04C05 MSO19220

95119G

2017-09-19 After removing several cadavers from line one (A line) while

giving food inspector breaks an additional Good Commercial

Practice check was done to determine the increase in cadavers

appearing on the inspection line.  At approximately 2106 hours

on September 19, 2017 while performing the Good Commercial

Practices verification task, the following was observed at the

entrance to the scald tank that feeds evisceration line one (A

line).  One young chicken was seen entering the scald tank with

an uplifted head, pupillary reflexes, rhythmic breathing,

movements and a superficial cut to the left side of the neck that

did not penetrate the vasculature.  

 was notified of these findings and that a

MOI would be issued.  A second verification at the same scald

tank entrance was started at 2111 of a 500 bird subgroup.  The

Shift Manager was present for this verification and manually

decapitated any birds approaching the scald tank that were not

previously decapitated. Live bird(s) entering the scald system

live is a less than Good Commercial Practices and results in

adulterated product. The establishment is responsible for

ensuring that birds under their control on the official premises

are treated in a humane manner that will minimize excitement,

discomfort, injury and/or death by means other than slaughter. 

As per Federal Register Notice Docket No. 04-037N dated

September 28, 2005, “Treatment of Live Poultry before

Slaughter,” the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines.  A copy of this Memorandum of Interview

will be forwarded to appropriate personnel in the District

Office.  Respectfully submitted on September 19, 2017 Dr.

 Cc: Mr. Donald Coley, DDM Dr. David

Thompson, DDM 

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

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P6666 Koch Foods of

Gadsden, LLC

04C05 GQH56120

53631G

2017-05-31 On Tuesday May 16, 2017 while performing an Ante Mortem

inspection and a Good Commercial Practice Check, I observed

several incidents of unacceptable bird handling/mistreatment.

At approximately 0009 I entered the live hang area; 

 had been present as well.  There is a metal plate

preset that dead on arrival birds roll under to become separated

from the live birds that get hung on the shackles. Live birds were

piling up at the end of the first belt that feeds evisceration lines

one and two. The birds were continually rolling under the metal

plate as well as over the top of the plate. On several instances

legs, wings and heads would get hung under the plate. The belt

operator continued to move the belt forward despite a pile of

birds being present and pressed up against the plate. The

Supervisor lowered the speed of the belt two different times.

After each time the birds were still piling at the end of the belt.

During these observations three completely flattened/crushed

and blood soaked dead birds came in over an approximately ten

minute period. After the third bird was seen and the birds were

no longer piling at the end of the belt I went to observe the

dump cage area to try to determine the cause of the crushed

birds. The establishment employee that was operating this

particular dump cage was the same one that was leaving birds

in cages and soaking them with the water pressure hoses that in

part resulted in the Good Commercial Practice Memorandum of

Interview GQH0812054831 issued the previous night’s shift. At

approximately 0024, the first cage that was observed to be

dumped, I observed a bird get crushed under the cage. Once the

cage was automatically moved back away from the belt bringing

birds into the establishment there was a bloody, badly injured

bird that had been crushed under the cage. The operator went

out to the bird, attempted to cervically dislocate the bird and

threw it from the dump cage stage to a condemned barrel that

was on the ground. I asked the operator to not dump any more

cages and to please get his supervisor. came

out to meet me and I informed him of the incident, explained to

him this was again unacceptable treatment of birds and that I

was going to apply a Tag not to let the employee operate any

further and we needed to have a meeting in the USDA office. I

applied U.S. rejected Tag B3802788 at approximately 0026. At

0028 I observed the bird that had been thrown into the

condemned barrel and it was still breathing. I looked up to the

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catwalk where the Supervisor was still present and informed

him that the bird was still alive. The dump cage operator then

stated that he had, “broke its neck.”  This was the only bird

present in the barrel, I reached in the barrel, felt the bird’s chest

and then again notified the Supervisor that the bird is alive, it

was breathing and had a heartbeat. I also asked if they could

please humanely euthanize the bird. The employee then came

down and manually decapitated the bird. A meeting was then

held with , establishment 

 and at approximately 0037 hour.

The incident, the gravity of the situation and that further

documentation would occur were explained during the meeting.

The proposed corrective actions were that the employee would

be suspended, retrained on animal welfare issues prior to being

allowed to return to work and a back-up operator would be

utilized. Maintenance would also fabricate a slide to prevent

birds from being able to climb back onto the stage where the

cages are moved as the second dump cage stage has that could

likely be started in the morning. I informed them that I would

remove the Tag when a new employee was in place and observe

operations. The Rejected Tag was removed at approximately

0052. As per Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live Poultry before

Slaughter,” the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines. My observations are consistent with less

than good commercial practices. A copy of this Memorandum

of Interview will be forwarded to appropriate personnel in the

District Office.  

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P6666 Koch Foods of

Gadsden, LLC

04C05 GQH08120

54831G

2017-05-31 On Sunday May 14, 2017 at approximately 2350 hour while

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed a weak moribund dorsally recumbent

bird with shallow respirations in an empty cage loaded onto a

trailer that was full of other empty cages. Additionally the bird

had deep lacerations to each of its digits on its right limb.  The

bird appeared to be suffering and in danger of dying by means

other than slaughter due to its weak condition.  At that time I

asked , who had been with me, to get a

supervisor.  came to the trailer where

the bird was located.  I explained at this time that this was

unacceptable to leave a bird in a cage and for birds to die by

means other than slaughter, I also pointed out the severe injury

to the birds digits and let know that USDA FSIS

takes mistreatment of birds very seriously.  I also notified him

that there had been three loose birds in the yard with fork lift

drivers driving around and USDA had to search for an

establishment employee to come catch the birds, this could lead

to birds becoming crushed. There was also a fourth bird loose in

the trailer holding shed.   At approximately 0010 hours while

observing the dump cages, an additional bird was seen that had

been left in a cage on the dump cage platform.  Once the cages

are dumped they are then sprayed out with high pressure water

to clean them prior to being automatically moved to the end of

the platform where they are picked up by the forklift.  The bird

that had been left in the cage had been sprayed with the

pressurized water and the doors to the cages had been closed;

the cage was being moved to the end of the platform to be

picked up by the forklift and none of the establishment

employees had seen the bird.  At that time USDA waved at the

dump cage operator and asked him to stop what he was doing

and notified him that a bird was still in the cage.  The employee

got the bird from the cage and returned it to production.  

again got   I informed him of the

incident and this was at this point was going to result in an MOI

and potentially further action if bird mistreatment continued to

occur.  An additional GCP check was done at approximately

0135, at 0139 myself and were standing on the

catwalk observing the same cage dump region, with the same

operator working, where the previous incident occurred and

again a bird was left in the cage, went unnoticed by both the

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cage dump operator and the supervisor and was drenched with

water by the pressure hose.  I immediately told the supervisor

and showed him the bird.  He had the dump cage operator

remove the bird and place it back into production.  I asked the

operator to stop dumping the cages while I filled out U.S.

Rejected Tag B38027087, I had to walk down the stairs of the

catwalk, around the outside of the cage dump stage and up

another set of stairs to apply the tag; while doing this the

operator dumped an additional cage after being informed to no

longer do so in front of supervision.  The tag was applied at

0144 and he was again told to no longer operate nor remove

the tag.  Supervision was told to meet with me in the USDA

office when they had corrective actions to resume operations to

prevent reoccurrence.  A meeting was held with the following

 and

.  I was told that an additional employee would

be stationed to the side of the dump cages as a temporary

corrective measure to monitor for birds left in cages until lights

could be installed over the cages which could possibly be done

in the morning.  I told them that we could try these measures

and see if they would work but this could not continue to

happen and I would remove the Rejected Tag.  The tag was

removed at approximately 0210.  After removing the tag, which

occurred during lunch break I walked through live hang.  Where

the second belt from the far dump cage, there are two, enters

the building the protective rubber flap that prevents the birds

from getting into the belt gears was bent away there was a live

bird tucked under the belt in between the gears that was at risk

of being crushed when the belt was restarted.  Additionally at

the end of the belt there were 12 dead birds with two additional

live birds in the pile at the very end of the belt.  There were not

any establishment employees or any supervisors in the area.  I

immediately went to the supervisor’s office to find 

 at approximately 0216 and asked him to accompany me

to the area to show him these situations.  I informed him that

the protective cover to the belt/gears must be fixed prior to

resuming production after lunch break.  He had already been

informed earlier in the evening that live birds could not

intermingle with dead birds.  At approximately 0309 

informed me that the belts covers had been fixed, I

observed the corrective actions.  Metal plates had been put up

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in place of the previous rubber ones, production resumed at

approximately 0310. was verbally informed

that due to birds being repeatedly mistreated by establishment

personnel, the incidents described above occurring in such a

short period of time, Supervision not reacting and correcting the

bird handling/mistreatment, the establishments equipment in

disrepair that could have caused further injury to birds, as well

as live birds comingling with dead birds that formal

documentation would occur. As per Federal Register Notice

Docket No. 04-037N dated September 28, 2005, “Treatment of

Live Poultry before Slaughter,” the Food Safety Inspection

Service (FSIS) strongly encourages all establishments engaged in

the slaughter of poultry to make every effort to treat poultry

humanely and abide by the Good Commercial Practices (GCPs)

as described by industry guidelines. My observations are

consistent with less than good commercial practices. A copy of

this Memorandum of Interview will be forwarded to appropriate

personnel in the District Office. Respectfully submitted, 

(b) (6) (b) (6) (b) (6)
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P6666 Koch Foods of

Gadsden, LLC

04C05 GQH00030

70531G

2017-07-31 On Sunday July 30, 2017 at approximately 1158 hour while

performing an Ante Mortem inspection and a Good Commercial

Practice Check with shadowing, I

observed a live bird intermingled in a pile under three other

dead birds and two processed carcasses at the end of the belt in

live hang that feeds evisceration line   The bird had a leg

trapped under a plastic guard plate at the end of the belt.  There

was not a supervisor in live hang at the time of the incident or

anywhere in the immediate area.  I asked the operator of the

belt to please stop pushing the belt forward to prevent any

further trauma to the bird as it was visibly struggling to attempt

to get out from under the other birds and from being trapped

under the plate.  The operator said, “okay” but continued to

move the belt forward.  The bird was becoming visibly weaker,

yet still breathing and alive.  I asked a second time for him to

stop and was again told okay as he continued to move the belt

forward.  At this time I asked to please

find a supervisor while I stayed with the bird.  While 

was attempting to locate a supervisor an establishment

employee with a radio passed through live hang.  I asked him to

please call for a supervisor to come to live hang as soon as

possible.  arrived at 0002.  I asked

 to please have the employee stop operating

the belt.  Once the belt was safely stopped I showed 

 the bird and explained the above situation to him.  He

removed the bird and placed it back into production and asked

if they could begin running the belt again.  I told him they could

and that a Good Commercial Practice MOI would result.  I then

went to check the other belt that feeds evisceration lines one

and two at approximately 0006 hour.  At the end of this belt

there were three live birds intermingled with an additional four

dead birds and wet feathers and filth on top of them that were

being continually pressed against the plate at the end of the

belt.  The live birds were pointed out to and he

put the birds back into production.  In addition there were

approximately 10 loose birds on the floor around/under the belt

and among the live hangers feet.  At that time I then asked him

if he had any questions about Good Commercial Practices or live

birds not comingling with dead birds since the last meetings

that we had when the previous Good Commercial Practice MOIs

were issued.  He said he did not.  As per Federal Register

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

(b) (6)

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 291

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Notice Docket No. 04-037N dated September 28, 2005,

Treatment of Live Poultry before Slaughter, the Food Safety

Inspection Service (FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good Commercial Practices

(GCPs) as described by industry guidelines. My observations

are consistent with less than good commercial practices. A

copy of this Memorandum of Interview will be forwarded to

appropriate personnel in the District Office. Respectfully

submitted on July 31, 2017. Cc: Dr.

