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1111 --

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 1 

EstNbr EstName Task_Code MOI# Date Description 

M1015 Empire Kosher 04C05 ARE221509 12SEP2018 

Poultry, Inc. 0212G In attendance:  and 

. At approximately 1200 hours,

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

(b) (6)

Est. P-1015, September 12, 2018, 1525 hours. 

Food Inspector called me to her USDA 

inspection station and showed me a young turkey with cherry 

red skin on neck and carcass.  I observed that the cut in the neck 

is near the base of the beak which apparently the reason why a 

thorough bleeding is not achieved. The turkey line supervisor 

concurred that it is a cadaver and the carcass is condemned.  At 

approximately 1400 hours, 

called me again to her USDA inspection station and showed me 

a young turkey with cherry red skin on neck and carcass.  I also 

observed that the cut in the neck is near the base of the beak 

which, again, apparently is the reason why a thorough bleeding 

is not achieved. The turkey line supervisor concurred that it is a 

cadaver and the carcass is condemned.  At 1525 hours, I 

(b) (6)

conducted a meeting with 

.  I asked how he plans to prevent the

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

(b) (6)

recurrence of the incident.  said he has to confer with 

the rabbis who are responsible for severing the esophagus, 

trachea, carotid arteries and jugular vein.  I provided 

(b) (6)

a 

copy of the Federal Register Notice Vol. 70, No. 187, published 

September 2005 (Docket No. 04-037N) and recommended to 

review the treatment of live poultry before and after slaughter.  I 

also notified 

(b) (6)

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, 

(b) (6)

of Est. P-1015: 

Empire Kosher. 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 2 

EstNbr EstName 

M1345 Tyson Foods, 

6 Inc. 

Task_Code 

04C05 

MOI# 

BQB36130 

81416G 

Date 

16AUG2018 

Description 

At approximately 1230, August 16, 2018, I was performing 

Good Commercial Practices verification in live hang.  I walked 

toward the end of the live hang belt and was passed by

(b) (6)

 who had already been heard 

speaking on the radio about DOAs (Dead on Arrival).  As I arrived 

to the end of the belt I observed a pile that reached up to the 

edge of the live hang belt which is approximately 3 feet high. I 

observed an employee throwing carcasses into an inedible 

barrel and I also observed employees hanging birds onto the line 

from the same pile of birds.  These birds are large birds and 

average a weight of 7.36 pounds according to plant records.  A 

pile of this size can kill a bird caught underneath, and birds who 

are having trouble breathing would be easily killed from the 

weight or unable to breath.  The 

explained to me these DOAs fell onto the floor from the belt and 

they count them before placing them in the inedible barrel. 

This is not a good commercial practice.  The establishment 

failed to maintain control of the live-hang process and thus 

allowing both live and dead birds to be discarded into a pile on 

the floor.  . 

(b) (6)
3 

0 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 

EstNbr 

M1725 

M1725 

0 

EstName 

Tyson Foods, 

Inc. 

Tyson Foods, 

Inc. 

Task_Code 

04C05 

04C05 

MOI# 

UQI121206 

5025G 

UQI590709 

4529G 

Date 

25JUN2018 

29SEP2018 

Description 

June 25, 2018, verification of good commercial practices was 

performed at live receiving. The fans and misters for all holding 

bays were on (temperature was 84 degrees). The staging bays all 

had trucks in them. Bay B had the "outside" - facing bay A and 

exposed to direct sunlight with no fans or misters. The general 

condition of the chickens on the shaded, misted side was 

acceptable with quietly siting chickens, alert and responsive. On 

the exposed side the chickens were panting and appeared 

lethargic. Some were prostrated. During the time when the sun 

is directly on Bay B, please consider leaving the truck at the 

holding shed at the bottom of the hill or stage from bays A and 

C, until the shade reaches that side. I related this to the live 

hang supervisor the next day, June 26, 2018. I described my 

review of live receiving the previous day and of my concern. I 

also related to him that the District Veterinary Medical 

Specialist had cited this issue during his visit last month and had 

made a few suggestions to the plant manager verbally. I 

explained that I understood the argument that keeping all three 

of the staging bays full facilitated smooth movement and 

control of process. I encouraged consideration of ways to avoid 

the two plus hours that the sun was fully on that one side of the 

trucks. 

(b) (6)

agreed to take my suggestion under 

consideration. The entire conversation and my findings from 

June 25 were relayed to the attendees of the regularly 

scheduled plant meeting at 8:30 am on June 26th. 

September 29, 2018, inspection observed the first lot of 

chickens slaughtered today were the same chickens that were 

returned to the farm when slaughter was canceled on Thursday, 

September 27th. These chickens were remarkable in that .5% of 

these chickens had green, gangrenous bruising on wings and 

elsewhere. It was evident that these were injuries sustained 

during handling and transportation on Thursday. Plant 

management was notified and responded by slowing the line 

speed to allow online and offline trim. Though not technically 

monitored under the purview of FSIS since the injury possibly 

occurred off-premises, it is worth noting that these chickens 

were observed being reloaded for their return to the farm on 

Thursday by CSIs and they reported that they observed 

appropriate handling by plant personnel. 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 4 

EstNbr 

M1969 

7 

M2032 

2 

EstName 

Chaudhry Meat 

Company, Inc. 

Equity Group 

Eufaula Div LLC 

Task_Code 

04C05 

04C05 

MOI# 

ZCA111406 

1822G 

ATF171306 

5707G 

Date 

22JUN2018 

07JUN2018 

Description 

In compliance, PHIS would not allow me to delete MOI 

On 06/07/2018, at approximately 1301 while performing my 

Good Commercial Practices at the entrance of the scalder, I 

observed one small uncut, alive bird pass by. I noted that the 

bird was breathing and alert to its surroundings. At the point of 

observation, the establishment has no further humane measures 

in place to ensure that all breathing has stopped prior to 

entering the scalder. I visually followed the bird as it entered 

and exited the head puller (prior to the entrance of the scalder) 

and into the scalder where it entered still breathing. I completed 

my check and went to the exit of the picking system where I 

observed the cadaver bird, head attached and bright red in 

color, exit the picking system. I then followed the bird to the 

evisceration department where 

was notified and removed the

(b) (6)

(b) (6)

bird from the evisceration line. stated that 

immediate corrective actions would be put in place to ensure no 

other birds entered the scalder breathing (exchanging of 

employees). He stated that retraining would be implemented, as 

well as, disciplinary action. At approximately 1339 I performed a 

verification GCP to ensure that corrective action implemented 

was effective. No birds were observed going into the scalder 

breathing at this time. A review of the daily establishment 

animal welfare records indicated no deviations for the shift. The 

Food Safety and Inspection Service (FSIS) is reminding all 

poultry slaughter establishments 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, which means they should be treated 

humanely (Reference Federal Register Docket #04-037N). 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 5 

EstNbr EstName 

M2032 Equity Group 

2 Eufaula Div LLC 

Task_Code 

04C05 

MOI# 

ATF290206 

1325G 

Date 

25JUN2018 

Description 

arrived, and I explained the situation. At this 

time, the live hang belt was cleared, and the bird had expired. 

When extricated, the bird had been eviscerated, and the caught 

leg amputated. This bird died by means other than slaughter. 

Poultry Establishments are to treat poultry in a manner 

consistent with good commercial practices, and take steps, both 

in design and maintenance, to prevent excitement, discomfort 

and accidental injury, and to treat poultry in a manner 

consistent with such practices. 

On Thursday, June 21, at approximately 2155 hours, I was 

performing Good Commercial Practices in the live hang room. I 

noted a live bird stuck, on the live hang belt, partially under the 

bracket. The bird appeared to move and lift its’ head up as other 

birds moved over and around it. The bracket is located under 

the end of the dumping belt, and along the side of the live hang 

belt. This bracket serves to keep birds, that are on the live hang 

belt, from becoming entrapped in a roller on the other side of 

the bracket, and under the dumping belt. The bird in question 

did not move as the belt underneath moved. I looked under the 

belts and noted the bird had a leg which was under the bracket, 

and the foot had been caught in the roller. Two minutes had 

passed and the bird had not moved. I stopped live hang, and 

waited for a supervisor to arrive. At which time, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 6 

EstNbr EstName 

M2032 Equity Group 

2 Eufaula Div LLC 

M2130 Cooper Foods 

Task_Code 

04C05 

04C05 

MOI# 

ATF340407 

5911G 

HEF030006 

1822G 

Date 

11JUL2018 

22JUN2018 

Description 

On Tuesday, July 10, 2018, at approximately 0055 hours, while 

conducting Good Commercial Practices Review and Observation 

in the Live Hang room, I, 

(b) (6)

observed a 

bird that had it's foot entrapped between the dumping (wide) 

belt and the roller underneath. This is at the end of the wide 

belt, and the bird was actually on the live belt. The bird's leg 

was over the bracket used to prevent this situation. Live hang 

was stopped, and the 

(b) (6)

was 

contacted. Live birds were on, and around the trapped bird, so 

hanging was commenced to clear the birds from this area of the 

live hang belt. Yet, dumping of birds continued three times, and 

birds continued to fill the belts. USDA intervention was again 

required to encourage the plant to clear the area in order to 

extricate the entrapped bird. Upon removal, the bird was dead, 

and fresh blood was at the torn and dislocated hip joint. No 

rigor mortis was present. This is the location that resulted in 

leg entrapment, which caused the death of a bird, noted on a 

GCP MOI, ATF1600061025I, dated June 21, 2018. Federal 

Register 04-037N encourages Establishments that slaughter 

poultry to abide by Good Commercial Practices,  so poultry do 

not die from causes other than slaughter. 

observed the following; in trailer CF 41, a live turkey 

within one of the cages had been impaled through its cloaca by 

an approximately 3-4 inch long, 1⁄2 cm diameter metal bar that 

had broken away from the cage door at its top and was 

protruding inwards at a vertical angle, located over halfway up 

the cage door. A significant proportion of the turkey’s weight 

was resting on the bar at the point of impalement, which 

prevented the turkey from moving away. I informed a live hang 

employee, who assisted in freeing the turkey from the metal 

bar. Injury to the cloaca was visible, as the full length of the 

broken metal bar had penetrated the tissues. Multiple live haul 

trailers that are older in appearance (i.e. with rusted bars) have 

been observed with broken cage door bars that protrude 

inwards. This presents a potential risk of injury to live turkeys, 

similar to what was already observed in this event. 

On June 21st 2018 at approximately 5:15 AM, while performing 

antemortem inspection in the cooling shed area, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 7 

EstNbr EstName 

M2738 Pitman Farms 

9 

Task_Code 

04C05 

MOI# 

NCO36140 

54324G 

Date 

24MAY2018 

Description 

On 05/24/2018,at approximately 0950 hours, I made the 

following observation while on routine tour of the live hang 

area. I was watching the duck stunning operation. I observed 

several ducks that were not stunned. As I watched further, I 

noticed that there would only be one or two conscious birds out 

of a green cage and the rest were effectively stunned. The 

employees who hang the birds were removing the conscious 

ducks and placing them in a green cage at the end of the 

conveyor belt. I spoke with and 

about the ducks. Celeste immediately went to 

(b) (6)(b

) 

(6)

M2738 

9 

M2738 

9 

Pitman Farms 

Pitman Farms 

04C05 

04C05 

NCO46020 

64322G 

NCO56050 

65025G 

22JUN2018 

25JUN2018 

observe the employee's hanging the birds and took control of 

the situation. She had 

(b) 

(6)

have an employee recover the 

ducks and place them back through the gas stunner. I asked 

Ismael if they were using the back-up stunner. He stated that it 

was not working. We went to the duck platform and I observed 

Ismael remove four conscious ducks off the line in front of the 

back-up stunner. The birds were recovered and dealt with in a 

humane manner. Then they were placed back into the gas 

stunner. The issue of not having a working back up stunner is 

the main reason for this MOI. We would request a time line on 

the repair of this essential equipment. 

at 2010 hours checked trailer Lic# 4LJ5260 and 4HJ9350 

chickens-----4MF2121 ducks. all acceptable at 0011 hours on 

06/22/2018 checked trailer Lic. # 4HZ3160 chickens--acceptable 

4RE3568 ducks---found two duck outside of their cages, on the 

trailer bed between the modules. I contacted 

, who recovered the ducks and replaced them in their 

(b) (6)

cage. 

On 06/25/2019 at approximately 0321 hours I was performing 

an Ante-Mortem Inspection in the receiving area. Where I 

observed a live duck outside of the cages on trailer Lic.# 

1WY2771. I spoke with 

(b) (6)

,  he recovered 

the duck and placed it back in a cage at 0328. 
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1111 

1111 

8 

9 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 

EstNbr 

M2738 

M2738 

9 

EstName 

Pitman Farms 

Pitman Farms 

Task_Code 

04C05 

04C05 

MOI# 

NCO57220 

71811G 

NCO42170 

92220G 

Date 

11JUL2018 

20SEP2018 

Description 

At 2013 hours 

(b) (6)

was performing an Ante-Mortem 

task at the receiving area. As I approached trailer Lic#. 1WY2773 

I observed a chicken underneath it. I spoke with a driver who 

had just brought in a load of turkeys. While the driver was 

recovering the chicken, Maintenance 

arrived and I informed him that I was issuing a MOI for Poultry 

Good Commercial Practices. The chicken was recovered and 

placed back in the trailer. 

(b) (6)

On 9/20/18 at approximately 08:50 hours while performing a 

Good Commercial Practice (GCP) task, I observed the following. 

In the CO2 stunning area I found one green unit containing 

about 8 birds on the floor, underneath the end of the CO2 

chamber. Approximately 2 were dead, 1 was alive, and had 

approximately a 1⁄2 inch head injury near the comb. The injury 

from this bird was bleeding and the blood spread onto the other 

birds. The other 5 birds appeared alive and to be free from 

injury. Nobody was around appearing to tend to the basket. I 

looked around and found 

(b) (6)

) at 

approximately 08:52 hours. I asked him why the birds were 

there. He explained the unit was weak, possibly damaged, and 

the pushout hooks broke through it when loading it into the 

CO2 chamber. This caused an interruption of operations and 

injury to the bird. I followed up with 

area) and he further explained the situation. Ismael said that the 

issue happened within the last hour. Dr. Mayard and I explained 

the reason for our concerns to 

(b) 

(6)

. The green unit was in 

such poor conditions that it allowed the push-out hook to crush 

it, causing injury to the bird, and potentially harming other live 

birds which is not acceptable. Having birds injured from 

equipment failure unattended for an unknown amount of time, 

is causing undue suffering and is not in keeping with Good 

Commercial Practices. understood our concerns and 

(b) 

acknowledge that failing to immediately tend to the unit of 

birds is a failure on their part. He said, this was a first for them 

regarding the whole incident and would make sure to not let 

this happen again. He also said he would convey the poor 

condition of the green unit to his superiors to prevent this from 

happening again. 

(b) (6)
Table:Memorandums of Interview (MOls) in response to FOIA-2019-18 9 

EstNbr EstName Task_Code MOI# Date Description 

M3213 Dakota 04C05 JEB461007 20JUL2018 On 7 /20/18 at approximately 0915 hours while monitoring 

0 Provisions LLC 5020G conditions in pick and hang, I noticed a bird on the li ne before 

the scalder that was arching his neck and trying to escape t he 

shackles. I notifie , oft he 

conscious bird about to enter the scalder and had the li ne 

immediately stopped. While I observed this bird on the line, he 

was able to arch his neck a nd blink his eyes. They grabbed a 

portable ladder and pulled the bird off the line. The bird had a 

superficial skin cut only. No major vessels were severed. The 

bird was then immediately relocated back on the line before the 

neck cutter to start the process over, 111111 stated t hey are 

having mechanical issues with t he stunner. He offered to slow 

down t he line and also use the back-up stunning device to allow 

for better stunning. He also stated- would do extra 

monitori ng of birds entering the scalder. The automatic cutter 

would also be looked at to ensure it is functioning properly. The 

incident t hat took place is a concern due to the neck cut miss 

and its path straight to the scalder to drown, as it was still 

breathing and fully conscious. I immediately notifie. 

, who is filling in for 

e incident. immediately called for a 

to discuss the incident and to further 

investigate. immediately called for an investigation as to 

the mechanical issues ofthe stunner. Employing humane 

methods of handling a nd slaughtering that are consistent with 

good commercial practices increase the li kelihood of producing 

unadulterated product. Poultry must be slaughtered in 

accordance with good commercial practices in a manner that 

will result in t horough bleeding of the carcass and ensure t hat 

breathing has stopped prior to scalding. Stunning of poultry, 

when performed, is also expected to be done in a consistent and 

effective manner. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 10 

EstNbr EstName 

M3414 Kadejan, Inc. 

5 

Task_Code 

04C05 

MOI# 

JQU311406 

1207G 

Date 

07JUN2018 

Description 

, he informed us 

that the plant would write up a new SSOP for cleanup lots and 

would also talk to the farmers about the severity of this action. 

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 methods of handling and slaughtering that 

While performing a Good Commercial Practices Verification at 

0920 hours on June 6, 2018, I observed that there was already a 

55 gallon drum or barrel that was full of DOAs (Dead on Arrival) 

in the live hang area where the drum was located. When I 

inspected the pens or batters where the birds were kept in, I 

observed that some of the drawers in the batters were packed 

heavier than other drawers. The plant had previously informed 

me that there are only to be twelve birds in an individual drawer 

of the batter. When I counted the birds in one of the drawers, I 

observed that there were fifteen birds in that drawer and I 

counted sixteen in yet another drawer. I inspected five drawers 

and observed that two out of the five drawers I had inspected 

had an excessive number of birds and there were only three 

batters left in that lot. In another batter, I observed a dead bird 

where the drawer had been closed with a chicken’s head 

wedged between the top of the drawer and the frame. I 

observed birds that had been staged inside the building that 

were breathing with their mouths open and there was no extra 

space in the drawer for the birds.  According to establishment 

records there were a total of 78 DOAs in the first lot. The FSIS 

Inspector condemned 20 birds in the lot of 1,406 birds. The 

outside temperature was 66° F. according to the weather on my 

cell phone. It was cloudy but not too humid with a slight breeze. 

I understand that this was the end of the barn and the farmer 

and the plant wanted to clean out the barn. The establishment 

had previously informed inspection that this would be a clean 

out lot and they would be changing lots at break time. When I 

inspected the batters from the second lot (lot #060) the birds 

appeared to have more room to move and were not as close 

together as in the first lot. They were not panting in excess, as 

with the first lot (lot #059). The three drawers I checked only 

had the twelve birds in each drawer as discussed with plant 

management. When Inspection discussed this MOI with 

(b) 

(6)
11 

4 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 

EstNbr 

M4513 

EstName 

Birdsboro Kosher 

Farms Corp. 

Task_Code 

04C05 

MOI# 

FKJ590906 

0220G 

Date 

20JUN2018 

Description 

are consistent with good commercial practices increases the 

likelihood of producing unadulterated product. This MOI will be 

forwarded to Dr. Larson and to Dr. Hotvet at District Office. 

Today on 06/18/2018 the inspectors found 21 carcasses were 

condemned as Cadaver (died with a cause other than 

slaughter) . After further inspection I found that the cause is 

Insufficient cut for both jugular veins. This is considered as Good 

Commercial Practice issue. 

(b) (6)

was informed 

with this issue. 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 and slaughtered humanely. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 12 

EstNbr EstName Task_Code MOI# 

M6137 Foster Farms 04C05 BXL240306 

4415G 

Date 

15JUN2018 

Description 

This MOI is intended to document the Poultry Good Commercial 

Practices incident that occurred on Thursday, June 14, 2018. At 

approximately 2315 hours, while monitoring the live hangers in 

plant 2 and utilizing a flashlight, I observed a big pile of Dead 

on Arrival (DOAs) birds lying on the ground behind live hang 

employees in line 3. I notified lead person in charged 

(b) 

about the excessive amount of birds on the ground and 

(6)

the failure to comply with their Bird Welfare and Handling 

Procedures which states in part “ 

” person began to remove the DOAs and 

placing them on a grey barrel. While I was illuminating the pile 

(b) (4)

(b) (b) (6)

(6)

with my handheld flashlight and Lead person continuing 

removing the DOAs, I noticed a bird under the pile moving and 

blinking. 

(b) (6)

grabbed the bird and placed it 

back on the conveyor belt to get hang on the line. Continuing 

with the removal of DOAs from the ground, I noticed another 

bird under the pile breathing hard. This bird could not voluntary 

move but showed signs of still been alive and not been 

euthanized properly on time. A third live bird was observed by 

me being removed under the pile that was blinking and moving. 

The bird was also placed on the line to be slaughter. A total of 3 

birds were observed alive and been under the pile of DOAs. I 

Welfare and Handling Procedures. 

was also notified of the incident and notified him

(b) (6)

(b) (6)

notified of the failure to comply with the Bird 

that agency regulations do require that live poultry are to be 

handled in a manner that prevents needless injury and suffering.

 At approximately 2345 hours establishment 

was inform of the incident and the discussion I had 

with and 

I reminded that the PPIA and 

Agency Regulations do require that live poultry be handles in a 

(b) (6)

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

(b) (6)

manner that is consistent with Poultry Good Commercial 

Practices, and that they not die from other causes other than 

slaughter. Please 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. 

(b) (6)

was informed that this MOI will be 

forwarded to the District Office and the District Veterinary 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 13 

EstNbr EstName Task_Code MOI# 

M6137 Foster Farms 04C05 BXL271607 

4607G 

Date 

07JUL2018 

Description 

Medical Specialist (DVMS) in case additional follow-up is 

recommended. Respectfully, 

This MOI is intended to document the discussion I had with day 

shift live hang 

(b) (6)

about the Poultry Good 

Commercial Practices incident that occurred on the Saturday, 

July 7th, 2018. At approximately 1100 hours while performing 

an ante mortem inspection of the trailers outside in Plant 2, I 

observed two trailers full of chickens parked in direct sunlight in 

the parking lot outside of the normal holding area. The trailers 

are normally stored in a covered holding area, but this area had 

(b) (6)

become full. The establishment states in part in their Animal 

Welfare Program in Standard P8 that " 

". Standard P9 states that " 

". Lastly, Standard P10 

states in part 

. The birds in the trailers 

(b) (4)

(b) (4)

(b) (4)

outside the holding area were panting heavily, were very vocal 

and restless, and I observed dead birds in multiple cages. There 

was a higher number of dead birds in the cages that were in 

direct sunlight. These birds had no shade, additional ventilation, 

and were not in a thermally controlled holding area. I notified 

(b) (6)

of my findings and reminded him that 

the PPIA and Agency Regulations do require that live poultry are 

to be handled in a manner that prevents needless injury and 

suffering and in a manner that is consistent with good 

commercial practices. He informed me the trailers were placed 

their temporarily and that they would be moved to the holding 

area when space became available. This occurred and the 

trailers were moved at 1115 hours. I recommended that the 

establishment 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 

(b) (6)

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, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 14 

EstNbr EstName 

M667 Mountaire 

Farms Inc. 