David Thompson, DDM 

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Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 292

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P6666 Koch Foods of

Gadsden, LLC

04C05 GQH07220

80309G

2017-08-09 On Wednesday, August 9, 2017 at approximately 2043 hour,

while performing an Ante Mortem inspection and a Good

Commercial Practice Check, I observed one young chicken, with

an uplifted head, pupillary reflexes, rhythmic breathing and a

superficial nick to the skin on the right side of the neck entering

the middle scald tank that feeds evisceration line 

 was immediately notified. 

Live bird(s) entering the scald system is less than Good

Commercial Practices and results in adulterated product.   At

approximately 2347 hour during the same shift I entered live

hang and maintenance was working on the belt under the

shackles that feeds evisceration lines 1 and 2.  There were

numerous loose birds on the floor in live hang, the belt was not

functioning and there was a pile of 200 or more live and dead

birds intermingled at the proximal end of the belt where the

birds enter from the outside dump belt.  There was an

establishment employee standing on the belt throwing live

birds.  Numerous birds had been suffocated/crushed.  I

immediately asked to please have the

dump cage operator no longer dump any birds, as the process

was completely out of control and I would have to document

this in a MOI.  His demeanor became very threatening and he

began yelling at me and pacing.  I attempted to gather

additional information as to how the situation would be

rectified and he continued to shout and walk away.  At that

time I proceeded to the dump cage region to hang U.S. rejected

tag B28869058 on the dump cage area to ensure more birds did

not continue to flow in and cause further

harm/suffocation/death by means other than slaughter until the

establishment could regain control of their process.  As I was

walking to the dump cage region yelled

for me to stop.  I asked for him to give me a moment and

proceeded to go around the dump cage and up the stairs to

hang the tag.  had climbed through the bars of the

catwalk and onto the dump cage region to reach the area prior

to me arriving there.  Upon my arrival at the top of the stairs 

stood in front of me and blocking me from hanging the

U.S. rejected tag.  I asked him to please step aside so I could

hang the tag, then we could step down from the stairs where it

would be safer and I would be happy to speak with him.  He

refused to move and told me that I could not walk out there for

(b) (6)

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safety reasons.  I explained to that I was not going to

walk out there or step on the region he was referring to; I just

needed to place the tag.  He still refused to move and yelled at

me that he was not going to let me do that and that I was

interfering with their process and he was not going to take it.  I

calmly stated that either he could hang the tag or step to the

side and stay there while I hung the tag, but he was hindering

inspection and yelling is unacceptable.  then

stepped aside and allowed me to place the tag at approximately

2350 hour.  I then turned to walk down the stairs to speak with

 further.  He shouted, “Don’t you walk away from

me”.  I turned back to and again told him we can

talk further but I would like to go down the stairs where it is

safer and we could but it would be in a calm manner.  As we

came down the stairs he said aggressively he was not going to

tolerate me interfering with their process and was going to call

.  The establishment has been observed

consistently having birds stacked 3 layers deep on the belts in

live receiving and this has been discussed in depth with

numerous supervisors.  It has been explained to them that this

puts birds at increased risk of becoming crushed/suffocated as

well as causing increased stress and could result in a GCP MOI if

birds become crushed as a result.  This has been further

discussed and documented in the past two weekly HACCP

meetings held on Tuesday nights at 2345 on August 1, 2017 and

on August 8, 2017.  Further an establishment employee was

observed slinging a live bird against a plate at the end of the belt

that feeds evisceration lines 1 and 2 on August 9, 2017 at

approximately 0454 hour.  was

notified of these observations at this time and it was explained

that birds cannot be handled in this manner. The

establishment is responsible for ensuring that birds under their

control on the official premises are treated in a humane manner

that will minimize excitement, discomfort, injury and/or death

by means other than slaughter. At approximately 0015 a

meeting was held in the USDA office with 

and .  All of the above issues were discussed

as well as workplace violence and hindering inspection duties,

which is unacceptable by USDA FSIS.  Corrective actions were

verbally given by the plant in which they stated that a drive

chain broke on the belt, they would clear the birds from the belt

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

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and not resume production until repairs were made and control

was regained.  I then went with to

verify the process was under control and the birds had been

removed from the belt.  The U.S. rejected tag was removed at

approximately 0025. My observations are consistent with less

than good commercial practices. As per Federal Register Notice

Docket No. 04-037N dated September 28, 2005, “Treatment of

Live Poultry before Slaughter,” the Food Safety Inspection

Service (FSIS) strongly encourages all establishments engaged in

the slaughter of poultry to make every effort to treat poultry

humanely and abide by the Good Commercial Practices (GCPs)

as described by industry guidelines.  A copy of this

Memorandum of Interview will be forwarded to appropriate

personnel in the District Office.  Respectfully submitted on

August 10, 2017 Cc: Dr. David

Thompson, DDM 

P6666 Koch Foods of

Gadsden, LLC

04C05 GQH45100

84311G

2017-08-11 At approximately 1230 today while monitoring the live hanging

pen here at Koch Foods I observed in excess of 50 live birds on

the floor around and underneath the hanging belts.  I observed

an obviously sick but still live bird at the end of the hanging

belt.  A Koch Foods team member retrieved the live bird and

threw the live bird into a condemn can half full of dead birds.  I

shined my flashlight in the can and observed the bird still

breathing and moving its wings.  I discussed the issues with 

 who asked for a break

and said he would take care of it and it would not happen

again.  At approximately 1:30 PM I returned to the hanging pen

and observed in excess of 35 birds on the floor around and

under the hanging belts.   As per Federal Register Notice Docket

No. 04-037N dated September 28, 2005, Treatment of Live

Poultry before Slaughter, the Food Safety Inspection Service

(FSIS) strongly encourages all establishments engaged in the

slaughter of poultry to make every effort to treat poultry

humanely and abide by the Good Commercial Practices (GCPs)

as described by industry guidelines.   My observations are

consistent with less than good commercial practices.   A copy of

this Memorandum of Interview will be forwarded to appropriate

personnel in the District Office.   Respectfully submitted on

__________, 2017.

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P667 Mountaire

Farms Inc.

04C05 KYN23060

84824G

2017-08-24 The purpose of this Memorandum of Interview is to document

the events on August 18, 2017 related to the large quantity of

dead-on-arrival (DOA) chickens discovered during a Poultry

Good Commercial Task in the live hang operations. At

approximately 1200 hours, I observed behind the live hang belt

for kill line #2, four full condemn barrels of dead birds as well as

a large pile of approximately 50-100 dead birds, with 5 to 6 live

birds sitting on top of the pile of dead birds. I immediately

notified ,

of my observance. The live birds were retrieved and hung on kill

line #2 and all of the dead birds were collected and condemned.

At the time, said that the cause of the

excessive amount of dead birds was that a belt broke causing

the birds to be smothered. At 1330 hours a meeting was held

between me, 

 and , to

discuss this situation. reported that surveillance

video showed that belts never stopped moving and that the

birds that were observed to be dead in the live hang room were

actually dead upon arrival and that they had not been

smothered at the establishment. At approximately 1435 hours

the Night Shift SPHV and I, requested to review the surveillance

video to confirm the establishment’s claim. After a discussion

with the plant management of USDA’s right to view the

surveillance video, that the establishment was using as an

adjunct to verify it’s Good Commercial Practice compliance, it

was determined by USDA that the video was inconclusive. It is

expected that measures are taken during grow out operations

and during transit to reduce the number of birds dying prior to

approved methods of slaughter. In addition, transporting large

amounts of DOA’s on the highway should be avoided. 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. I

recommend review of the Federal Register on Treatment of Live

Poultry Before Slaughter for FSIS recommendations concerning

treatment of live poultry before slaughter. A copy of this MOI

will be forwarded to the District Veterinary Medical Specialist

(DVMS) in the event additional follow-up is recommended.

(b) (6)

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P689 Liberty Free

Range Poultry

LLC

04C05 JEF481209

5414G

2017-09-14 To: Plant Manager Phillip Paulk, At approximately 1200 hours,

while performing ante mortem on Lot 3, I noticed that one of

the coops was broken at the corner at the middle section that

joined the top and bottom parts of the coop. This break in the

coop left approximately a 2-3 inch opening with jagged edges.

The opening was large enough that if a bird stuck its head and

neck through the opening, they could potentially be injured. I

also noticed an empty coop on a trailer that had approximately

a 3-4 inch hole in the middle of the bottom part of the coop.

This hole had exposed sharp edges and was large enough a bird

could get a leg caught in the hole and injure itself. I did not see

any Supervisor in the unloading dock area so I went to find one.

I saw as she was exiting the building and

informed her of what I had seen. She radioed for the 1st

 and the unloading dock

 to meet us at the unloading dock area. I

then showed all of them the coops that were broken and had

the potential of causing injury to a bird. I asked 

, and if they had a program that addressed the

reuse of broken coops. I was informed by management that

they did not have a program in place at this time. On Thursday

September 7th, I had noticed several coops that were damaged

to the point that they could cause injury to a bird. Some of

these coops were empty and some of them had live birds in

them at the time of observation. I asked President Gerald

Lessard if the plant had a program to ensure that these coops

were removed from circulation so that they could be repaired

before any injury came to a bird. Mr. Lessard assured me at that

time that there was a program in place on the “live side” to

make sure that broken coops were not reused until they were

repaired. During the weekly exit meeting on 9-8-2017, I

discussed the issue that I had seen the previous day with the

establishment management team. I was informed by

management that they did not have a program at this

establishment to ensure that broken coops were not reused. 

 stated that a program was being designed

to address this issue. This is documented in

MOI - JEF36060957091. USDA’s concerns are that broken

coops are continually being refilled with live chickens. The

potential for injury to the chickens do exist. The establishment

does not have any written program in place to ensure that these

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damaged coops are removed from circulation even after a week

from when the first observation took place and I spoke to Mr.

Lessard. It also appears that the program on “ live side” does not

prevent the reuse of the broken coops eithe

P7085 Tyson Foods, Inc 04C05 HMO40030

11225G

2017-01-25 During the week of January 15th, the USDA Food Inspectors on

the lines were hanging back carcasses for further disposition

from the SPHV. Many of these carcasses had broken backs or

broken pelvis/thigh joints which resulted in the bird to bleed out

into the abdominal/chest cavity. Each time I examined one of

these carcasses, I showed GPM Trever Wood the carcass. USDA’s

concerns are that the live chickens are being handled in such a

manner that results in broken backs and dislocated joints which

either severs or bursts the blood vessels, which then bleed into

the abdominal/chest cavity. This type of handling is considered

to be excessive or aggressive due to the injuries that are seen on

postmortem examination. Tonight, January 24, 2017, there has

been an excessive number (10-15) of these types of carcasses

held back for further disposition from the SPHV. Once again I

have correlated with Mr. Wood and showed him each one of

the birds that bled internally. Some of the birds tonight were

condemned as DOA’s due to the fact that the bird bled out

internally and died prior to slaughter. Those carcasses had

broken backs and the down side of the carcass showed blood

pooling. USDA is concerned that the aggressive mishandling of

live chickens is still occurring. This mishandling is easily seen on

postmortem examination of the carcass. This type of handling is

reflective of failing to follow the National Chicken Councils

Guidelines for Good Commercial Practices as well as Tyson’s

policies for properly handling of live chickens.  

(b) (6)
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EstNbr EstName Task_Code MOI# Date Description

P7085 Tyson Foods, Inc 04C05 HMO53060

71903G

2017-07-03 On July 02, 2017 at approximately 0258 am I entered the live

hang room.  I observed sixteen dead carcasses lying on top of

thirteen live birds at the end of the conveyor belt on the floor.  I

observed five live birds under the conveyor next to the open

drain. On the left side of the hanging table were six birds and on

the left side were four live birds and one behind me all on the

floor. I notified verbally and visually of

the situation.  Assistant Plant Manager Trevor Woods reviewed

the video of the Live Hang room which confirmed the

information that I gave him.  APM Woods ensured 

and me, that he will hold the supervisors

accountable and this incident should not ever occur again.

(b) (6) (b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 299

EstNbr EstName Task_Code MOI# Date Description

P7091 Pilgrim's Pride

Corporation

04C05 SBF202203

5720G

2017-03-20 On 03 20 2017 at approximately 1548 hours, 

while conducting a Poultry Good Commercial Practices task in

the Live Haul holding sheds observed  birds were also open

mouth breathing and showing signs of heat stress in every

trailer ( those marked with an E for East plant as well as those

marked with a W for west plant).  There were several DOAs in

the DOA hoppers outside of Live Hang (3 of the 4 hoppers were

completely full) however, Live Hang has been kept in good

orderly fashion with minimal DOA cadavers observed on the

floor behind the hangers.  The grower was for Lot 2,

although, this task was started after the lot had switched from

Lot 1 of to lot 2, therefore, not all of the DOA

cadavers are from Lot 2. Last month (February), 

 spoke with to let

her know that he was going to talk with the growers and tell

them to start lowering the numbers of chickens in the cases in

preparations for the increased temperatures with Poultry Good

Commercial Practice handling as top concern. In addition, 

 has mentioned to 

 about noticing airflow conditions in the

Live Haul Holding Sheds last month on a high heat day. 

 did have maintenance out and improve the conditions

within the Live Haul Holding Sheds at that time

spoke with again on 03 20 2017 at approximately

1658 hours about the Live Haul Holding Sheds and the

possibility of misters like those that are in the back dock holding

area, he said he will ask about it and let know. 

The establishment is reminded in addition to the regulations

found in 9CFR 381.65(b.  FSIS encourages establishments to

develop and implement a systematic approach to ensuring

poultry presented for slaughter are treated in a manner that

minimizes excitement, discomfort, and accidental injury.  The

initial component of the approach is to assess the areas where

handling problems may occur.  Establishments should

periodically evaluate their handling methods to ensure that

their employees are treating animals in a manner that

minimizes injury, excitement and discomfort prior to slaughter

and that their methods ensure all poultry are slaughtered in

accordance with 9 CFR381.65 (b). Copies of this Memorandum

of Interview (MOI) will be distributed to the establishment,

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

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

(b) (6) (b) (6) (b) (6) (b) (4) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 300

EstNbr EstName Task_Code MOI# Date Description

inspection file and District Veterinary Medical Specialist per FSIS

Directive 6100.3.  Documented by 

(b) (6)
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EstNbr EstName Task_Code MOI# Date Description

P7101 Tyson Foods,

Inc.

04C05 LUC272208

3310G

2017-08-10 At approximately 2220 hours on August 8, 2017, while verifying

the effectiveness of the establishment’s adherence to good

commercial practice requirements, I observed the following: .

 was also present and observed the below

because he was performing an assessment of my verification of

their adherence to the regulatory requirements) On trailer

#17756, the back two cages of birds contained so many birds

that the birds were two deep (one bird sitting on top of another

bird because there was just no room on the bottom layer of the

cage) for at least 3⁄4 of each section of each of the two cages. The

cages were so packed full of birds that it was impossible to get a

good look at the majority of the birds in the cage on the trailer.

On the lower three or so levels at the edges of the sections of

the cage that could easily be seen, I observed at least 12 dead

birds and several other birds with purple colored combs and

waddles that were struggling to breath because they were

pushed so tightly against the side of the cage or had another

bird on top of them. I also observed several birds that had skin

abrasions and were bleeding because they were pressed against

the sides and side of the cage had rubbed the skin to make it

bleed. The lower cage of the two had one of the sections where

the door was open and birds were sitting on the door but none

were observed falling out of the cage or any other injury relating

to the door not being properly closed. 

 with us and observed this also.

, and Ryan Roper,

Assistant Plant Manager, came to the area and were also

notified of this issue. The dumpers were cleared of the other

cages, the trailer was moved to the unloading area, a skip was

placed in the line, and these two cages were dumped, the only

action that would try to prevent any further birds dying by

suffocation. The rest of the trailer was examined and no other

cages were observed in this condition of overcrowding and a

dead bird was observed here or there throughout the rest of the

trailer but nothing like what was in these last two cages. All of

the dead birds were condemned. There were approximately 336

dead-on-arrival birds from the two cages identified by the

establishment for trailer #17756. Based on establishment

documentation, the trailer was weighed at 2141 hours and our

observations were at approximately 2220 hours, so the trailer

had been on the lot for approximately 39 minutes in this

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 302

EstNbr EstName Task_Code MOI# Date Description

condition. After the two cages were dumped onto the live hang

line and the chickens that were alive were hung on the line, the

establishment took its company break. During this time, the

establishment notified FSIS personnel that all of the chickens

had been caught for this shift, so no further action was taken at

that time. I had to return to get ready to take the line after the

company break, so observed the last trailers that

came to the establishment and observed some of the sections of

the cages were full on one layer, none were loaded so that piling

up of chickens or suffocation was an issue. discussed

with that he was not going to take action and stop

the establishment’s kill since this was a catching issue and all

the chickens were caught for this shift. He discussed with 

 that prior to him ) leaving for the night, the

establishment would need to provide the actions it was taking

to ensure that this issue did not reoccur. The actions provided

included: “The Live Haul Manager, Live Production Manager,

and Complex Manager were notified of the overcrowded cages

observed on trailer #17756. Managers from the establishment

will meet with the contracted catch crew to discuss this and

ensure understanding of animal welfare expectations. Dead

birds will not be loaded on the farm in the same cage with live

birds. Catch crews will utilize head count per cage section to

prevent overcrowding in the cages.” discussed with

 that, while some of the dead birds could have been

dead at the farm, based on the signs observed with the birds in

the trailer and the way they were in the cages, the crowding of

the cage sections/suffocation of chickens contributed to the

number of dead carcasses observed in these two cages. Based

on the above actions, no regulatory control actions were taken

as a result of the observation of this issue. The next shift the

same calendar day, the establishment provided 

 information to demonstrate the actions were

taken as provided the previous shift.

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 303

EstNbr EstName Task_Code MOI# Date Description

P713 Gentry's Poultry

Co., Inc.

04C05 HDA43120

11726G

2017-01-26 GCP MOI Est. 00713 P; Gentry’s Poultry; January 26, 2017. In

attendance: 

Mr. Wayne Berry, Plant Manager. At approximately

1330, while performing a GCP Inspection, I saw 4 dead chickens

under the cage dumper, 1 dead chicken caught in the rollers of

the dumper, and 1 live chicken in between the rolling belts of

the dumper. I showed both and the

chickens that were falling through a hole in the dumper. 

 said that it was supposed to have been fixed yesterday

and that he would fix it as soon as possible. A plant employee

removed the live chicken from the belt area. I again reminded

 and that the PPIA and Agency regulations

do 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. I recommended that 

 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. I 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. 

(b) (6)

(b) (6)

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

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 304

EstNbr EstName Task_Code MOI# Date Description

P713 Gentry's Poultry

Co., Inc.

04C05 HDA32120

15826G

2017-01-26 Good Commercial Practices MOI Est. 00713 P; Gentry’s

Poultry; January 25, 2017 In attendance: 

 Mr. Wayne Berry,

Plant Manager. At approximately 0635 on 01/25/2017, while

performing a Pre-Operational Sanitation Inspection with 

I saw 4 live chickens huddled under the cage dumper

and 2 dead chickens lying under the cage dumper. Since no

cages had yet been placed on the dumper, these chickens were

obviously left over from the previous days' production. . 

said that the plant was having a problem with chickens

falling out of the cage dumper. then captured the

loose live chickens and placed them in a portable cage and

placed the dead chickens in a condemned product barrel.  

Later,  I reminded and that the PPIA and

Agency regulations do 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. I

recommended that 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. I 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. 

(b) (6)

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 305

EstNbr EstName Task_Code MOI# Date Description

P713 Gentry's Poultry

Co., Inc.

04C05 HDA02120

82811G

2017-08-11 On 08/09/2017, at approximately 0655, while conducting a

Good Commercial Practices inspection in the cage unloading

area, I observed the plant employee who was operating the cage

dumper throwing live chickens backhanded into the hopper. I

climbed the stairs and asked him to not throw the chickens,

instead to carry and place them in the hopper if they did not fall

out of the cage properly. A few minutes later, as I was watching

the cages being unloaded, I saw that 1 live chicken was left in

the presumably now emptied cage. The doors were shut, and it

was moved to the end of the dock to be picked up by the forklift

and placed back on the truck. After the forklift operator placed

the cage back on the truck, I asked him to stop and to go find

his supervisor and ask him to meet with me in the unloading

area. came out and I showed him the live

chicken left in the cage. He instructed the forklift operator to

remove the cage and then had the cage dump operator remove

the live chicken and carry it back to the hopper. The PPIA and

Agency regulations do 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.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 306

EstNbr EstName Task_Code MOI# Date Description

P727 Simmons

Prepared Foods,

Inc.

04C05 VCF321305

2902G

2017-05-02 On May 2, 2017, at approximately 11:00 hours, 

, met with 

.  The following is a synopsis of the discussion

and events regarding not slaughtering in accordance with good

commercial practices:  At approximately 06:35 hours while

attempting to find to determine the reason for early

break, observed maintenance personnel in the hanging

room. While looking for in the live hang area, I

observed that birds and carcasses had been left on the line for

Kill Line 2. As I observed the live birds/carcasses, I observed the

establishment had performed kill cuts on carcasses between the

end of the guide bar for the heads/necks and as far as they

could reach toward the stunner (approximately 6 carcasses). I

observed four carcasses that were in the neck/head guide bar.