M667 Mountaire 

Farms Inc. 

Task_Code 

04C05 

04C05 

MOI# 

KYN28080 

73112G 

KYN35120 

83924G 

Date 

12JUL2018 

24AUG2018 

Description 

While touring the cooling shed at Mountaire Farms in Selbyville, 

DE, I observed a flattened and dead carcass in the 11th bay of 

the cooling shed.  The bird was located about two-thirds of the 

way back from the front of the compartment that houses 

loaded trailers of live birds and was directly in the path of the 

right axle of the trailer.  Upon noticing the carcass, I summoned 

a member of plant management to the area and 

arrived.  I walked with

(b) (6)

him to the bay where the carcass was located and we witness 

the 

GCP Memorandum of Interview (MOI) Time:1311 Dumper 2 

(for Evis lines 3&4) While performing a Good Commercial 

Practice task I observed one bird loose on platform where cages 

are dumped. Dumper operator moved the next cage into 

position, hitting and driving the bird in front of it, injuring the 

bird but not killing it. The bird was white, clearly visable and 

well within the line of sight of the dumper operator. While 

looking at the injured bird, I observed two additional birds that 

were in the corner of the platform where the first bird had been 

pushed. There is a small space between where the cages stop 

and the fence that protects the dumper operator. This space 

was what kept the birds from being totally crushed. There were 

at least 4 dead birds under this same dumper but I did not 

observe how they died. I alerted 

(b) (6)

and Plant Manager,Mr. 

Daniel Riveria and showed them where this incident had 

occurred. The dead birds underneath the dumper had been 

removed except one and the three birds on the platform where 

gone as well. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 15 

EstNbr EstName Task_Code MOI# 

M7089 Tyson Foods Inc 04C05 FHB160107 

2910G 

Date 

10JUL2018 

Description 

At approximately 2140 hours, while performing a Good 

Commercial Poultry (GCP) task in the receiving area, I observed 

overcrowded chickens on the wide belt (the belt after the 

dumper) while the establishment had stopped hanging on the 

kill line due to an accident which had occurred on the further 

processing side. I did not observe any establishment supervisors 

or employees in the area of the wide belt. Most employees 

appeared to be taking a break. While standing on the catwalk 

above the wide belt, I observed approximately 3 layers of live 

chickens. I observed movement under the layers and only the 

rear ends of some chickens as the temperature outside was 

approximately 80 degrees at that time. I notified an employee 

on the yard that I needed a supervisor 

(b) (6)

, came and observed the conditions. I stated the 

establishment needed to take action to prevent the chickens 

from suffocating. He then called 

(b) (6)

. The action taken was to remove the door to the side 

of the belt and try to remove chickens with hooks and place 

them into a nearby cage. The establishment felt this was taking 

too long and elected to remove the chickens from the full 

carousel inside, place them into the cage and then started the 

wide belt to move the chickens inside. At that time the 

establishment called for production to begin hanging chickens 

on the kill line. The chickens quickly entered the building. At 

2200 hours, the chickens from the belt were inside the building. 

The dead chickens were placed into three piles on the floor. 

Approximately 50 chickens died by suffocation due to 

overcrowding and from the establishment not employing good 

commercial practices. 

(b) (6)

and Mr. Griffin were both 

notified that a GCP MOI would be documented. At 2230 hours, 

Mr. Reginald Griffin, GPM, came into 

(b) (6)

office where 

I was also present and we began discussing the chickens that 

died by suffocation. 

(b) (6)

met with Mr. Griffin again at 

2250 hours and reminded him that the PPIA and Agency 

regulations require that live poultry be handled in a manner that 

is consistent with good commercial practices and that they not 

die from causes other than slaughter. It is a prohibited act to 

slaughter poultry in any way that is not in compliance with the 

PPIA (21 U.S.C. 458(a)(1)). If birds hung on the kill line expire 

prior to slaughter due to mishandling, or die in a manner that 

does not comply with good commercial practices, the resultant 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 16 

EstNbr EstName Task_Code MOI# Date Description 

product is adulterated under the PPIA. 

(b) (6)

presented 

Mr. Griffin a copy of the Federal Register Notice Vol. 70, No.187, 

published September 2005 [Docket No. 04-037N] for review of 

FSIS’ recommendations concerning treatment of live poultry 

before slaughter. Mr. Griffin was notified that a copy of this MOI 

would be forwarded to the District Office and the District 

Veterinary Medical Specialist (DVMS) in case additional 

follow-up is recommended. Respectfully, 

P7089, Tyson Foods. 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 17 

EstNbr EstName 

M737 House of 

Raeford -

Wallace Div 

Task_Code 

04C05 

MOI# 

DHA08080 

91405G 

Date 

05SEP2018 

Description 

removed approximately 8 birds during that time.  She 

notified maintenance who determined that the water in the 

stunner needed more salt in the water to increase the 

effectiveness of the stunner and a extra person was put in place 

to cut the missed birds. 

(b) (6)

was notified of the 

establishments failure to comply with 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".  If you have any questions please review 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 

that slaughter are considered adulterated and must be 

condemned.  Mr. Johnson this MOI will be forwarded to the 

District Office and the District Veterinary Medical Specialist in 

case additional follow-up is recommended.  If you have any 

questions or concerns regarding the above, please feel free to 

, who removed the live bird 

from the line and took it back to live hang to be rehung.  My 

findings were confirmed by 

(b) (6)

that the bird had not 

been cut after it had been removed from the line.  After the line 

had been restarted I observed a 15 minute period and 

(b) 

(6)

Mr. Cowan Johnson, Plant Manager, P-737 House of Raeford 

Teachey, NC 28464 Mr. Johnson This MOI is being issued to 

document the observation of a live bird entering the scalder on 

9/5/18.  At approximately 0534 while  performing Good 

Commercial Practice task, I observed a live bird entering the 

scalder.  The bird at the time of my observation the bird had 

normal rhythmic breathing, controlled head movement and 

eyes blinking.  After further observations there was no evidence 

showing that the bird's neck had been cut after going through 

the stunner.  I immediately stopped the line when the bird 

mentioned had reached the e-stop button which is located at 

the entrance of the scalder.  I immediately notified 

(b) (6)

contact , or 

.  Respectfully, P737 

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 18 

EstNbr EstName 

M7470 Mountaire 

Farms Inc. - NC 

Division 

Task_Code 

04C05 

MOI# 

YRA161505 

4830G 

Date 

30MAY2018 

Description 

This memorandum of interview (MOI) is being issued to 

document what was observed and subsequently discussed with 

establishment management on May 30, 2018.  At 

approximately 1545 hours, an inspector on Line 3, Station 3 

rang his bell to alert USDA that he had hung back a cadaver. 

The carcass had a dark red, swollen head with no observable cut 

to the neck.  The neck and upper breast were also dark red in 

coloration; the viscera had dilated blood vessels on the 

intestines and a swollen liver, all engorged with blood.  These 

lesions are all consistent with a bird that died by means other 

than slaughter.  Upon further discussion with the inspector on 

Line 3, Station 3, he informed me that he had condemned two 

other cadavers with heads still attached and no neck cut within 

about 10 minutes of each other, but his condemn barrel had 

already been emptied.  The cadaver that I did observe was 

notably smaller in size than the rest of the flock; the inspector 

confirmed the other two cadavers he condemned were of a 

similar small size.  I proceeded to the kill area to verify 

regulatory requirements. As I approached the back-up killer on 

Line 3, I noticed he was slightly swaying his head from side to 

side and not looking forward at the kill line.  When the back-up 

killer noticed my presence, he sat up and faced forward to look 

at the birds.  I discussed my observations of the back-up killer 

and showed the cadaver to 

.  I informed him that a MOI would be

(b) (6)

issued to document the incident. 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.  A copy of this MOI will be 

forwarded to the District Veterinary Medical Specialist (DVMS) 

in the event additional follow-up is recommended. I certify this 

MOI contains a summary of all pertinent matters discussed. 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 19 

EstNbr EstName Task_Code MOI# Date Description 

M7470 Mountaire 04C05 YRA121307 31JUL2018 

Farms Inc. - NC 0631G 

Division 

At approximately 12:34 PM, Inspector and 

appeared at my office 

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

with a carcass for me to examine. The bird was taken out of 

production by Inspector 

(b) (6)

, located on Line 3 

Station 3. The carcass was that of a well fleshed, medium sized 

bird. The skin was hyperemic, leading to a pronounced bright 

cherry red color. The head was edematous and markedly 

hyperemic, having a swollen and reddish-purple appearance. 

When the neck was examined, there was no indication of an 

incision necessary to sever the vessels and cause the bird to 

bleed out. These signs are consistent with a bird having died by 

means other than by slaughter. The carcass was condemned as 

a cadaver and I informed 

(b) (6)

that an MOI would be 

issued. The PPIA and Agency regulations require that live 

poultry be handled in a manner that is consistent with good 

commercial practices and that they not die for causes other 

than by slaughter. The Federal Register on Treatment of Live 

Poultry before Slaughter gives recommendations on how to 

prevent these occurrences. A copy of this MOI has been 

forwarded to the District Veterinary Medical Specialist (DVMS) 

in the event further action is recommended. I certify that this 

MOI includes all pertinent matters discussed concerning this 

incident and is true to the best of my knowledge. 

(b) (6)
                           

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 20 

EstNbr EstName Task_Code MOI# Date Description 

M751 Pitman Farms 04C05 MMK1218 25MAY2018 Memorandum of Interview to Discuss Birds Held Over for 

Inc. (Moroni 053525G Slaughter Norbest Turkey / Est# P01049 Meeting Time: Friday, 

Turkey 

Processing) 

May 25, 2018 at 1230 Attendees: 

USDA  Establishment 

This meeting was necessitated by observations made 

(b (b) (6)

while performing a Good Commercial Practices task each day 

during the week of May 21, 2018. The establishment protocol 

concerning live birds held over is documented in both their 

Animal Welfare Program and also SOP #307 Live Bird Holdover. 

The written procedure pertains to an unscheduled live bird 

holdover due to a deviation such as a breakdown or shutdown 

over from Wednesday morning to Thursday afternoon, a period 

and 

Wednesday Holdover (approx. 

400 toms) A partial trailer load of toms (trucks #98) was held 

(b) (4)

of time that exceeded 24 hours.  According to , the 

deviation in production causing the holdover was 

”  The QA release of evisceration for 

preoperational inspection was delayed approx. 1 hour 

(b) (4)

(b) (6)

Wednesday morning due to sanitation deficiencies.  The start of 

operations in evisceration was further delayed on Wednesday 

morning due to deficiencies found during the USDA 

preoperational inspection.  Line speed reductions were due to 

the poor condition of the toms (airsacculitis, breast blisters and 

fecal contamination). As documented in previous MOI, issues 

outside of mechanical breakdowns (a trend of lower line speeds 

due to quality of birds, zero tolerance failures, preoperational 

deficiencies, FPS failures, etc) may be historical and anticipated 

when planning production. As was discussed previously, it is 

not a good practice nor is it in the establishment’s interest to 

hold birds overnight.  A previous complaint was filed with the 

district office by an observer that concerned holdover birds. 

aspects of a particular poultry operation for a prudent 

establishment to consider when planning production. 

did not know if historical data concerning the 

condition of the birds from a particular producer is considered 

(b

) 

(6)

(b) 

(6)

understood, therefore, that FSIS will continue to issue MOI 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 21 

EstNbr EstName Task_Code MOI# Date Description 

for this matter. This memorandum serves to document what 

was discussed and also provide the Denver district office with 

information concerning the operations being conducted at this 

establishment.  A copy of this memorandum of interview was 

provided to establishment management, and the signed original 

will be placed in the USDA files. 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 22 

EstNbr EstName Task_Code MOI# Date Description 

M751 Pitman Farms 04C05 MMK3114 19JUL2018 Memorandum of Interview to Discuss Birds Held Over for 

Inc. (Moroni 073119G Slaughter Norbest Turkey / Est# P01049 Meeting Time: 

Turkey 

Processing) 

Thursday, July 19, 2018 at 1320 Attendees: 

USDA  Establishment 

This meeting was necessitated by observations made 

(b (b) (6)

while performing a Good Commercial Practices task each day 

during the week of July 16, 2018. The establishment protocol 

concerning live birds held over is documented in both their 

Animal Welfare Program and also SOP #307 Live Bird Holdover. 