The carcasses appeared stunned with no kill cut across their

neck. As I continued observing, I observed approximately 20

birds in the stunner. After  waiting an appropriate amount of

time in which the carcasses should have regained consciousness

and observing no breathing, I requested . After testing

to determine if the carcass was responsive to stimuli,  the

carcasses were removed from the line. Three of the four

carcasses were deceased with the fourth (which was in the

widest part of the guide bar) resumed breathing and regained

consciousness upon removal.  Based on my professional

experience, knowledge, and observations, the carcasses most

likely asphyxiated from the neck/head guide bar. Then, I

informed that allowing carcasses to asphyxiate is not

consistent with being slaughtered in accordance with good

commercial practices. informed me repeatedly that

the line broke down and inquired about how they were

supposed to prevent unanticipated equipment breakdowns. I

informed that carcasses must be slaughtered in

accordance with good commercial practices and although

equipment breakdowns cannot be anticipated, we still cannot

allow carcasses to die by asphyxiation or other methods

inconsistent with good commercial practices.  At approximately

07:05 hours, the establishment resumed production on Kill Line

1 as company break had ended. I observed that a large number

of birds were fluttering as they approached the kill machine and

after passing through the kill machine. The establishment had

two back-up killers present which were struggling to perform kill

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 307

EstNbr EstName Task_Code MOI# Date Description

cuts on the carcasses. This indicated to me based on my

professional knowledge and experience that the stunner had not

been turned on.  The establishment immediately corrected

and was later confirmed by establishment management.  Once

the line was repaired (approximately 40 minutes after the

malfunction of the kill line), the carcasses from the stunner were

removed from the line and disposed of via condemn barrels. At

approximately 11:00 hours, I met with and informed

him that birds must be slaughtered in accordance with good

commercial practices. My observations indicated that they had

not and that I was issuing an MOI documenting our discussion. 

At this time, I also discussed my observations regarding the

carcasses that appeared to enter the kill machine without being

stunned.   verbally informed me of plans to prevent

recurrence and I requested those plans in writing. A verbal

synopsis of the actions that will be taken when a Kill line

malfunctions were: stunners turned off, birds removed to

prevent drowning/persistent stunning, and kill cuts will be

performed on birds within the head/neck guide bar to prevent

asphyxiation. The meeting was adjourned at approximately

11:10 hours.

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 308

EstNbr EstName Task_Code MOI# Date Description

P727 Simmons

Prepared Foods,

Inc.

04C05 VCF240906

3529G

2017-06-29 On June 26, 2017, at approximately 07:15 hours, 

, and 

, met with   

The following is a synopsis of the discussion regarding cervical

dislocation and the establishment’s animal welfare plan. 

 reviewed the animal welfare plan for the procedure

regarding cervical dislocation. The animal welfare plan states

the thumb and index finger will be placed at the back of the

skull and the legs are quickly pulled with the other hand. 

expressed concern about whether this was the method

that the employees were utilizing. inquired about

where the method was acquired from. was informed

that procedure was adapted from live haul. informed

 and that they appear to pull more on the

neck than the legs and sometimes will twist the neck resulting

in decapitation of the bird. informed establishment

management that two or three birds were decapitated while

attempting to perform cervical dislocation.  There wereseveral

others (approximately 5-6) that had severe fluttering of the

body muscles for greater than 30 seconds as they traveled down

the conveyor. The establishment informed me that they would

perform retraining of personnel that perform cervical dislocation

to ensure that the procedure is being implemented as written. 

The meeting was adjourned at approximately 07:35 hours.

P7470 Mountaire

Farms Inc. - NC

Division

04C05 YRA241606

3414G

2017-06-14 While observing the plants GCPs at 16:16 I observed a live bird

in the dead on arrival bird bin half way buried. The bird looked

distressed at the time.  I informed 

of my findings. He immediately removed the live

bird from the bin.  The cause was determined to be that the

dead on arrival belt monitor left his station for a moment and

the line running

 added an additional monitor to the system to prevent

any future occurrence.

(b) (6)

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

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

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 309

EstNbr EstName Task_Code MOI# Date Description

P7470 Mountaire

Farms Inc. - NC

Division

04C05 YRA172208

1418G

2017-08-18 This memorandum of interview (MOI) is being issued to

document what was observed while performing a Poultry Good

Commercial Practices verification task on 08/18/2017.  At

approximately 1750 hours, I observed an excessive number of

DOAs coming down system 2 live hang belt.  There was a large

pile of DOAs, approximately 9 feet long by 2 feet high, pushed

against the back wall behind live hang belt 2.  I immediately

requested for 

 to radio for 

 to inform the employees to stop hanging on

Line 2 until the DOAs had been removed and disposed of

properly.  While observing the employees removing the DOAs

from the area, I noticed a live bird amongst the pile of DOAs at

the end of live hang belt 2 that moved once an employee

stepped on its wing.  When I questioned the cause of excessive

DOAs, responded and said it was due to the heat. 

Regulatory control was relinquished at 1805 hours and hanging

was allowed to resume once the DOAs had been disposed of

properly.  Establishment data showed Lots 2E and 8E reported

DOA percentages of 2.12% and 2.17% respectively. 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.  I

recommend review of the Federal Register on Treatment of Live

Poultry Before Slaughter for FSIS recommendations concerning

treatment of live poultry before slaughter.  A copy of this MOI

will be forwarded to the District Veterinary Medical Specialist

(DVMS) in the event additional follow-up is recommended.

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 310

EstNbr EstName Task_Code MOI# Date Description

P7470 Mountaire

Farms Inc. - NC

Division

04C05 YRA050809

4308G

2017-09-08 On 09/082017, at approximately 7:30 am and while giving

breaks, the Food Inspector on Line Station 2 ask for me to

inspect a carcass that she had pulled out of production for

condemnation. In the course of evaluating the carcass, I noted

that the bird was small in size, had a markedly swollen head and

the skin on the head and neck was a dark purple color. The

viscera was noticeably erythematous and congested. When the

neck was further evaluated there was no indication that a cut

was present to allow the bird to bleed out properly. These signs

are consistent with a bird dying from causes other than

slaughter. The carcass was shown to 

 and 

 and were told that an MOI would be

issued. The carcass was condemned.                 The PPIA (21

U.S.C. 453(g)(5)) as well as the Agency's regulations (9 CFR

381.90), provide that carcasses of poultry showing evidence of

having died from causes other than slaughter are considered

adulterated and thus must be condemned. It is also required

that the poultry be slaughtered in accordance with good

commercial practices, in a manner that results in thorough

bleeding of the poultry carcass, thus ensuring that bleeding has

stopped before reaching the scalder so that birds do not drown

(9 CFR 381.65(b)). Compliance with these requirements ensure

that poultry are not mistreated.                  A copy of this MOI

will be forwarded to the District Office and the District

Veterinary Medical Specialist in the event additional follow up is

recommended.

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

(b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 311

EstNbr EstName Task_Code MOI# Date Description

P7485 Wayne Farms

LLC

04C05 QBM13170

90230G

2017-09-30 On September 29, 2017, at approximately 2230 hours I

observed Less than Good Commercial Practice at establishment

P-7485 Wayne Farms in Jack, AL.  While performing a Good

Commercial Practice verification task, I observed one (1) live

bird in the DOA (Dead on Arrival) dumpster by the cage dumper

in the Live Receiving area of the establishment.  The live bird

was average in size, buried under feathers, fecal material and

other DOA’s. The top layers of debris and DOA’s did not contain

any denaturant. The bird’s head, neck and a partial wing was

visible.  The bird was alert, responsive and appeared to be in

good health.  I motioned for an employee in the Live Receiving

area that was assisting with cages being unloaded/loaded to call

for management.   After a few minutes, 

 arrived and I informed him of my

findings.  I reminded that the PPIA and

Agency guidelines require live poultry be handled in a manner

consistent with Good Commercial Practices (GCPs) by making

every effort to treat poultry humanely.  

immediately removed the bird from the dumpster and

humanely euthanized the bird by means of rapid cervical

disarticulation. I strongly encourage the establishment to

review Federal Register Notice Docket No. 04-037N dated

September 28, 2005, “Treatment of Live Poultry before

Slaughter” for recommendations concerning treatment of live

poultry before slaughter.  A copy of this Memorandum of

Information (MOI) will be forwarded to the Jackson District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended. Respectfully

submitted cc: 

      

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

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 313

EstNbr EstName Task_Code MOI# Date Description

P7487 Koch Foods, LLC 04C05 SPG220803

1920G

2017-03-20 On Thursday, March 16, 2017, at approximately 09:15 A.M., I

) performed good commercial

practices check. While performing the good commercial

practices check, I observed less than good commercial practices

in the picking room. I observed a live chicken with arched neck,

blinking eye at 280 picking line entered the scalding tank. I

retrieved the chicken (carcass) at eviscerating line number two

re-hang table after exited from the picking room. The finding

was shown to 

, and discussed the finding with

. The finding was not in compliance with

poultry inspection regulation 9CFR 381.65 (b). As per the

Federal Register notice Docket No 4-037N dated September 28,

2005, “Treatment of live poultry before slaughter.” The food

safety and inspection service strongly encourages all

establishments engage the slaughter of poultry to make every

effort to treat poultry humanely abide by good commercial

practices. Sincerely, , P-7487  Koch Foods of

Chattanooga Cc: , District Jackson 

      Chattanooga, District Jackson

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

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 314

EstNbr EstName Task_Code MOI# Date Description

P7487 Koch Foods, LLC 04C05 SPG270608

1611G

2017-08-11 On Wednesday August 9, 2017,  at approximately 07:25 A.M.,

(EDT) the plant manager Mr. Gary tallent informed the

inspection program personnel that a live trailer rolled over on

the farm.   At approximately 11:05 A.M., The trailer carrying

20 cages arrived at the Koch Foods P-7487 facility. I checked the

trailer and didn’t see any damage to the cages, but there were a

lot of dead birds in the cages . At approximately 1:00 P.M., the

management started segregating the live birds from the dead

birds. They were denaturing the dead ones and transferring

them into the offal trailer.   At approximately 4:35 P.M., the

management informed me that they will stop hanging the birds

on the 280-line and they will euthanize (cervical disarticulation)

all the live birds. I was in the live hanging area watching for

proper cervical disarticulation. I observed two barrels had one

improperly euthanized bird. I told the employees to remove the

bird from the barrel and euthanized them properly. I left around

5:02 P.M., and who was on pack out   took over.

They finished around 5:35 P.M.   As per the federal register

notice Docket No 04—037N dated September 28, 2005,

“treatment of live poultry before slaughter “The food safety

inspection service strongly encourages all establishments

engage the slaughter of poultry to make every effort to treat

poultry humanely abide by good commercial practices as

described by industry guidelines. Compliance with these

requirements helps ensure that poultry treated humanely. 

Sincerely,   P-7487.   Koch Foods of

Chattanooga, Jackson District cc: 

Jackson District      . Chattanooga,

Jackson District

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 315

EstNbr EstName Task_Code MOI# Date Description

P7487 Koch Foods, LLC 04C05 SPG211109

1425G

2017-09-25 On Friday, September 22, 2017, at approximately 09:00 A.M.,

trailer number 180 arrived at Koch Foods of Chttanooga

slaughter facility. I observed the following.  Most of the cages

doors were opened. Birds were trapped in between the cages. 

Birds were pile up on the trailer bed between the cages. Birds

were sitting on the top of the cages door, I saw three birds neck

were trapped in-between the cages door, necks were hanging,

were dead. The management started working on the cages,

putting the birds back into cages. The management started

moving the cages to the cage dump area. I noticed

approximately 15 birds fell off the cages during moving process. 

The findings were shown to plant manager Mr.Gary Tallent, and

. As per Federal

Register Notice docket No 04-037N, dated September 28,

2005,”Treatment of live poultry before slaughter” the USDA

food safety inspection service strongly encourages all

establishments engaged in slaughter of poultry to make every

effort to treat poultry humanely abide by good commercial

practices. Compliance with these requirements helps ensure

that poultry treated humanely. Sincerely, 

 P-7487 Koch Foods of Chattanooga. cc: 

 Jackson District.      . Jackson

District.

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 316

EstNbr EstName Task_Code MOI# Date Description

P7487 Koch Foods, LLC 04C05 SPG211009

4826G

2017-09-26 This morning, on September 26, 2017, at approximately 07:15

A.M., while performing the good commercial practices observed

the following less than good commercial Practices check in the

cage dump area. The trailer number 182 was parked in the

cage dump area to dump the cages at the cage dump station. I

observed small section of a bird’s wing was trapped under the

outer rear wheel of the trailer. The bird was struggling to free

its entrapped wing. The finding was shown to live hanging

supervisor. The driver moved the trailer and the supervisor

removed the bird, put back into the cage. At approximately

09:15 A.M., I met with 

 and notified about the above incident and told him

that inspection will issue a GCP MOI. FSIS DOCKRT

No.04-037N. Treatment of live poultry before slaughter, states

that under the poultry production inspection act and the agency

regulations live poultry must be handled in a manner that is

consistent with good commercial practices. In order to ensure

that the poultry handled and slaughter in a manner consistent

with good commercial practices. Poultry should be treated in a

manner as to minimize excitement, discomfort and accidental

injury throughout the processing. Sincerely, 

P-7487, Koch Foods of Chattanooga cc: 

 Jackson District        , Jackson

District

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 317

EstNbr EstName Task_Code MOI# Date Description

P758 Tyson Foods, Inc 04C05 ILK332203

3817G

2017-03-17 Tyson Foods, Carthage

Complex 3865 Hwy. 35 N. Carthage, MS 39051 , 

At approximately 2145 hours while performing the PHIS Good

Commercial Practices (GCPIP) verification task, the following less

than GCPIP incident was observed on the No. 2 picking line.  A

live young chicken, from a random subgroup sample of

approximately 500 birds, with uplifted head, pupillary reflexes,

rhythmic breathing and no cut to the neck entered the scald

tank.   A cadaver was verified at the exit of the last picker on the

No. 2 picking line with a bright red appearance, ventral pooling

of blood in the neck and head with no cut to the neck.   The

carcass was observed entering the evisceration department

where requested 

to remove the bird from the line.  took possession of

the carcass and requested 

 to radio for Mr. Frank Triplett, 2nd Shift

Assistant Plant Manager, and 

 responded to my request and was shown

the cadaver which had entered the scald tank while still

breathing.   The bird was relinquished by and given to

 for condemnation.  A second verification check of

approximately 500 birds was performed on the No. 2 picking

line with no live birds entering the scald tank.   This was

determined to be an isolated incident and not a loss of process

control.,   Allowing birds to enter the scald tank while still

breathing is not consistent with GCPIP and results in adulterated

product.  The establishment must ensure birds under their

control on the official premises be treated in a manner that will

not  cause unnecessary suffering, injury, or death by means

other than slaughter. A meeting was held in the USDA office at

approximately 2230 hours to discuss the less than GCPIP.  

and were in attendance. 

detailed the events to which resulted in the less than

GCPIP incident.  was informed that a MOI would be

issued in response to the incident.   stated 

would have to offer any forthcoming response from the

establishment. As per Federal Register Notice Docket 04-037N,

"Treatment of Live Poultry Before Slaughter", the Food Safety

Inspection Service (FSIS) strongly encourages all establishment's

engaged in the slaughter of poultry to treat poultry humanely

prior to slaughter and abide by Good Commercial Practices

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

(b) (6)

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

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 318

EstNbr EstName Task_Code MOI# Date Description

(GCPs) as described in industry guidelines. Respectfully, 

, Canton, MS 9024 1039 W. Fulton

St. Canton, MS 39046 cc;  Mr. Perry Davis        Mr. Don Coley 

       Dr. David Thompson        Dr. Larry Davis        

        

(b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 319

EstNbr EstName Task_Code MOI# Date Description

P7632 Zorro Leasing

LLC

04C05 HYE300603

2015G

2017-03-15 It was reported to me by   to

 that there were birds with a lot of bruises.  I inspected

the birds that were hung back and saw areas of blood tinged

fluid filled pockets between muscle and skin ranging in size. 

One was large enough to cover both breasts of the bird.  I did

a Good Commercial Practices Task to ensure proper handling of

the birds.  At the time of inspection, 

 was actively denaturing DOA birds in the

designated bin.  The employees hanging birds were doing so in

the appropriate manor not to cause harm to the birds.  The

employee at the Dumper station was checking to see if birds

were distressed or stuck in coops while using caution not to

dump birds on top of each other.  The birds, once hung, were

going through the stunner and past the blade consistently well

and I did not see any sensitive bird go into the scalder. I then

walked over to the shed where the Live Haul trucks are staged. 

The birds were quiet but the condition of multiple coops were in

disrepair.  Some areas had bent bars, broken bars and broken or

warped floor panels.  These areas that can potentially be

harmful to birds.  After inspecting several trucks, I saw one that

had a bird with its leg sticking out of the bars, between the

coops.  There was frank blood present on the leg and although

the bird was calm, when it tried to remove its leg it could not.  

The bird did not appear distressed and I did not see dripping

blood from the leg.  Due to the location, I could not see if this

coop was in disrepair or not. Live Hang personnel had gone to

break so I immediately called the office of 

 from my personal cell phone.  came to

where I was right away and called 

 to tend to the wellbeing of the bird and to see the

condition of the coops.  The coop was bent with pliers to allow

the bird to be removed without harm and immediately hung on

the shackles to be humanly slaughtered. I do not think the

bruises that were reported were a result of the coops and I do

not suspect mistreatment of animals at this establishment.  The

bruises could have possibly been inflicted during live catch at

the farm.  Please attend to the condition of the coops in

addition to the methods used to handle birds at the farm and in

transit to this establishment in an attempt to prevent the

conditions that we have seen. Respectfully, 

(b) (6)

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

(b) (6)


Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 322

EstNbr EstName Task_Code MOI# Date Description

P764 Perdue Foods,

LLC

04C05 CUA18070

73824G

2017-07-24 At 0623, while performing the poultry Good Commercial

Practices task, the following issue was observed: - After exiting

the kill room on line 1 (in which I had observed a trade off of

people in charge of backup killing), I stood at the location where

the birds on kill line 1 enter the scalder.  I was observing the

birds to ensure they were not breathing prior to enter the

scalder.  I observed a single bird with its eyes open and no

observable kill cut - I touched this bird and tried to find a kill

cut, which I was unable to find.  I signaled ,

who was standing nearby, and tried to non-verbally

communicate the problem (I am unsure he understood, so see

below).  I then visually followed the birds through the process

and observed them exit the first bank of picker machines.  There

was one bird seen with a swollen and congested (red) head,

without a kill cut.  I continued to monitor the birds on kill line 1

and did not see any further missed kill cuts or cadavers. - I

notified and 

of the problem in the receiving office

at 0630.

P764 Perdue Foods,

LLC

04C05 CUA19200

80624G

2017-08-24 On 8/24/2017 at 1754, while performing the Poultry Good

Commercial Practices task in the receiving area, I found one live

bird inside the dead-on-arrivals (DOAs) container. The bird was

partially buried under other dead birds, and was sprayed with

blue dye a chemical denaturing substance. I notified a plant

employee and he immediately removed the live bird from the

DOAs tank. Then I discussed this incident with 

the and 

, and I reminded him that live poultry must be treated in

a manner consistent with good commercial practices.  At 1922

 informed me that he made contact with 

 and 

 The discussion involved doing a PW3, (Corrective Action)

failure for Poultry Care Violation for a live bird in the DOA Bin,

and a Disciplinary Record for a Poultry Welfare violation. 

 will come in and do a retraining on all floor associates

and Team Leads on the requirements for placing a dead bird in

the DOA Bin. The documentation and training will be kept in the

Poultry Care Training Log Book.

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

(b) (6)

(b) (6)

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

(b) (6)

(b) (6)

(b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 323

EstNbr EstName Task_Code MOI# Date Description

P7669 Turkey Valley

Farms LLC

04C05 RZB451102

0420G

2017-02-20 Est. 7669p, Turkey Valley Farms, February 20th, 2017, 0635

hours. At approximately 0620 hours one of the USDA online

food inspectors notified me that he was condemning more

cadavers than normal. At approximately 0627 hours, while

performing a Good Commercial Practices verification task I

observed 1 out of 100 carcasses with no cut present on the neck

and showing signs of consciousness (blinking eyes, open mouth

breathing, raised head, and wing movement) proceed into the

scalder. This bird did not come into contact with the final

stunner located prior to the scalder. I waited after the feather

picking machines and prior to the hock cutter to verify that the

carcass had no cut present on the neck. During this time, I also

observed 3 out of 100 carcasses hanging by one leg. 

, was present throughout this task and

was immediately notified of the findings. 

 and Les Goff, Plant Manager were

also notified of the findings. The end of the lot was at

approximately 0645 hours. No further issues or concerns were

observed. Mr. Goff later notified me that disciplinary action was

taken to counsel the employee at the back-up kill station. In

the past 90 days one similar Good Commercial Practices

Memorandum of Interview (MOI) was documented on

11/30/16; MOI RZB2208112530G, titled Poultry Good

Commercial Practices / RZB1608115730I.

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 325

EstNbr EstName Task_Code MOI# Date Description

that he would look to modifying their scheduling due to time of

loading and/or inclement weather forecast.

P7669 Turkey Valley

Farms LLC

04C05 RZB270907

4125G

2017-07-25 Est. 7669p Turkey Valley Farms, July 25th, 2017 At

approximately 0820 hours, while performing a Good

Commercial Practices verification task, I 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 final stunner located prior to the scalder

was not operating. 

was present during this task and was immediately notified of

my findings. At approximately 0900 hours notified

me that the stunner was not working due to a wiring issue. At

approximately 0905 hours an additional 100 bird check was

performed and no further issues were observed. A similar Good

Commercial Practices Memorandum of Interview (MOI) was

documented on 7/21/17; MOI RZB5410072721G, titled Good

Commercial Practices. At this time, the final stunner was not

functioning properly. The corrective actions were either not

effective or not implemented properly to prevent recurrence.