The written procedure pertains to an unscheduled live bird 

holdover due to a deviation such as a breakdown or shutdown 

and “is in conjunction with applicable best industry practices, 

notably National Turkey Federation (NTF) “Animal Care Best 

Management Practices, 2012.”  Wednesday Holdover (approx. 

750 toms) A partial trailer load of toms (truck #72) was held 

over from Wednesday morning to Thursday morning.  According 

to Mr Freeman, the deviation in production causing the 

holdover was 

.”  Line speed reductions were due 

(b) (4)

to the poor condition of the toms (airsacculitis) and related 

failures of FPS checks. As documented in previous MOI, issues 

outside of mechanical breakdowns (a trend of lower line speeds 

due to quality of birds, zero tolerance failures, preoperational 

deficiencies, FPS failures, etc) may be historical and anticipated 

aspects of a particular poultry operation for a prudent 

establishment to consider when planning production. As was 

discussed previously, it is not a good practice nor is it in the 

establishment’s interest to hold birds overnight.  A previous 

complaint was filed with the district office by an observer that 

concerned holdover birds. 

(b) 

(6)

understood, therefore, that FSIS 

will continue to issue MOI for this matter. This memorandum 

serves to document what was discussed and also provide the 

Denver district office with information concerning the 

operations being conducted at this establishment.  A copy of 

this memorandum of interview was provided to establishment 

management, and the signed original will be placed in the USDA 

files. 

(b) (6)
                           

                                       .....,. 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 23 

EstNbr EstName Task_Code MOI# Date Description 

M751 Pitman Farms 04C05 MMK3414 24AUG2018 Memorandum of Interview to Discuss Birds Held Over for 

Inc. (Moroni 085324G Slaughter Norbest Turkey / Est# P01049 Meeting Time: 

Turkey 

Processing) 

Friday, August 24, 2018 at 1320 Attendees: 

USDA  Establishment 

This meeting was necessitated by 

(b (b) (6) (b) 

(6) (b) (6)

observations made while performing a Good Commercial 

Practices task each day during the week of August 20, 2018. 

The establishment protocol concerning live birds held over is 

documented in both their Animal Welfare Program and also 

SOP #307 Live Bird Holdover.  The written procedure pertains to 

an unscheduled live bird holdover due to a deviation such as a 

breakdown or shutdown and “is in conjunction with applicable 

best industry practices, notably National Turkey Federation 

(NTF) “Animal Care Best Management Practices, 2012.” 

Monday Holdover (approx. 10,000 hens) Five trailer loads of 

hens were held over from Sunday night / Monday morning to 

Tuesday morning.  According to 

(b) (6)

, the deviation in 

production causing the holdover was “due to the unscheduled 

late start due to sanitation contractor performance today.” 

Sanitation had not been able to clean first or second processing 

since late last week due to problems associated with the water 

treatment facility. Tuesday Holdover (approx. 1,000 toms) A 

full trailer load of toms (truck #82) was held over from Monday 

morning to Tuesday afternoon.  According to , the 

deviation in production causing the holdover was 

” As documented in previous MOI, issues outside of 

(b) 

(4)

(b) (6)

mechanical breakdowns (a trend of lower line speeds due to 

quality of birds, zero tolerance failures, preoperational 

deficiencies, FPS failures, etc) may be historical and anticipated 

aspects of a particular poultry operation for a prudent 

establishment to consider when planning production. As was 

discussed previously, it is not a good practice nor is it in the 

establishment’s interest to hold birds overnight.  A previous 

complaint was filed with the district office by an observer that 

concerned holdover birds. 

(b) 

(6)

understood, therefore, that FSIS 

will continue to issue MOI for this matter. This memorandum 

serves to document what was discussed and also provide the 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 24 

EstNbr EstName Task_Code MOI# Date Description 

Denver district office with information concerning the 

operations being conducted at this establishment.  A copy of 

this memorandum of interview was provided to establishment 

files. 

management, and the signed original will be placed in the USDA 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 25 

EstNbr EstName 

M7559 David Elliot 

Poultry Farm 

Inc. 

Task_Code 

04C05 

MOI# 

SNA59100 

53830G 

Date 

30MAY2018 

Description 

At approximately 10:45am while performing a Good 

Commercial Practices verification task in the live-haul/receiving 

area of slaughter room at Est. P-134, there were several stacked 

crates on the loading dock that were unloaded from the truck 

parked inside the building that contained many chickens that 

were heavily panting/open-mouth breathing. These crates on 

the loading dock were some of the last ones unloaded from the 

truck parked inside. There were also several (6-8 crates) stacked 

in the far corner of the slaughter room adjacent to the crate 

washer with several dead birds (4-7 carcasses) in each crate, and 

almost 2 full red inedible barrels with dead birds/DOAs removed 

during crate unloading (birds that did not have their necks 

cut/were slaughtered). At approximately the same time, I 

examined the full truck, that had yet to be unloaded,  parked on 

the outside of the building and in front of several fans, and did 

not observe any birds panting/open-mouth breathing or any 

significant DOAs that could be observed from walking both sides 

of the outside of the truck. I notified 

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

, as well as

(b) (6)

 and - that the some of the 

birds in the slaughter room/loading dock area were showing 

signs of heat distress/ heavily panting and there was also a 

significant accumulation of DOAs to go along with this 

observation.  Both 

(b) (6)

came to 

the slaughter area to observe the birds in question and the 

current accumulation of DOAs. According to the slaughter 

floor manager, he believed that all of the chickens- the ones that 

were panting on the loading dock and the ones from the crates 

that were DOA- all came from the same area/part of the truck. 

I spoke with 

(b) (6)

regarding the air flow coming from 

the fans on the wall that face the truck parked inside- the truck 

the panting chickens were unloaded from. Comparatively, and 

subjectively, the air-flow from the fans on the outside seems 

significantly higher than the air-flow from fans on the inside wall 

of the dock area.  One fan, the second fan from the loading dock 

was also not operating at all. According to 

(b) (6)

, the 

truck on the outside was loaded at 12 birds per crate, while the 

truck parked on the inside was loaded at 10 birds per crate. The 

truck parked on the outside is also parked in direct sunlight on a 

day where the forecasted high temperature was to be a high of 

88oF.  However, the birds inside the building, in the shade (not 

in direct sunlight), packed in crates less densely (10 vs. 12 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 26 

EstNbr EstName Task_Code MOI# Date Description 

that part of the issue may be attributable to the air flow 

from the inside fans (in addition to the high outside 

temperatures). According to 

(b) (6)

, the establishment 

currently has a device on order to further investigate the air flow 

generated by the fans, to obtain more objective data about the 

air-flow produced. He is also looking into the status of the 

non-operational fan- to see if it not working is a matter of a part 

that needs to be ordered or some other reason. Until the fan on 

the wall is operational, he mentioned planning to unload the 

chickens from that particular section of the truck (when parked 

inside) first. At the end of the slaughter day there were 176 

DOAs out of 12,008 birds slaughtered (1.47%). (Most of these 

coming from the first truck that was unloaded inside) 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). The increase in DOAs 

on this day was likely due to the effects of heat, further 

exacerbated by the non-functioning fan. IPP will continue to 

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. Addendum: On May 30, 

2018, while in the receiving/loading dock area of the slaughter 

room where the truck of birds currently being unloaded is 

located, there were 3 additional fans on the wall (from 

yesterday), in addition to the 5 built-in fans in the wall. 

birds/crate) and also with similar distribution of several fans 

blowing toward the truck are showing more signs of heat 

distress. At approximately 12:45pm, after the second truck 

that was originally parked outside, was brought inside the 

building (to the same location as the first/previous truck), I 

again observed many birds heavily panting/open-mouth 

breathing. The birds most severely and consistently affected 

were located directly in front of the non-functioning fan. 

According to 

(b) (6)

, this is the same area of the truck 

that the birds were unloaded from the first truck that were 

panting/open-mouth breathing and had the higher 

concentration of DOAs. I expressed my concern to 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 27 

EstNbr EstName 

M9230 Dayton Natural 

Meats, LLC 

M9977 Tyson Foods Inc. 

Task_Code 

04C05 

04C05 

MOI# 

KDD55120 

75113G 

YBL000707 

4430G 

Date 

13JUL2018 

30JUL2018 

Description 

Additionally, the non-operational fan from yesterday is now 

working. According to 

(b) (6)

, the fan needed a belt 

replaced and the fan is now functional. 

At approximately 0750 hours, during Friday's, July 13 poultry 

slaughter operations at Establishment 9230, 

Dayton Natural Meats, line inspector 

observed one cadaver carcass with it's head intact after scalding 

and evisceration.  The bird carcass was a deep red color and 

slightly bloated.  The bird was removed from the line and set 

aside for management to see.  Slaughter floor supervisor 

Herman Mendoza was contacted and informed of the incident. 

He went to discuss the incident with the employee cutting off 

heads and stressed the importance of addressing each head on 

every bird prior to scalding.  No other instance of this nature 

was observed at the time of this writing.  This issue will be 

considered an isolated event and the establishments process 

controls are recognized as compliant and " 

(b) (4)

". 

(b) (6)

On 7/30/2018 at approximately 0700 hours I was performing a 

routine poultry Good Commercial Practice (GCP) verification 

task in the live hang room of establishment P1325, Tyson Foods, 

Inc.  I observed one live chicken in the bottom of the 

establishment’s designated Dead on Arrival (DOA) cart that 

contained approximately five DOA chickens.  Despite some DOA 

chickens lying on top of it, the live bird appeared strong as it 

was sitting upright in good body condition with its eyes open 

removed the live bird from the cart and, upon finding 

it to be strong and alive, hung it on the line for slaughter.  I 

reminded both supervisors that Agency regulations require live 

poultry to be handled in a manner that is consistent with good 

commercial practices and that they not die from causes other 

than slaughter.  I also explained to them that live chickens in the 

DOA cart can die from suffocation, which is then considered 

and breathing normally. I immediately showed

 my findings. 

(b) (6)

(b) (6)

adulterated product. Respectfully, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 28 

EstNbr EstName Task_Code MOI# 

M9977 Tyson Foods Inc. 04C05 YBL541108 

4417G 

Date 

17AUG2018 

Description 

the chicken and notified him of my 

findings.  The establishment employee euthanized the chicken 

in my presence.  A live chicken in the DOA cart was recently 

observed, as documented in GCP MOI YBL0007074430G on 

7/30/2018.  The establishment was reminded that Agency 

regulations require live poultry to be handled in a manner that 

is consistent with good commercial practices and that they not 

die from causes other than slaughter.  I also explained to them 

that live chickens in the DOA cart can die from suffocation, 

which is then considered adulterated product. Respectfully, 

On 8/17/2018 at approximately 0813 hours I was performing a 

routine poultry Good Commercial Practice (GCP) verification 

task in the live hang room of establishment P1325, Tyson Foods, 

Inc.  I observed one live, weak young chicken in the 

establishment’s designated dead-on-arrival (DOA) cart that 

contained approximately ten DOA chickens.  I immediately 

showed the nearest establishment employee, who removed the 

live chicken from the cart and placed it on the establishment’s 

designated holding table.  I requested establishment 

management and, upon arrival, I showed 

(b) (6)

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 29 

EstNbr EstName Task_Code MOI# 

M9977 Tyson Foods Inc. 04C05 YBL060609 

3621G 

Date 

21SEP2018 

Description 

two cadavers I had found in a red barrel that 

the establishment uses to dispose of carcasses.  Both were a 

deep red color throughout the body with the necks completely 

uncut and the heads still attached and engorged with blood. 

the cadaver and continued with my 

GCP verification task.  Approximately 1-2 minutes later while 

observing chickens at the pre-scald area, I observed one chicken 

still breathing when entering the scalder.  The chicken’s head 

was completely attached and there was no bleeding cut on the 

neck.  I immediately notified 

(b) (6)

and went to the sort 

1/rehang area to confirm my findings.  At approximately 0540 

hours I showed 

(b) (6)

On 9/21/2018 at approximately 0535 hours I was performing a 

routine Poultry Good Commercial Practices (GCP) verification 

task in the live hang room of establishment P1325, Tyson Foods, 

Inc.  I observed one cadaver in the establishment’s designated 

Dead on Arrival (DOA) cart.  The 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 back-up 

kill person failed to manually cut the neck to permit the 

required bleed out.  I immediately showed 

(b) (6)

(b) (6)

immediately went to the Receive/Kill/Process (RKP) 

area while I continued to observe carcasses coming into the 

evisceration department.  At approximately 0541 hours I 

observed another cadaver on the line #4 rehang belt.  This 

cadaver had the head removed but was uniformly red in color 

indicating it had not been bled out.  I immediately brought the 

cadaver to the RKP area and showed 

(b) (6)

.  He informed 

me that the regular back-up kill person was not at work today 

and the establishment had been using a replacement employee 

for the back-up kill. 

(b) (6)

also informed me that he had 

since removed the replacement and put a more experienced 

employee in place in response to my findings.  The regulations 

(9 CFR 381.65(b)) require that poultry be slaughtered in 

accordance with GCP.  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. 

Respectfully, 

(b) (6)

Update:  Written 

response from the establishment is attached. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 30 

EstNbr EstName 

P1209 Whitewater 

Processing Co. 

Task_Code 

04C05 

MOI# 

FFG400805 

5730G 

Date 

30MAY2018 

Description 

Est. P1209 Whitewater Processing Co. At 0900 hours while 

observing birds entering the scald tank as part of a routine GCP 

task

(b) (6)

 observed the following. An old breeder turkey 

(hen) was observed to be breathing and raising it's head on the 

production line just before the scald tank. 

(b) (6)

stopped 

the line and  alerted Plant personnel of the finding, They then 

left to retrieve a knife. An establishment employee, who re-cut 

the hen's neck and then removed the bird from the production 

line and carried her away. The line was then restarted. 

went immediately to the office and discussed the finding 

with both 

(b) (6) . 

(b) (6)

P1209 Whitewater 04C05 FFG050806 07JUN2018 Est. P1209 Whitewater Processing Co. At 0854 hours while 

Processing Co. 2107G observing birds entering the scald tank as part of a routine GCP 

task, 

(b) (6)

observed the following. An old breeder turkey 

(hen) was observed to be breathing and raising it's head on the 

production line just before the scald tank. 

(b) (6)

stopped 

the line and alerted Plant personnel of the finding, They 

removed the bird from the line. An establishment employee, 

who re-cut the hen's neck.. The line was then restarted. 

went immediately to the office and discussed the finding 

with  . 

(b) (6)

(b) (6)

P1209 Whitewater 04C05 FFG210807 25JUL2018 Est. P1209 Whitewater Processing Co. At 0901 hours while 

Processing Co. 1025G observing birds entering the scald tank as part of a routine GCP 

task, 

(b) (6)

observed the following. An old breeder turkey 

(hen) was observed to be breathing and raising it's head on the 

production line just before the scald tank. 

(b) (6)

stopped 

the line and alerted Plant personnel of the finding, Plant 

personnel removed the bird from the line. An establishment 

. Who stated he would 

take immediate corrective measures. 

employee, rehung the bird prior to the stunner. The line was 

then restarted. went immediately to the office and 

discussed the finding with 

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

-

--

-

-

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 31 

EstNbr EstName 

P1209 Whitewater 

Processing Co. 

P1209 Whitewater 

Processing Co. 

P1243 Perdue Foods, 

LLC. 

Task_Code 

04C05 

04C05 

04C05 

MOI# 

FFG051308 

0821G 

FFG380809 

0126G 

XLB130306 

5519G 

Date 

21AUG2018 

26SEP2018 

19JUN2018 

Description 

Est. P1209 Whitewater Processing Co. At 1352 hours while 

observing birds entering the scald tank as part of a routine GCP 

task, 

(b) (6)

observed the following. An old breeder turkey 

(hen) was observed to be breathing and raising it's head on the 

production line just before the scald tank. 

(b) (6)

stopped 

the line and alerted Plant personnel of the finding, Plant 

personnel removed the bird from the line. An establishment 

employee, rehung the bird prior to the stunner. The line was 

then restarted. 

(b) (6)

went immediately to the office and 

discussed the 

and 

(b) (6)

finding with 

(b) (6)

also present was 

. Who stated he would take immediate 

corrective measures which included reviewing findings with 

plant personnel. 

(b) (b) 

(6) (6)

Est. P1209 Whitewater Processing Co. At 0905 hours while 

observing birds entering the scald tank as part of a routine GCP 

task, 

(b) (6)

observed the following. A young turkey (hen) 

was observed to be breathing and raising it's head on the 

production line just before the scald tank. 

(b) (6)

stopped 

the line and alerted Plant personnel of the finding, Plant 

personnel removed the bird from the line. An establishment 

employee, rehung the bird prior to the stunner. The line was 

then restarted. 

(b) (6)

went immediately to the office and 

discussed the finding with 

(b) (6)

.. Who stated he would 

take immediate corrective measures which included reviewing 

findings with plant personnel. 

At 0405 hours, while performing Good Commercial Practices 

Task, I observed an establishment employee place a bird in the 

DOA bin and then scoop feathers into the bin.  I walked over to 

examine the contents of the DOA bin and observed a live bird 

under a pile of feathers.  The bird had rhythmic breathing and 

was blinking its eyes. There were two other birds in the bin 

which were dead.  There was no denaturant applied to anything 

at this time.  I notified 

(b) (6)

who retrieved the bird 

and agreed that it was alive.  I also informed 

(b) (6)

of 

the finding.  While the bird was not buried under others at the 

time of my observations, additional birds could have been 

placed upon it leading to suffocation, resulting in death by 

means other than slaughter. 
• 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 32 

EstNbr EstName 

P1272 Pilgrim's Pride 

Corporation 

Task_Code 

04C05 

MOI# 

CCA091205 

5231G 

Date 

31MAY2018 

Description 

Allen Shoemak, Plant Manager Pilgrim's Pride Corporation 

P-1272 113 McNeal Drive Douglas, GA 31533 On Friday, May 

25, 2018 at approximately 0824 hours while performing a Good 

Commercial Practices Task at P-1272 I, 

(b) (6) , 

observed an issue with the implementation of Good Commercial 

Practices in the pre-evisceration area. During a period of 

downtime in the pre-evisceration area on picking line number 

one, I observed the birds hanging inside of the stunner as being 

deceased. I immediately notified 

(b) (6)

of 

my concern of the birds within the stunner being deceased and 

my concerns as to why or how this could have occurred. There 

were approximately fifteen birds deceased within the stunner at 

that time. , 

, and 

were all notified shortly thereafter. This 

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

presents as a concern because even though when observed all 

water was emptied from the stunner equipment, all birds were 

still deceased. Observations were not made upon initial 

stopping of the pre-evisceration line, but there is a strong 

concern that when line stoppage occurs, birds are not being 

handled properly to prevent birds from dying prior to slaughter 

during the process. This occurrence follows a similar 

occurrence documented on April 16, 2018 in a Memorandum of 

on the production floor shortly after the occurrence. 

stated the concern would be looked into further. The issue will 

be discussed again in the scheduled USDA weekly meeting on 

Thursday, May 31, 2018 at 1315 hours. All comments will be 

documented in the weekly meeting MOI. Respectfully, 

Interview. This issue was discussed briefly with 

and 

(b) (6)

(b) (6)

(b) (6) (b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 33 

EstNbr EstName 

P1272 Pilgrim's Pride 

Corporation 

Task_Code 

04C05 

MOI# 

CCA210806 

2019G 

Date 

19JUN2018 

Description 

was notified shortly thereafter and observed 

this good commercial practice concern. Twenty three deceased 

birds were removed from the picking line. This presents as a 

strong concern of implementation of proper good commercial 

practices. Allowing birds to die before the kill step in the process 

presents a major concern for animal welfare and handling. 

This occurrence follows two similar occurrences documented on 

April 16, 2018 and May 25, 2018, both in Memorandum of 

Interviews. This issue was discussed with management at a 

small meeting in the USDA veterinarian’s office shortly after the 

of my concern of the birds within 

the stunner being deceased and my concerns as to why or how 

this could have occurred. 

(b) (6)

, observed an issue with the implementation of Good 

Commercial Practices in the pre-evisceration area. During a 

period of downtime in the pre-evisceration area on picking line 

number two, I identified the birds hanging inside of the stunner 

as being deceased. I immediately notified 

(b) (6)

Allen Shoemak, Plant Manager Pilgrim's Pride Corporation 

P-1272 113 McNeal Drive Douglas, GA 31533 On Saturday, 

June 9, 2018 at approximately 1210 hours while performing a 

Good Commercial Practices Task at P-1272 I, 

(b) (6)

occurrence. Relief , 

, Plant Manager, Todd Shoemak 

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

and myself were present. Mr. Shoemak stated that he agrees 

this is an issue and will take measures immediately to prevent a 

reoccurrence by placing a person in management in this area 

when downtime occurs. He also stated he will contact his 

corporate offices to get any insight available on how to further 

prevent a reoccurrence as well. The issue will be discussed 

again in the scheduled USDA weekly meeting on Tuesday, June 

12, 2018 at 1315 hours. All further comments will be 

documented in the weekly meeting MOI. Respectfully, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 34 

EstNbr EstName 

P1272 Pilgrim's Pride 

Corporation 

Task_Code 

04C05 

MOI# 

CCA370507 

1610G 

Date 

10JUL2018 

Description 

Todd Shoemake, Plant Manager Pilgrim's Pride Corporation 

P-1272 113 McNeal Drive Douglas, GA 31533 On Wednesday, 

July 4, 2018 at approximately 1309 hours while performing a 

Good Commercial Practices Task at P-1272 I, 

observed an issue with the implementation of Good 

(b) (6)

Commercial Practices in the live receiving area on line two. I 

observed the cage dump operator throw two live birds from a 

cage to the live hang belt. At approximately 1312 hours, I also 

observed the cage dumper operator on line one throw one bird 

in the same manner. I immediately notified 

of my observations. 

was notified shortly thereafter. The 

throwing of live birds is a major concern. It can cause injuries to 

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

the birds internally and externally. No other live birds were 

observed being thrown in my presence. A short, brief meeting 

was held with 

(b) (6)

regarding this 

issue shortly after my observations. Mr. Dean stated that he 

would speak with both cage dump operators and the supervisor 

of the area. He also stated every employee on both day shift and 

night shift in the live receiving areas would receive refresher 

training on animal welfare. This issue will also be discussed with 

management at the next USDA weekly meeting on July 10, 

2018. Respectfully, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 35 

EstNbr EstName 

P1272 Pilgrim's Pride 

Corporation 

Task_Code 

04C05 

MOI# 

CCA541708 

0203G 

Date 

03AUG2018 

Description 

Est. P-01272,Pilgrim’s Pride, August 3, 2018, 13:40 hours. In

attendance: , 

, 

, 

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

On August 3, 

(b) (6)

(b) (6)

(b) (6)

2018 I, , was informed by 

that there was a cadaver bird on line 1 station 3 for me to look 

at. At 1340 hours I examined the bird and observed that the 

neck of the bird was not cut. The bird did not have viscera and 

was vibrant red. In conclusion this bird was uncut and alive 

when it entered into the scalder. 

and were notified 

of the findings and forthcoming MOI. I reminded and

 that the PPIA and Agency regulations require that 

live poultry be handled in a manner that is consistent with good 

(b) (6)

(b) (6)

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

commercial practices and that they not die from causes other 

than slaughter. I later notified 

District Veterinary Medical Specialist (DVMS) in case additional 

follow-up is recommended. Respectfully, 

Pilgrim’s Pride. 