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 326

EstNbr EstName Task_Code MOI# Date Description

P7903 Perdue Foods,

LLC

04C05 UYN36080

93528G

2017-09-28 At about 0955 on September 26, 2017, I was in the rehang area

and observed a cadaver on the line 1 rehang conveyor belt. I

demonstrated the cadaver to a supervisor. I continued to

observe the area and saw more cadavers on line Before the

birds go through the head puller on line , I picked off the line

 cadavers with bloody heads and no neck cuts and a cadaver

with a bloody head and a poor cut right below the jaw. The

birds were demonstrated to 

 and . I went to

the line cutting blade and verified that a back up cutter was

stationed there. I returned to the rehang area and pointed out

two additional cadavers with bloody heads and poor neck cuts

to informed me that he went to the

line cutting blade and replaced the back up cutter with

another person. Since I observed the first cadaver on the line 1

conveyor belt and not on a shackle, it is possible that cadaver

did not originate from line 1. That cadaver could have

potentially come from line . The plant utilizes large blue

containers to temporarily store out of flow birds. When the

plant employees have the opportunity to address the out of

flow birds, they will throw them on any of the three rehang

conveyor belts. The first cadaver could have been an out of flow

bird from line that was temporarily placed in a blue container

and then tossed on the line 1 rehang conveyor belt to be hung

on line 1.   At about 1330 at the change of shift, I performed a

GCP task. In the DOA hopper, there was a pile of several DOAs

and debris. I observed the head of a live chicken sticking out of

the pile. There were a couple of DOAs on top of it. I tried to find

a supervisor in the immediate area but could not locate one. I

went to the truck area and called over one of the plant

employees who works in the area, and I demonstrated the bird

to him. He left to find a supervisor. I dug the bird out of the pile.

 came to the area. I

showed him the bird and told him I found it in the pile of DOAs. 

At this plant, DOAs are placed on the DOA conveyor belts by the

lines. These conveyor belts deposit the DOAs into the DOA

hopper. A conveyor belt runs from the DOA hopper to a truck

outside. These belts are turned on manually by a plant

employee. They do not constantly run. A plant employee is

supposed to check the DOA belts periodically and remove any

live birds that mistakenly get on there. This is meant to prevent

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (4 (b) (b) (4) (b) (b) (b) (b) 
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 327

EstNbr EstName Task_Code MOI# Date Description

live birds from reaching the DOA hopper. Before the DOAs in the

hopper are transported to the truck, another person checks and

counts the DOAs. It is not written in the plant’s animal welfare

program exactly how frequently a person checks the DOA belts

and hopper for live birds. Since there was no way for me to be

sure when the DOA hopper would be checked next, I do not

know how long it would have been before someone found the

bird.         FSIS reminds the plant that it is their responsibility

to ensure the birds are handled in a manner that minimizes

excitement, discomfort, and accidental injury. FSIS encourages

establishments to develop and implement a systematic

approach to ensuring poultry presented for slaughter are

treated in a humane manner. The initial component of the

approach is to assess the areas where problems may occur. The

second component asks that establishments 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. Finally,

establishments should periodically evaluate their handling

methods to ensure that their employees are treating animals in

a manner that minimizes injury, excitement and discomfort

prior to slaughter and that their methods ensure all poultry are

slaughtered in accordance with 9 CFR 381.65(b). The

establishment is reminded that NRs for noncompliance with

381.65(b) and MOIs for GCPs when finalized are posted for

public review on the FSIS website and that the information

associated with NRs and GCPs can be FOIA requested by

individuals from the general public. The establishment is also

reminded that establishments with PHIS access can respond to

the MOIs and NRs in PHIS by using the response tab. Copies of

this Memorandum of Interview (MOI) will be distributed to the

establishment, inspection file and District Veterinary Medical

Specialist per FSIS Directive 6100.3.
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 328

EstNbr EstName Task_Code MOI# Date Description

P7987 Amick Farms,

LLC

04C05 QKA41220

10204G

2017-01-04 During the morning of 1/4/17, shortly after 0500, I was

observing the treatment of live birds in the live hang area. There

were a large number of live and dead birds under the live

hanging table and around the room. I observed a large pile of

birds (50+) near the line where the establishment hangs dead

birds before removing their heads and placing the birds in

condemn barrels. I observed that a bird at the top of the pile

was still weakly breathing. Given the unusually large number of

birds in the pile and the presence of a live bird, I was concerned

about the presence of more live birds in the pile. I went to the

production office and asked 

 to meet me in the live hang area. I showed him the

large pile of birds and the live bird on top of the pile. He had

establishment employees start to hang the birds on the

condemn line. As he searched the pile, he pulled out a live bird

that was being suffocated and returned it to the live hanging

table. At that point, I explained to him the establishment has to

ensure that live birds are not buried under a pile of dead birds. I

also showed him a live bird on an enclosed table where dead

birds were starting to pile on top of it. At the end of the live

hanging line, there is a short belt that transports birds to a table.

Live and dead birds can end up on the belt and table; however,

establishment employees should check the table frequently

enough to prevent live birds from getting buried. 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.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 329

EstNbr EstName Task_Code MOI# Date Description

P8289 Reichardt Duck

Farm, Inc.

04C05 XKC511709

2321G

2017-09-21 At approximately 1010 hours on 9/20/2017 at Est. 8289 while

performing the Good Commercial Practices task I observed that

only one employee was livehanging ducks on shackles.  On

several occasions the employee attempted to shackle two ducks

at a time causing ducks to be left hanging with only one leg in

the shackle.  I observed the ducks suspended by one leg flap

their wings and attempt to right themselves.  This practice could

lead to broken, disjointed legs and unnecessary discomfort to

the ducks.  I immediately instructed the employee to cease

livehanging and requested to speak with establishment

management.  arrived and I

explained the situation to him and he spoke with the plant

employee.  Normal hanging of the ducks resumed at

approximately 1015.  It is the establishment’s responsibility to

handle ducks in a manner as to minimize excitement,

discomfort, and accidental injury the entire time that live

poultry is held in connection with slaughter and not mistreating

birds or handling them in a way that will cause death, injury,

prevent thorough bleeding or result in excessive bruising.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 330

EstNbr EstName Task_Code MOI# Date Description

P843 Pilgrims Pride 04C05 PZA551101

2231G

2017-01-31 At approximately 0730 hours, while giving USDA breaks, I was

presented a small chicken that was a cadaver. Upon closer

observation, I noticed that although there was a cut on the side

of the neck, the cut was very shallow. Only the skin was cut. The

subcutaneous tissue and underlying blood vessel were not cut. I

immediately informed 

of my findings. She immediately went back to

the Kill Room to investigate. At 1145 hours, I held a meeting

with I reminded him that we

have had two other incidences of live chickens entering the

scalder last week. No other cadavers were observed the rest of

the shift. I also reminded him that this is in violation of

9CFR381.65(b) Below is a list Poultry Good Commercial

Practices MOIs that have been written in the last year. 

4/28/2016 PZA5606041228G Live bird entering the scalder 

4/29/2016 PZA2105045629G Live bird entering the scalder 

7/19/2016 PZA2403074819G Live bird seen entering the scalder

8/8/2016 PZA3313080908 G Cadavers 9/7/2016

PZA5703090907G Live bird seen entering the scalder 

10/26/2016 PZA4101100526G Three live birds approaching the

scalder with no visible cuts to their neck. 12/20/2016

PZA4610120320G Cadavers No cut on necks 12/21/2016

PZA1416121021G Cadavers Bad cuts 1/18/2017

PZA1210015018G Live Bird entering the scalder 1/18/2017

PZA1507010418G Live Bird entering the scalder 1/25/2017

PZA5813012225G Live Bird entering the scalder 1/28/2017

PZA5813012225G for a breathing bird seen entering the scalder

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 331

EstNbr EstName Task_Code MOI# Date Description

P843 Pilgrims Pride 04C05 PZA161302

0801G

2017-02-01 On 01 February 2017 at 1345 hours, while performing a

follow-up inspection of live birds entering the scalder.  I

observed 1 live bird on the kill line just before entering the

scalding tanks. The eyes were open and bird was trying to right

itself and vocalizing with no visible cut to the neck.  The bird

was removed from the line for observation by plant

management. and   were

both notified. Plant management was also notified that the

Poultry Product Inspection Act (PPIA) and Agency regulations

require that live poultry be handled and slaughtered in a

manner consistent with good commercial practices (GCPs), and

that they not die from causes other than approved slaughter

methods. Perthe regulation 9CFR 381.65 (b), Poultry must be

slaughtered in a manner that will result in thorough bleeding of

the carcasses and ensure that breathing has stopped prior to

scalding. Further planned actions have been ineffective in

preventing recurrence. This trend has been documented in

recent months in the following Poultry Good Commercial

Practices MOIs: PZA5511012231G on 1/31/2017 for a cadaver

bird. PZA2410014531G on 1/31/2017 for a breathing bird seen

entering the scalder. PZA5813012225G on 1/28/2017 for a

breathing bird seen entering the scalder PZA1210015018G on

1/18/2017 for a breathing bird seen entering the scalder 

PZA1507010418G on 1/18/2017 for a breathing bird seen

entering the scalder PZA2403074819G on 7/19/2016 for a

breathing bird seen entering the scalder PZA5703090907G on

9/7/2016 for a breathing bird seen entering the scalder 

PZA4101100526G on 10/26/2016 for three breathing birds

approaching the scalder with no visible cuts to their neck.

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 332

EstNbr EstName Task_Code MOI# Date Description

P843 Pilgrims Pride 04C05 PZA111303

4428G

2017-03-28 On 28 March 2017 at 0745 hours, after finishing giving

Inspector breaks.  I observed one bird on the evisceration line

with the head still on the bird and the throat was not cut

indicating a live bird entering the scalder.  At 0800 hrs. while

observing birds entering the scalder I observed one bird entering

the scalder the eyes were open and bird was trying to right itself

and vocalizing with no visible cut to the neck.  The bird was

removed from the line for observation by plant management.

 and  were both notified.

Plant management was also notified that the Poultry Product

Inspection Act (PPIA) and Agency regulations require that live

poultry be handled and slaughtered in a manner consistent with

good commercial practices (GCPs), and that they not die from

causes other than approved slaughter methods. Perthe

regulation 9CFR 381.65 (b), Poultry must be slaughtered in a

manner that will result in thorough bleeding of the carcasses

and ensure that breathing has stopped prior to scalding. 

Further planned actions have been ineffective in preventing

recurrence.     This trend has been documented in recent

months in the following Poultry Good Commercial Practices

MOI's: PZA1613020801G on 2/1/2017 for a cadaver and

breathing bird entering scalder. PZA5511012231G on

1/31/2017 for a cadaver bird. PZA2410014531G on 1/31/2017

for a breathing bird seen entering the scalder. 

PZA5813012225G on 1/28/2017 for a breathing bird seen

entering the scalder. PZA1210015018G on 1/18/2017 for a

breathing bird seen entering the scalder. PZA1507010418G on

1/18/2017 for a breathing bird seen entering the scalder. 