(b

) 

(6)

P1272 Pilgrim's Pride 04C05 CCA410308 15AUG2018 Allen Shoemake, Plant Manager Pilgrim's Pride Corporation 

Corporation 3115G P-1272 113 McNeal Drive Douglas, GA 31533 On Friday, 

live bird lying at the bottom of the DOA bin among several other 

live birds were observed in the DOA bin. This issue was 

also be discussed again at the next weekly meeting on August 

14, 2018 at 1315 hours and the minutes will be documented in 

, 

that this MOI will be forwarded to the District Office and the 

(b) (6)

August 10, 2018 at approximately 1816 hours while performing 

a Good Commercial Practices Task at P-1272 I, 

, observed an issue with the implementation of Good 

Commercial Practices in the live receiving area. I observed one 

(b) (6)

deceased birds. I immediately hung USDA Hold 

Tag # B41208142 in the area of the DOA bin and notified 

and 

. 

was notified shortly thereafter. The bird was euthanized 

and placed back inside of the DOA bin by . No other 

(b) (6)

(b) (6)

(b) (b) (6)

discussed with shortly after 

the occurrence in the USDA Veterinarian’s office. The topic will 

(b) (6)

the corresponding MOI. Respectfully, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 36 

EstNbr EstName 

P1272 Pilgrim's Pride 

Corporation 

Task_Code 

04C05 

MOI# 

CCA260908 

2827G 

Date 

27AUG2018 

Description 

, 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 before entering the 

Todd Shoemake, Plant Manager Pilgrim's Pride Corporation 

P-1272 113 McNeal Drive Douglas, GA 31533 On Friday, 

August 24, 2018 at approximately 1147 hours while performing 

a Good Commercial Practices Task at P-1272 I, 

(b) (6)

first scald vat. I immediately notified 

and 

removed the cadaver from 

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

the picking line upon exit from the scald vats. The cadaver was 

observed with an engorged head intact with no cut visible to the 

neck. Ms. Smith stated she would place an additional 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 further discussed with management at the next USDA weekly 

meeting on August 28, 2018. Respectfully, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 37 

EstNbr EstName Task_Code MOI# Date Description 

P1272 Pilgrim's Pride 04C05 CCA011409 12SEP2018 

Corporation 4312G 

Est. P-01272, Pilgrim’s Pride, September 11, 2018, 1652 hours. 

In attendance: 

, 

On September 11, 2018 I, 

, observed inhumane handling of a live bird in 

the cage dump area. While performing my Good Commercial 

(b) (6)

(b

) 

(6)

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

Practice (GCP) verification I observed the cage dump operator 

for line two throw a live bird from the cage dump platform to 

the live hang belt that leads into the building. The cage dump 

operator was retrieving a bird from a cage on the platform that 

did not open to release the bird unto the live hang belt. He 

pulled the bird out of the cage on the left side of the platform 

and threw the bird, releasing it from his hands into the air above 

his head and 3-4 feet to his right unto the live hang belt. 

and

 were notified of the forthcoming MOI. When 

(b) (b) (6)

notified, Mr. Kenton Pascal immediately corrected the 

employee. stated that disciplinary actions 

bird. He also stated that the employee will be monitored for the 

handled in a manner that is consistent with good commercial 

practices. I also notified them, that this MOI will be forwarded 

to the District Office and the District Veterinary Medical 

will be taken with the employee that inhumanely handled the 

(b) (6)

duration of the shift. I reminded and 

that the PPIA and Agency regulations require that live poultry be 

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

Specialist (DVMS) in case additional follow-up is recommended. 

Respectfully, 

(b) (6)

Pilgrim’s Pride. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 38 

EstNbr EstName Task_Code MOI# Date Description 

P1284 Pilgrim's 04C05 GDA03140 23JUL2018 

74023G 

hours while observing conditions in the live hang area in the 

Est. P-1284, Pilgrim’s, July 23, 2018, 1430 hours.  In attendance: 

; ; 

. At approximately 1250 

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

poultry receiving department, I ) and 

observed a live chicken in the dead-on-arrival 

(DOA) barrel that contained approximately thirty DOA chickens. 

(b) (6)

(b) (6)

While observing the top layer of birds from the barrel, we 

observed a live bird evident due to its open eyes, breathing and 

ultimately movement when picked up by the leg. 

was notified of the finding and the bird was hung 

back into production.  and I went 

(b) (6)

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

through the remaining birds in the DOA barrel.  We met with

 and reminded him that 

handled in a manner that is consistent with good commercial 

practices (GCPs), and that they not die from causes other than 

slaughter.  Poultry are also to be handled in a manner that 

prevents needless injury and suffering in order to produce a 

commercially marketable product. Compliance with these 

requirements helps insure that poultry are treated humanely.  I 

recommended that 

(b) (6)

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 him a copy of this 

document. 

(b) (6)

stated he would investigate the cause 

and provide any planned action with a written response.  I 

notified 

(b) (6)

that this MOI will be forwarded to the 

District Office and the District Veterinary Medical Specialist 

Respectfully, 

the PPIA and Agency regulations do require that live poultry be 

(b) (6)

(DVMS) in case additional follow-up is recommended. 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 39 

EstNbr EstName Task_Code MOI# 

P1294 Holmes Foods 04C05 CKC310508 

Inc. 3627G 

Date 

27AUG2018 

Description 

On August 24, 2018 at approximately 12:30 p.m., while 

conducting a good commercial practice task; I walked over to 

the lot where birds were being held awaiting slaughter.  I 

observed two trucks with birds.  At the first truck, there was a 

row of fans facing the birds blowing air to keep them cool. 

However, the last two fans on that row were barely moving and 

it did not appear to be producing adequate air to keep the birds 

cool.  The birds in the column directly in front of those fans 

had very little movement, their feathers only slightly moved 

from the air received from the fans, and the birds were visibly 

panting.  As I proceeded to the next truck I observed the fifth fan 

from the front of the row was not working at all.  Since I am 

fairly new to the CSI position, I requested 

(in the absence of 

(b) (6)

) to investigate my observations, 

to verify the situation warranted corrective action.  At 

approximately 1:30p.m., 

(b) (6)

walked over to the lot and as 

he was approaching, he saw the first truck of chickens leave; but 

was able to see that the same two fans that were facing the 

truck were not working properly, and still barely moving.  He 

was also able to see that the fan not working on the other row 

was actually unplugged and the cord wrapped up.  He observed 

the chickens directly in front of that fan having obvious signs of 

distress with them panting heavily.  He immediately notified 1st

(b) (6)

 of the issue.  He later notified, 

and the 

.  assured him that the 

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

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

issue would be looked into over the weekend. It is important 

that the establishment understands that preventing the 

mistreatment of poultry decreases the chances of producing 

adulterated carcasses.  This document serves as written 

notification that failure to comply with regulatory requirements 

could result in additional regulatory or administrative action. 
 

        

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 40 

EstNbr EstName 

P1307 Mar-Jac 

Poultry-AL 

Task_Code 

04C05 

MOI# 

KIL460208 

2510G 

Date 

10AUG2018 

Description 

At approximately 2250 while performing an Ante-Mortem and 

an Animal Welfare verification check at line #1 cage dump, I 

observed the cage dump operator throwing four live chickens, 

two at a time, from their cage upwards to the top of the cage 

dump which was at least 5 feet away.  The chickens flailed their 

wings in distress as they skidded, approximately 2 feet, across 

the top of the cage dump which also caused distress to other 

chickens.  I notified 

(b) (6)

of my observations. 

immediately addressed the situation with the cage dump 

operator. Federal Register Notice Docket No. 04-037 dated 

September 28, 2005, “Treatment of Live Poultry Before 

Slaughter “, encourages those in the poultry slaughter industry 

to abide by Good Commercial Practices.  In order to ensure that 

poultry are handled and slaughter 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 the slaughter process.  My 

observations are not consistent with this guidance.  A copy of 

this Memorandum of Interview (MOI) will forwarded to 

appropriate personnel in the District Office. Respectfully 

submitted on August 10, 2018, 

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

Cc: 

Dr. Gregory Brookhouser, DDM 

(b) (6) (b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 41 

EstNbr EstName 

P1309 House of 

Raeford Farms 

Inc. 

Task_Code 

04C05 

MOI# 

JLA311207 

4427G 

Date 

27JUL2018 

Description 

At approximately 1011 hours, during the performance of a Good 

Commercial Practices verification task, I observed a bird 

handling issue.  I was outside on the sidewalk watching the 

forklift operator place live haul cages on the cage dump when I 

observed a mist coming off the top of the cages that were on 

the truck that was being unloaded.  Since this was unusual, I 

investigated further.  I noted that an establishment employee 

was standing on the opposite side of the truck with a hose, and 

he appeared to be spraying the eight loaded cages remaining on 

the truck.  To better observe the employee, I walked to the end 

of the sidewalk and saw the employee walk around the back of 

the live haul truck while continuing to spray the cages.  I noted 

that the employee was the live hang line leader, and he was 

using a hose that was spraying water under high pressure while 

standing only a few feet away from the back of the truck.  The 

water was spraying directly into the cages onto the live birds 

awaiting slaughter.  I immediately instructed the employee to 

stop spraying the birds and asked the purpose of what he was 

doing.  The employee indicated that the establishment manager 

had instructed him to spray the birds in the cages to “ 

” so that they would defecate prior to slaughter.  I 

requested to speak with establishment management, and 

responded.  I informed Ms. 

(b) 

(4)

(b) 

(6)

Andrews that use of a high pressure hose on live birds confined 

discontinued.  I then continued inside to the Evisceration 

in live haul cages for any reason was unacceptable. 

indicated her understanding, and the practice was 

(b) 

(6)

Department, where I spoke with 

about the incident.  I reiterated that handling live birds 

(b) (6)

in this manner was unacceptable.  The PPIA and Agency 

regulations require that live poultry be handled in a manner that 

is consistent with good commercial practices (GCPs) and that 

they not die from causes other than slaughter.  This MOI will 

Respectfully, P1309, House of Raeford 

Farms 

be forwarded to Greenville Circuit and to 

. 

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

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 42 

EstNbr EstName Task_Code MOI# 

P1315 Tyson Foods, 04C05 ZCB370905 

Inc. 2025G 

Date 

25MAY2018 

Description 

The subject of this MOI has been moved to Inspection Notes for 

documentation purposes. It has been appealed to 

verbally, and the appeal was granted. This MOI has not been 

removed/deleted due to PHIS program malfunction and has a 

Help Ticket for correction to the matter. 

(b) (6) (b) (6)
1111 - ■ 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 43 

EstNbr EstName Task_Code MOI# 

P1315 Tyson Foods, 04C05 ZCB061206 

Inc. 2606G 

Date 

06JUN2018 

Description 

While performing the antemortum section of GCP inspection 

this morning the 

(b) (6)

observed the following 

situation at the receiving area on June 6, 2018. At 10:15 AM 

one live chicken was visualized in the corner of the 

DOA/condemned tote covered in denaturant in dorsal 

recumbency positioning with its head and neck buried by litter 

breathing with a respiratory rate of 60 breaths per minute. 

There were approximately 6-8 other chicken carcasses buried by 

litter without denaturant applied that were positioned in a 

higher elevation of the tote due to the tote having one slanted 

side. 

was notified and immediately accompanied 

(b) (6)

(b) (6)

Dr. Blades to the area of receiving. The chickens neck and head 

was uncovered from the litter which it then promptly jumped 

up flapping its wings and vocalizing. The chicken was 

manual transcervical dislocation and transection. This is 

first incidence finding at P1315 of this nature to date.

(b) (6)

(b

) 

(6)

unquestionably vibrant. euthanized the chicken with 

This situation does not follow Good Commercial Practices. 

Establishment response (Billy Clark, Plant Manager, 

, 

) was given as follows. DOA birds would not 

be shoveled onto the dump belt  with litter from the live hang 

(b) (b) (6)

area. Bird carcasses would be manually placed on the dump belt 

to be transferred outside and denaturant applied as they fall off 

the belt into the DOA bin by hand mechanism as there is not an 

automated spray system. Litter will be shoveled onto the belt 

after any DOA birds have been denatured therefore no further 

carcasses should be buried in litter without the ability to apply 

denaturant. The DOA belt will no longer be a continuous moving 

belt. There will be an on/off switch utilized to prevent any live 

birds from jumping onto the belt and being transported outside 

without establishment employee knowledge. The belt will only 

be turned on periodically for DOA denaturing/transport outside 

the live hang room or clean up of litter pile from the end of the 

hanging belt. The gate that currently prevents birds from 

jumping down onto the DOA conveyor belt will continue to be 

monitored for correct use and maintenance. Live receiving 

employees have been counseled verbally as to correct 

notification and procedures when a live loose bird is found in 

the receiving areas. 
■ 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 44 

EstNbr EstName Task_Code MOI# 

P1315 Tyson Foods, 04C05 ZCB511908 

Inc. 3114G 

Date 

14AUG2018 

Description 

reported to the IIC that the DOA belt 

line leading outside to the DOA bin would no longer be utilized. 

The hole in the wall where this belt line is currently would be 

sealed with a piece of metal. DOAs and chicken litter would be 

placed into a yellow condemn barrel and transported outside 

the backdoor of the live hang room to be dumped into the DOA 

bin outside manually. 

that Lot 4 had not yet entered the 

Evisceration Department negating the task. Following this 

procedure the IIC donned reflective vest PPE and went outside 

to perform the antemortum portion of GCP inspection 

verification. At 6:25 PM a live chicken was visualized by the IIC 

in the DOA bin outside with faint amounts of denaturant on it. 

This chicken was vibrant in nature and ran around the outside 

edges of the DOA bin when approached for closer visual 

inspection. 

(b) (6)

was notified by establishment 

employee radio communication and arrived at 6:29 PM to 

dispatch the chicken by manual decapitation in the presence of 

the IIC. This MOI is being associated with MOI 

#ZCB4220073231G written on 07/31/2018 for similar causes. 

The establishments preventative measures or implementation 

have not kept live chickens from being treated as DOA birds. 

This does not follow Good Commercial Practices. 

(b) (6)

was notified of this finding 

at 6:15 PM as he entered the backdoor of the Live Hang Crew 

hallway. The IIC entered the USDA office via this same hallway, 

changed smocks and proceeded to the Evisceration line 2 for a 

requested Leukosis verification for Grower 27486 Lot 4. After 

performing the verification, the IIC was informed by 

(b) (6)

On 8/14/18 while performing GCP verification task, the IIC 

visualized the following within the live hang room. The 

protective flap; located on the eastern end of the DOA belt line 

next to the Line 1 North live hang personnel bottom step that 

transfers Dead on Arrival (DOAs) and chicken litter into the 

outside DOA bin, was detached on one side and folded inward 

onto the belt. This flap is to prevent live birds from falling or 

jumping onto the DOA belt and being transferred outside 

unknowingly by live hang attendants if vibrant chickens leave 

the live hang belt prior to being hung in the shackles. 

(b) 

(6)
                                                                          

1111 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 45 

EstNbr EstName Task_Code MOI# 

P1315 Tyson Foods, 04C05 ZCB262009 

Inc. 1205G 

Date 

05SEP2018 

Description 

At Tyson Foods, Inc., establishment 01315P, on 8/30/2018, at 

approximately 2230 hours, while conducting ante-mortem and 

Good Commercial Practices inspection, 2nd shift 

observed two live young chickens in the DOA bin. It was 

(b) (6)

also observed there was no appreciation of denaturant present 

amongst the group of birds in the bin. 

removed the involved birds and provided 

(b) (6)

appropriate cervical dislocation procedure. While checking the 

bin, Mr Wade recovered a third, live bird and applied 

appropriate cervical dislocation procedure. 

2nd shift, 

and 

discussed the situation, which occurred due to an apparent 

(b) (6)

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

communication lapse amongst staff in the hanging room, and 

that communication coaching would be in order. On 8/31 at 

around 1535 hours, 

(b) (6)

informed 

(b) (6)

of the 

issuance of this memorandum for the stated infraction. This 

event is being associated with MOI ZCB01190821141. 

P1317 Wayne Farms 04C05 QUI482007 27JUL2018 Wayne Farms LLC. 700 McDonald Ave. Albertville AL, 35950 

LLC 1827G FROM: , 2nd shift To: Mr. Bryan Elrod, Plant 

July 27, 2018, while performing the Review and Observation 

component of the PHIS task, “Poultry Good Commercial 

Practices,” I, observed a few live birds covered by and comingled 

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. Corrective and preventive measures 

addressing this incident are appropriate. I look forward to your 

response. A copy of this Memorandum of Interview will be 

Manager Dear Mr. Elrod, At approximately 20:38 hours, on 

(b) (6)

with several dead birds in a pile on the floor at the end of the 

live bird belt. and

 were notified of the finding and implemented 

corrective action(s).  As per Federal Register Notice Docket No. 

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

forwarded to appropriate personnel in the Jackson District 

Office. Dr. Gregory Brookhouser, 

DDM Respectfully submitted, 

(b) (6)

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

Albertville 07/27/2018 
 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 46 

EstNbr EstName Task_Code MOI# Date Description 

P1317 Wayne Farms 04C05 QUI522008 24AUG2018 

LLC 3024G 

TO: Mr. BRYAN ELROD, Plant Manager Wayne Farms LLC. 700 

McDonald Ave. Albertville AL, 35950 FROM: 

, , At approximately 20:25 hours, 

(b) (6)

(b) (6)

on August 24, 2018, while performing the Review and 

Observation component of the PHIS task, “Poultry Good 

Commercial Practices,” I observed two live birds in the DOA 

barrel. The birds were lying on the top of other dead birds and 

being in eminent danger to be crushed and smothered by other 

birds when piling up on the top of each other. During 

my observation I have noticed that all birds were denatured 

including both live birds 

, was notified about my observation. 

also observed the deficiency. I then notified 

, of the observed deficiency, during a 

(b) (6)

(b) (6)

(b) (6)

brief meeting held in USDA/FSIS office at approximately 20:40 

hours. I also informed them that a GCP MOI documentation of 

our meeting and discussion of the observed deficiency would be 

forthcoming. 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. 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 

(b) (6)

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

Office. Dr. Gregory Brookhouser DDM

 Albertville AL, 35950 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 47 

EstNbr EstName 

P1353 Pilgrims Pride 

Corporation 

Task_Code 

04C05 

MOI# 

WUM0704 

050224G 

Date 

24MAY2018 

Description 

On May 23, 2018 at approximately 2250 hours, I was informed 

by on-line inspection personnel that a DOA bird had been 

identified on the inspection line. I immediately went to the live 

receiving area. Upon my arrival, I found a pile of DOA’s at the 

end of the belt. The pile had reached the top of the belt and was 

approximately three feet in height. I instructed 

to stop hanging birds until the 

(b) (6)

problem was resolved. As the plant employees were picking up 

the DOA’s, I observed two live birds that had been completely 

covered by dead birds. In addition, I observed one of these live 

birds being put in a DOA condemn barrel. The live bird was not 

removed and establishment employees had begun placing dead 

birds on top of the live bird. I removed the live bird from the 

DOA condemn barrel and notified 

and . I 

explained my observations and informed them that a 

(b) (6)

(b) (6)

Memorandum of Interview (MOI) was going to be documented 

and a copy forwarded to the appropriate personnel in the 

Jackson District Office. Without USDA intervention, multiple 

live birds would have been at risk of dying by means other than 

slaughter. Under my observation, establishment employees 

finished disposing of the dead birds at approximately 2304 

hours and resumed hanging at that time. 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, distress and injury by 

means other than slaughter. Also such abuse of poultry and 

treatment in a manner not consistent with good commercial 

practices, and death by means other than slaughter, may render 

the poultry adulterated. Respectfully submitted on May 23, 

2018 

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

Cc: Dr. David Thompson, 

DDM; ; 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 48 

EstNbr EstName 

P1353 Pilgrims Pride 

Corporation 

Task_Code 

04C05 

MOI# 

WUM2202 

065426G 

Date 

26JUN2018 

Description 

On 06/26/2018 at approximately 0305 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. 

was notified. I explained 

(b) 

(6)

my observations and informed him 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. 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)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 49 

EstNbr EstName Task_Code MOI# 

P164 Tyson Foods Inc 04C05 IJM580408 

5221G 

Date 

21AUG2018 

Description 

CSI Statum performed AM/GCP @ 2330 hrs. 

performed AM/GCP @ 0303 hrs. Mr. Steve Langford, On 

(b) (6)

August 18, 2018 at approximately 0308 hrs. I, 

, observed less than Good Commercial Practices (GCP). 

(b) (6)

On the back dock while performing a Good Commercial Practice 

Task, I observed a live chicken inside the DOA bin. 

was notified at approximately 0309 

hrs.  Mr. Hodges immediately notified 

.  notified 

at approximately 0318 hrs. of the  findings while 

(b) (6)

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

performing the GCP Task.  Allowing bird(s) to enter the DOA bin 

alive is not consistent with Good Commercial Practices and bird 

(s) dying by means other than slaughter results in adulterated 

product. Every effort must be made by the Establishment to 

prevent live bird(s) from entering the DOA bin, and measures to 

prevent mishandling of poultry must be adhered to by the 

Establishment to ensure unnecessary suffering by poultry under 

the Establishment’s control. Refer to FSIS Docket No. 04-37N, 

Treatment of Live Poultry before slaughter. 

P165H OK Foods, Inc. 04C05 DAF10130 29JUN2018 At approximately 1038 on 6/29/18, while performing a good 

60629G commercial practice check, I (Dr. Daily) observed a sensible bird 

(eyes open, head up) proceeding down the line and into the line 

of my observation. We traveled down the line and observed a 

cadaver exit the pickers. 

(b) (6)

removed the cadaver from 

the line, and examined it. There was no cut on the neck. 

Shortly thereafter, I performed a recheck and observed zero 

sensible birds prior to the scalder.  This finding was later 

.  Later in the shift 

notified me that the employees would be retrained and be

(b) (6)(b) 

(6)

discussed with 

(b) (6)

and 

1 scalder. 