PZA2403074819G on 7/19/2016 for a breathing bird seen

entering the scalder. PZA5703090907G on 9/7/2016 for a

breathing bird seen entering the scalder. PZA4101100526G on

10/26/2016 for three breathing birds approaching the scalder

with no visible cuts to their neck

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 333

EstNbr EstName Task_Code MOI# Date Description

P855 Pilgrim's Pride

Corporation

04C05 FDA53230

43327G

2017-04-27 Est. P855, Pilgrims Corporation, USDA Office, April 27, 2017,

10:47 PM. In attendance: 

, 

 On 4/27/17 at approximately 2:30 AM during the

performance of a routine SPS task I observed

a pile of commingled live and dead birds at the doorway to the

live hang room on the L1 side, piled several birds high and

approximately 6x6 feet in area. It did not appear the live birds

were being smothered or suffocated, although they were unable

to move around freely.   was

picking up and throwing away dead birds. I left and attempted

to find  to notify her of the situation. I was unable to

locate her and decided to check the L2 side of the live hang

room. At approximately 2:40, observed birds being

piled too high in the dumper cages, to the extent that birds

were nearly touching the top of the cages. She informed 

 of this and at that time observed the pile of birds on the

floor on live hang Line 1. She left to inform of this

Good Commercial Practice violation.   At approximately 2:41

AM I observed another much more extensive pile of

commingled live and dead birds on the Line 2 side of the live

hang area, several birds high and extending from the wall on the

right all the way to the entrance to the door. I observed

breathing live birds in the pile underneath dead birds. Their

breathing appeared labored and difficult. While I did not

observe suffocated cyanotic birds, the amount of dead birds in

the pile was so excessive as to create the potential conditions

that lend themselves to smothering and/or suffocation. There

were no establishment employees picking up birds on this side.

 At 2:42 AM I took immediate regulatory control action and

informed that they would need to stop hanging

on Line 2 until the situation was corrected and the birds were

picked up off of the floor. Hanging was stopped and live birds

were sorted from dead birds, which were thrown away.  I

observed incidents in which two undersized birds were picked

up from above, being grabbed over the wings and neck area

with a single hand instead of by the leg and then tossed onto

the belt. I informed of these

incidents at this time. Once the birds were picked up off the

floor and humane conditions restored I released the line at

approximately 2:47 AM. Inspection stated that while 

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

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 334

EstNbr EstName Task_Code MOI# Date Description

 was in the process of picking up the dead birds, the fact

that the birds were piled up to the point of commingling dead

and live birds is an indicator that the process is out of control.

Employing humane methods of handling consistent with Good

Commercial Practice can help produce unadulterated product. 

Plant Response stated that while they want to

keep the lines full, humane handling procedures and good

commercial practices are a priority. He stated that there is

usually a person assigned to pick dead birds off the floor but

they have had issues with staffing. 

 has been instructed that when shorthanded hangers

should be pulled off of the line to pick up dead birds.  The

proposed corrective action is to add an additional responsibility

to the SSOP for live hangers. Live hangers already rotate

positions on the hanging line , wherein the first

hanger on the line rotates to the last position. The proposed

modification for the SSOP would add a responsibility to pick up

dead birds off of the floor during the rotation before returning

to the line. This modification will require corporate approval to

become formalized but the establishment has already

implemented this procedure within the live hang department.   

With regard to the mishandling of the undersized birds, 

 stated that he did not believe that the birds were being

mishandled, as they were not grabbed by the wings or necks

themselves. He made available the Pilgrims Corporation Animal

Welfare Procedures Training, 2016 Revision.

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 335

EstNbr EstName Task_Code MOI# Date Description

P9197 Perdue Foods,

LLC.

04C05 UAB59120

43612G

2017-04-12 At approximately 0845 hours while performing Good

Commercial Practices (GCPs) with ; in the live

hang room we observed an establishment’s associate throw one

live bird from the floor onto the incoming conveyor belt.

Unfortunately, I was unable to stop the employee from

throwing the bird; however I discussed with the associate not to

throw birds onto the conveyor belt. I was unable to determine if

the bird suffered any ill effects. I notified 

 and of the issue. 

 counseled the employee on humanely handling

birds according to the establishment’s poultry welfare

procedures. At approximately 1030 hours, 

performed a follow-up GCPs task and she observed an

establishment’s associate pick up ten live birds and properly

placed them on the conveyor belt. A copy of this compliant has

been sent to the 

 and .

P935 Allen Harim

Foods, LLC.

04C05 YXA081702

1120G

2017-02-20 On February 20, 2017 at approximately 1705 hours while

performing Good Commercial Practice (GCP) Verification I

observed one live bird on top of the approximate 50 DOAs pile

located on the stainless steel table at the end of the large bird

live hang line.  An establishment employee was removing the

DOAs from the stainless steel table when a second live bird was

uncovered at the bottom of the pile.  Agency regulations require

that live poultry be handled in a manner that is consistent with

GCPs and that they not to die from causes other than slaughter. 

 was notified of

the possible suffocation of the live birds in the pile of DOAs and

that this MOI would be forthcoming.  It is 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.  I 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. 

Respectfully,   Allen Harim Foods,

P-935 Harbeson, DE. 19951

(b) (6)

(b) (6)

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

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

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 336

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

04C05 YXA551604

3613G

2017-04-13 At approximately 1437 hours inspection personnel on line 1,

station 2 and station 3 notified me that they held back 1 carcass

each for final disposition.  Upon examination I observed the skin

and neck of both carcasses to be cherry red and petechiation of

the breast muscles.  The carcasses were condemned and

documented as cadavers.  

was notified and observed the cadavers.  had

establishment personnel make adjustments to the kill blade.  

At approximately 1600 hours while traveling to line 1, to

provide inspection breaks, the inspector at station 2 notified me

of 2 carcasses and the inspector at station 3 notified me of 1

carcass being held for final disposition.  Upon Examination I

observed the skin and neck of the 3 carcasses to be cherry red

and petechiation of the breast muscles.  The carcasses were

condemned and documented as cadavers.  At approximately

1650 hours the inspectors on line 1, station 2 and station 3

notified me of 2 additional carcasses (1 at each station) being

held for final disposition.  Upon examination I observed the skin

and neck to be cherry red and petechiation of the breast

muscles of both carcasses.  These carcasses were condemned

and documented as cadavers.  I then went to the kill line to

investigate further.  The establishment’s back-up kill employee

on the large bird line was having trouble keeping up with the

number of birds that were missing the kill blade.  I then traveled

further down the kill line where an additional back-up kill

employee is usually stationed however; there was no employee

in place.  As I was observing the birds moving down the line, I

observed 1 bird with its head raised and eyes blinking, which

had missed the kill blade and the back-up kill employee had also

failed to exsanguinate the bird.  

 appeared beside me and I showed him the live

bird traveling toward the scalders.  

 and I went to the entrance of the

scalder.  When the live bird appeared attempted to

remove the bird but was unable to unseat its legs from the

shackles.  called over the radio for the line to be

stopped however the live bird was partially submerged into the

scalder as the line stopped.  removed the bird

from the line plus an additional live bird (head raised, eyes open

and blinking and no cut to the neck) that had not entered the

scalder.  I notified and 

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

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 337

EstNbr EstName Task_Code MOI# Date Description

 of the cadavers observed at post

mortem inspection and the observation of a live bird entering

the scalder.  In response, management replaced the back-up kill

personnel and added an extra back-up kill employee to the large

bird kill line.  At approximately 1800 hours (start of lunch

break), inspection personnel on line 1, station 2 and station 4

notified me that they held back 1 carcass each for final

disposition.  Upon Examination I observed the skin and neck of

the station 2 carcass to be cherry red and the carcass at station

4 body, neck and head were cherry red with no cut to the neck. 

These 2 cadavers were identified during the time that

establishment management was initiating corrective measure

for the live bird entering the scalder. At approximately 1900

hours I returned to the kill line and verified that the corrective

measure was in place.  No live birds were observed entering the

scalder.  It is 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.  I 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. Respectfully, 

 Allen Harim Foods, P-935 Harbeson, DE. 19951

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 338

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

04C05 YXA181704

3114G

2017-04-14 At approximately 2145 hours while performing Good

Commercial Practice (GCP) verification I observed a live hang

employee, on the small bird live hang line, pick a live bird up,

hold the bird with one hand by the hips and throw it toward a

shackle.  The bird's right hock landed in the shackle while the

left hock and leg remained dangling.  

 was notified of the mistreatment

of the live bird during shackling. The live hang employee was

immediately removed from the live hang area.  

stated that the employee was disciplined and all live hang

employees will be re-trained on humane handling. It is

recommended that establishment management review the

Federal Register (attached) on “Treatment of Live Poultry before

Slaughter”, published September 2005 for FSIS

recommendations concerning treatment of live poultry prior to

slaughter.  I 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. Respectfully,     

 Allen Harim Foods, P-935 Harbeson, DE. 19951

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 339

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

04C05 YXA501605

0119G

2017-05-19 At approximately 1718 hours while performing Good

Commercial Practice verification I observed that there was no

denaturant on the birds in the DOA bin.  I removed several birds

off the top and noticed that there were a couple of layers of

DOAs that did not have a denaturant.  

 came over to the DOA bin and as we were

moving DOAs around in the bin, a few of them were moving. 

Upon investigation, a live bird was found buried under

approximately 4 DOA birds.  I then traveled outside to the

dumping station and observed a trailer of live birds stationed in

the direct sunlight, with no fans or misters.  The outside

temperature was approximately 87 degrees Fahrenheit.  

 and 

were notified of the possible suffocation of the live bird in the

DOA bin and the mishandling of birds that could cause death

prior to slaughter.  Two “fire fans” were placed beside the trailer

to cool the birds. It is recommended that the establishment

management review the Federal Register (attached) on

“Treatment of Live Poultry before Slaughter”, published

September 2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  I 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. Respectfully, 

 Allen Harim Foods, P-935 Harbeson, DE. 19951

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

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 340

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

04C05 YXA581805

4323G

2017-05-23 At approximately 1953 hours while verifying Good Commercial

Practice in the cage dump area, I observed 3 live birds under the

small bird dump station.  I continued outside to perform

antemortem inspection of the live birds in the trailers.  Upon my

return I observed an establishment employee gathering the

loose live birds under the dumping station and tossing them

over the stainless steel wall of the live hang belt and onto the

belt that transfers the live birds into the facility.  While catching

the last bird the employee grabbed and carried the live bird by

the head and neck then tossed the live bird over the stainless

steel wall of the live hang belt and onto the belt that transfers

the live birds into the facility.  This stainless steel wall is

approximately 7 to 8 feet off the ground. 

 was notified of the mistreatment

of birds and advises the establishment that preventing

mistreatment of poultry decreases the production of

adulterated carcasses. It is recommended that the

establishment management review the Federal Register

(attached) on “Treatment of Live Poultry before Slaughter”,

published September 2005 for FSIS recommendations

concerning treatment of live poultry prior to slaughter.  I

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.   

Respectfully,   Allen Harim Foods,

P-935 Harbeson, DE. 19951

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 341

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

04C05 YXA071006

3923G

2017-06-23 June 23, 2017 Subject:           Memorandum of Interview 

                        Mistreatment of live poultry             A meeting

was held in USDA office at P-935 on Friday June 23, 2017 at

1210 hours with 

) concerning the following Good Commercial Practices: 

On Friday June 23, 2017, one of the Inspectors on Evisceration

Line 1 Station # 3 called me for Veterinary disposition. Upon

examination of carcass, I observed that head of the carcass was

intact with no cut on neck veins. The facial area was swollen;

skin around the neck area was purple in color while rest of the

carcass was bright red in color. The carcass was condemned and

documented as cadaver. was immediately

notified of the finding. The Poultry Products Inspection Act

(PPIA) and the agency regulations do require that poultry must

be slaughtered in accordance with good commercial practices in

a manner that will result in thorough bleeding of carcasses and

ensure that breathing has stopped prior to scalding so that birds

do not drown or die other than slaughter. It is the Agency’s

expectations that all Good Commercial Practices be correctly

and effectively implemented. told me that back up

killers will get write up as per establishment policy and an

additional back up killer was placed on Kill line 1. 

assured USDA that the matter would be resolved. A copy of

this Memorandum of Interview will be forwarded to Front Line

Supervisor (FLS) in case additional follow-up is recommended

and a copy will be placed in the official USDA file.  Please feel

free to contact me with any questions or concerns. Sincerely, 

(b) (6)

(b) (6)

(b) (6)(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 342

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

04C05 YXA311807

1803G

2017-07-03 On July 3, 2017 at approximately 1705 hours while performing

Good Commercial Practice (GCP) Verification I observed

approximate 36 DOAs piled on the stainless steel table at the

end of the large bird live hang line.  Upon further investigation I

uncovered 3 live birds buried in the pile of DOAs.  Agency

regulations require that live poultry be handled in a manner that

is consistent with GCPs and that they not die from causes other

than slaughter. was

notified of the possible suffocation of the live birds in the pile of

DOAs and that this MOI would be forthcoming.  It is

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. I 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. Respectfully,     

 Allen Harim Foods, P-935 Harbeson, DE. 19951

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 343

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

04C05 YXA080907

0126G

2017-07-26 From:                    . Date:                    

07/26/2017 Subject:                               Poultry Good

Commercial Practice/ Meeting Date:   07/26/2017 Meeting

Time    : 6.45 Am Establishment: P 935 – Allen Harim Foods,

LLC Comments:                        To: Mr. Kevin Gordon, Plant

Manager.                 CC: . This

memorandum of interview serves as written notification of

occurrence of one Cadaver found on USDA inspection station

today July 26, 2017. At approximately 6.45am FI identified a

cadaver on line station 4. She held that carcass for 

Veterinary disposition and notified me accordingly. Upon

arriving at her station I observed that the head of the carcass is

intact with no bleeding cut on the neck. The facial area was

swollen; skin around the neck was purple in color while the rest

of the body of the carcass was bright red in color. 

 was immediately

notified of my findings. He assured me to take proper measures

to prevent recurrence. The Poultry Products Inspection act

(PPIA) and the agency regulations  do require that poultry must

be slaughtered in accordance with good commercial practices in

manner that will result in thorough bleeding of carcass and

ensure that breathing was stopped prior to scalding, so that

birds  do not drown or die other than slaughter. It is the agency

expectation that all Good Commercial Practices be correctly and

effectively implemented. The copy of this Memorandum will

be forwarded to Front Line Supervisor (FLS) in case additional

follow up is recommended. A copy will be placed in the official

USDA file. Please feel free to contact me with any question or

concern. Sincerely. 

(b) (6)

 CC: 

(b) (6)

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

(b) (6)

(b) 
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 344

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

04C05 YXA551308

3429G

2017-08-29 This memorandum of interview serves as written notification of

occurrence of three Cadaver found on USDA inspection station

today August 28, 2017. At approximately 8.35am FI identified

a cadaver on line station 1. She held that carcass for

Veterinary disposition and notified me accordingly. Upon

arriving at her station I observed that the head of the carcass is

intact with no bleeding cut on the neck. The facial area was

swollen; skin around the neck was purple in color while the rest

of the body of the carcass was bright red in color. 

 was Present notified

of my findings. He assured me to take proper measures to

prevent recurrence.  On the same line at about 11.00 two

other birds were observed with the head intact, no bleeding cut 

on the neck, the facial area was swollen skin around the neck

was purple in color and carcasses were bright in color.  

 assured me to take action and fix the problem.  The

Poultry Products Inspection act (PPIA) and the agency

regulations  do require that poultry must be slaughtered in

accordance with good commercial practices in manner that will

result in thorough bleeding of carcass and ensure that breathing

was stopped prior to scalding, so that birds  do not drown or die

other than slaughter. It is the agency expectation that all Good

Commercial Practices be correctly and effectively implemented. 

The copy of this Memorandum will be forwarded to Front Line

Supervisor (FLS) in case additional follow up is recommended. A

copy will be placed in the official USDA file. Please feel free to

contact me with any question or concern. Sincerely. 

 CC: 

(b) (6)

(b) (6)

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

(b) (4
Table:Memorandums of Interview (MOIs) in response to FOIA 2018-00062. 345

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

04C05 YXA061809

2121G

2017-09-21 At approximately 1920 hours, while performing ante-mortem

and Good Commercial Practice (GMP) verification on the carry

over birds, in the holding shed and in the yard, I observed the

following: One carcass on the ground in front of trailer #63 in

the second bay of the holding shed.  This carcass was flat and

had a tire mark down the middle of the body. Agency

regulations require that live poultry be handled in a manner that

is consistent with GCPs and that they not die from causes other

than slaughter. Upon further investigation I observed two (2)

loose live birds on the ground and six (6) loose live birds on the

floor of three (3) trailers, between the coops.  These loose live

birds were located in the cooling shed and the yard which is in a

high traffic area where incoming and outgoing trucks travel thus

creating the potential for birds to become injured or die from

causes other than slaughter. 

 was notified of the potential for birds to become

injured or die from causes other than slaughter.  All loose live

birds were placed in coops and all doors were secured.  It is

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. Respectfully, Allen

Harim Foods, LLC. P-935 Harbeson, DE.  19951

(b) (6)

(b) (6)

(b) (6)
Enforcement Actions for GCP from 01/01/2017-09/30/2017(source:09/11/2017)

Date Aer__ District Establishment_Number Establishment_ID

21-Jun-17 15-17-GCP074 15 M44932 32101

26-Apr-17 50-17-GCP062 50 P15724 20791

18-Apr-17 05-17-GCP061 05 284690

27-Apr-17 15-17-GCP060 15 M9230 25167

10-Mar-17 15-17-GCP053 15 P6058 25089

21-Jun-17 90-17-GCP069 90 P20322 23842

13-Apr-17 90-17-GCP055 90 P20245 20897

24-Feb-17 15-17-GCP052 15 P6164A 25095

24-May-17 50-17-GCP063 50 P34287 28079

7-Jun-17 90-17-GCP065 90 P509 23457

22-Jun-17 90-17-GCP070 90 P6529 23511

25-Jan-17 90-17-GCP051 90 P308 23384

27-Apr-17 90-17-GCP059 90 P1307 23479

31-Jul-17 90-17-GCP072 90 P40345 20395

24-Jan-17 90-17-GCP049 90 P6510 23416

31-Aug-17 90-17-GCP078 90 P6616 23417

29-Aug-17 90-17-GCP076 90 P890 23477

26-Apr-17 90-17-GCP058 90 P6504 23397

11-Apr-17 90-17-GCP054 90 P19112 20860

12-Sep-17 90-17-GCP080 90 P17340 20812

7-Jun-17 90-17-GCP067 90 P6638 23418

5-Jan-17 90-17-GCP042 90 P192 23401

3-Jan-17 90-17-GCP040 90 P17500 23438

7-Mar-17 50-17-GCP056 50 P39 21207

31-Jul-17 90-17-GCP073 90 P27427 28313

15-Sep-17 90-17-GCP083 90 P18557 23441

18-Jan-17 90-17-GCP046 90 P18557 23441

14-Sep-17 90-17-GCP082 90 P247 23472

19-Jan-17 90-17-GCP047 90 P247 23472

20-Jan-17 90-17-GCP048 90 P522 23391

13-Sep-17 90-17-GCP081 90 P522 23391

25-Jan-17 90-17-GCP050 90 P164 23453

26-Jul-17 90-17-GCP071 90 P6651 23400

28-Aug-17 90-17-GCP075 90 P758 23411

11-Sep-17 90-17-GCP079 90 P19514 20874

6-Jan-17 90-17-GCP043 90 P559 23392

9-Jan-17 90-17-GCP045 90 P6 23382

30-Aug-17 90-17-GCP077 90 P33833 27528

4-Jan-17 90-17-GCP041 90 P1235 23413

7-Jun-17 90-17-GCP066 90 P7485 23429

6-Jan-17 90-17-GCP044 90 P1317 23396
6-Jun-17 90-17-GCP064 90 P7342 23420

20-Jun-17 90-17-GCP068 90 P912 23394

15-Mar-17 50-17-GCP057 50 P1209 20590
PH_Establishment_ID Establishment_Name Size

123757 BelCampo Butchery

2091 Case Farms of Ohio, Inc S

D Bar X Meats

6112 Dayton Natural Meats, LLC S

6025 Draper Valley Farms S

4783 Equity Group Eufaula Div LLC L

2197 Equity Group Kentucky Division, LLC L

6036 Foster Poultry Farms L

12731 Huismann's Poultry V

4544 Koch Foods LLC S

4595 Koch Foods of Alabama L

4487 Koch Foods of Mississippi LLC L

4567 Mar-Jac Poultry-AL L

13933 Misty Lea Farm V

4512 Peco Foods Inc L

4513 Peco Foods of Mississippi L

4562 Peco Foods, Inc Canton Division L

4496 Peco Foods, Inc. S

2160 Perdue Foods LLC -Cromwell Plant L

2111 Pilgrim's L

4514 Pilgrims Pride Corporation L

4501 Pilgrims Pride Corporation L

4526 Pilgrims's Pride Corporation L

2477 Pine Manor Inc. S

9450 SS Enterprises of Warren Co., Inc. V

4530 Sanderson Farms, Inc. L

4530 Sanderson Farms, Inc. L

4554 Sanderson Farms, Inc. (Procesing Div) L

4554 Sanderson Farms, Inc. (Procesing Div) L

4490 Sanderson Farms, Inc. (Processing Div) L

4490 Sanderson Farms, Inc. (Processing Div) L

4538 Tyson Foods Inc L

4499 Tyson Foods Inc. L

4507 Tyson Foods, Inc L

2173 Tyson Foods, Inc. L

4491 Tyson Foods, Inc. L

4485 Tyson Foods, Inc. N

12540 Water Valley Poultry, LLC S

4509 Wayne Farms LLC L

4518 Wayne Farms LLC L

4495 Wayne Farms LLC L
4516 Wayne Farms LLC

L

4493 Wayne Farms, LLC

L

1914 Whitewater Processing Co.S
Enforcement_Action_Type comments comments_type

Good Commercial Practice Good Commercial Practices review CIC

Good Commercial Practice Routine GCP Visit CIC

Good Commercial Practice Custom Exempt Review

Good Commercial Practice Routine GCP review CIC

Good Commercial Practice Routine GCP visit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit Report

Good Commercial Practice Routine GCP visit CIC

Good Commercial Practice Routine GCP Audit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine GCP Visit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit CIC

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit CIC
Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine DVMS Verification Visit

Good Commercial Practice Routine GCP Visit CIC
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