(b) (6)

was notified 

disciplined according to company policy.  Additionally, the 

maintenance department will remove a portion of the blood 

tunnel side wall to allow for better visualization of the birds as 

they travel down the line past the employee who continually 

monitors for sensible birds. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 50 

EstNbr EstName Task_Code MOI# 

P165H OK Foods, Inc. 04C05 DAF29020 

71431G 

Date 

31JUL2018 

Description 

At approximately 2021 hours, I performed ante-mortem on Lot 

3A, trailer 2034 at the back dock area. I noticed that one of the 

cages had a door that was open about 1/4th of the way. There 

were also two cages in which the birds wings had been caught 

in the sides of the doors. At approximately 2023 hours, I 

finished performing ante-mortem on Lot 4 at the back dock area 

also. I then noticed that there were 2 live chickens on the 

ground at trailer 2034 as well as a door. The jack driver looked 

at me and shrugged his shoulders. The cage in which this door 

fell off of was on the unloading belt which led to the cage 

dumper. The door that fell off of the cage was the same door 

that I had noticed being open while I was performing 

ante-mortem on this trailer. The lead came over and picked up 

both live chickens and placed them onto the rehang belt. The 

supervisor was not in the area at this time. The establishment 

employees are supposed to be looking at the cages prior to 

moving them so that these types of cages can be flagged in 

order to prevent any harm to the live chickens. The live side 

employees are also supposed to be checking the trailers in the 

live shed for open doors so that they could be closed or the cage 

flagged prior to the trailer being moved to the back dock area. 

Neither the live side employee nor the back dock employees 

tried to prevent this incident from occurring. I then met with 1st

 and informed him of 

what I had observed at the back dock unloading area. 

informed me that he would have the back dock 

(b) (6)

(b) 

(6)

responded in the meeting that he would correlate with 

live side to ensure that the live side employee is looking at the 

trailers in the live shed. On 5-15-18, I observed a second 

incident in the live shed which involved a chicken having its’ 

head caught in a door which resulted in the death of that bird. I 

also discussed the numerous observations of open cage doors 

throughout the week. This meeting was documented in 

MOI – DAF0204052216G. The establishment response to this 

employees retrained and those directly involved would be 

disciplined according to the establishment’s policy. On 

5-11-18, during the Weekly Exit Meeting, I discussed the issue of 

open cage doors in the live shed with plant management and 

documented this discussion in MOI – DAF1502053411G. 

(b) 

(6)

MOI states “ 

(b) (4)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 51 

EstNbr EstName Task_Code MOI# Date Description 

”. USDA’s concerns are that the employees directly 

(b) (4)

P165H OK Foods, Inc. 04C05 DAF06100 

85806G 

P165H OK Foods, Inc. 04C05 DAF23110 

93006G 

06AUG2018 

06SEP2018 

involved in the welfare of the chickens are not being observant 

as to the condition of the cages and taking appropriate action 

when necessary which has resulted in live birds falling out of a 

cage onto the ground. It is the establishment’s responsibility to 

adhere to Good Commercial Practices and prevent these 

incidents from occurring. 

At approximately 0749 on 8/6/18, while performing a good 

commercial practice check, I ( 

(b) (6)

) observed a sensible bird 

(eyes open, head moving) proceeding down the line and into the 

line 1 scalder. 

was notified of my observation. We traveled down the line and 

observed a cadaver exit the pickers. 

(b) (6)

removed the 

cadaver from the line, and examined it. I observed that there 

was a kill machine cut along the side of the face/jaw of the bird. 

(b) (6)

observed zero sensible birds prior to the scalder. 

This finding was discussed with 

.  Shortly thereafter, I performed a recheck and

(b) (6)

(b) (6)

and

(b) (6)

 notified me that the employees would be 

retrained and disciplined according to company policy. 

Additionally, one of the employees may be relocated to a 

different position. 

At approximately 0955 on 9/6/18, while performing a good 

commercial practice check, I (

(b) (6)

 observed a sensible bird 

(eyes open, head moving) proceeding down the line and into the 

line 1 scalder. 

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

was 

notified of my observation. removed the cadaver 

from the line past the pickers, and examined it. I observed that 

there was no cut on the neck of the bird.  This finding was 

discussed with , 

and 

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

(b) (6)

Shortly thereafter, I performed a recheck and observed zero 

sensible birds prior to the scalder.  and 

notified me that the employees would be retrained and 

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

disciplined according to company policy.  Observations of a 

single sensible bird entering the scalder were also documented 

on 6/29/18 and 8/6/18.  All of these finding occurred on line 1. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 52 

EstNbr EstName Task_Code MOI# 

P165H OK Foods, Inc. 04C05 DAF38020 

91618G 

Date 

18SEP2018 

Description 

At approximately 0036 hours, while performing ante mortem 

inspection on Lot 6 – Trailer 2038, I observed a chicken with its 

head caught in between the door and the cage frame. The bird 

was not showing any signs of life and there was blood splattered 

on the front of the door from where the bird bled onto it. I 

immediately went to the back dock and located 

. I showed the cage with the 

chicken’s head caught in the door. stated that 

he would inform 

(b) (6)

(b) (6)

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

USDA’s concerns are that the employees directly 

involved in the welfare of the chickens are not being observant 

when they place the birds into the cages and close the doors. 

Although the live side management team has provided 

additional training to the catch crews and drivers, it is 

questionable whether these measures have been properly 

implemented as seen by today’s incident which resulted in the 

strangulation/skull crushing death of the bird. It is the 

establishment’s responsibility to adhere to Good Commercial 

Practices and prevent these incidents from occurring. The 

establishment is encouraged to reply to this MOI. 

of the issue so that the appropriate personnel on live side could 

be informed. On 5-15-2018, MOI-DAF0204052216G was 

issued for this very same type of incident occurring. A chicken 

had its head caught between the door and the cage frame which 

resulted in the strangulation/skull crushing type of death. The 

plant responded to that MOI with the following statement: “On 

the live side all personnel involved has received additional 

animal welfare training. This matter was addressed with both 

catch crews and drivers in an effort to prevent further incidents. 

Attached are copies of related documents that have been signed 

and dated.” The attached documents included the training 

document for the catch crew on how to catch the birds and 

place them in the cages without injury. The documents also tell 

the catch crews what to do if a bird is caught in the door and 

that they are to take care of it immediately. Another document 

is for the drivers and it states 

(b) (4)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 53 

EstNbr EstName Task_Code MOI# Date Description 

P165S OK Foods, Inc. 04C05 LWA00220 05JUL2018 

70205G 

P165-s, OK Foods; 7/5/18, 2000 hours. Attendance: 

Jesus Sosa (Live Hang supervisor).  At 1458 on 7/5/18, 

at CI stand 1 and while performing 

(b) (6) (b) 

(6) (b) (6)

carcass by carcass inspection observed a cadaver carcass come 

to her stand. She described the carcass as still having a head and 

neck without any exsanguination cuts on them. The head, neck, 

and wings of the carcass were bright red and appeared heavily 

congested. She had the line stopped and the cadaver removed 

from the evisceration line. The cadaver was shown to the line 

lead who had the carcass disposed of. No further cadavers were 

seen on this line after this incident.  At approximately 1950 on 

7/5/18 I was observing the auto-rehang area to conduct a line 

speed check when I observed a plant employee throw a carcass 

from the Line 2 rehang table towards a condemn can and miss. I 

picked up the carcass and observed a head still attached to the 

carcass and that there were no exsanguination cuts anywhere. 

The head and neck were bright red and appeared heavily 

congested. This carcass did not die by slaughter and would have 

been alive going into the scalder and as such is a cadaver. I had 

the carcass held back until 

and were shown the 

(b) (6)

(b) (6)

that an MOI would be documented over this issue. A 

copy of this MOI will be submitted to the DVMS in case 

additional follow-up is recommended. 

cadaver which was then disposed of by the plant. I stayed at the 

rehang table until the line emptied a few minutes later due to 

the establishment's lunch break and no more cadavers were 

seen in this time. I informed

(b) (6)

 that Agency 

regulations require live poultry to be handled in a manner 

consistent with good commercial practices and that they are 

not to die from causes other than slaughter. I notified 

(b) 

(6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 54 

EstNbr EstName Task_Code MOI# 

P165S OK Foods, Inc. 04C05 LWA50200 

75612G 

Date 

12JUL2018 

Description 

At 1800 on 7/12/18 while performing a GCP task I entered the 

live hang room and observed that the belt and shackles were 

empty and that roughly half of the live hang workers were at 

three full yellow condemn barrels and removing DOA birds from 

them to perform a cervical dislocation and then throw the 

carcasses into a large trash dumpster which was about half full. I 

waited in the room for a few minutes to observe the next cage 

of birds to be brought in which appeared to be normal. I then 

went to the live haul shed and observed that the 5th trailer bay 

had a load of birds on it but 15 of the fans were either barely 

working or not working at all. The birds in those cages were 

observed to be heavily panting. The other bays had working 

fans, but I observed that for every two trailer bays there is only 

one set of fans providing air to them. This means that the only 

air coming to the bay furthest from the fans must go through an 

entire trailer of cages first. I could not feel any air flow from the 

fans coming to the cages furthest from the fans because of this. 

The birds in those cages were observed to also be panting 

heavily. I had 

(b) (6) , 

come out to the live haul shed and I showed him the issues. He 

radioed for the Live crew to move the trailer in the bay with the 

non-working fans into another bay. Then he had the doubled up 

bays separated out as much as possible so that each trailer 

would get its own set of fans. He called for maintenance to look 

into the non-working fans, but they were unable to get access to 

the fan breaker box because it was locked and they did not have 

a key. At 1920 on 7/12/18 I returned to the live hang room 

and observed that there were a large number of DOA birds 

coming across the live hang table again. The workers at the end 

of the belt could barely keep up with the number of dead birds 

reaching the end of the line to the point where the carcasses 

were occasionally piling up there. I observed that the worker 

putting carcasses into the yellow barrel on two separate 

occasions put a live bird into the yellow barrel. The live bird was 

caught before any carcasses were placed on top of it so they did 

not get smothered, however the worker was obviously not 

ensuring that only dead birds were going into the condemn 

barrel

(b) (6)

 was shown the issue and he had the 

worker slow down and better observe the carcasses before 

placing them in the barrels. 

(b) (6)

and I correlated 

with the DOAs that were coming into live hang and we saw that, 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 55 

EstNbr EstName Task_Code MOI# 

P165S OK Foods, Inc. 04C05 LWA45170 

74919G 

P165S OK Foods, Inc. 04C05 LWA00130 12SEP2018 

94412G 

Date 

19JUL2018 

Description 

without exception, all of the carcasses were well fleshed out and 

in otherwise good body condition. Most of the carcasses we 

observed showed some signs of rigor mortis(wings and legs 

stiff). 

(b) (6)

used a thermometer into the breast muscle 

of some of the DOAs and got temperatures in the mid 90s. Jesus 

Sosa, live hang supervisor, stated that they had three trailers of 

birds come into live hang that all had similar death loss. The 

establishment has the responsibility to follow good commercial 

practices in regards to the handling of chicken. Effective efforts 

must be taken to prevent the unnecessary death of poultry 

which will in turn reduce incidents of adulterated or otherwise 

unwholesome product being produced. 

This  MOI is to document my conversation with 

, , and 

. At approximately 0517 hours, while 

(b) (6)

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

observing the establishment's Good Commercial Practices, I 

observed a Live-Hang employee picking up live chickens and 

throwing them approximately 3 to 4 feet up the Live-Hang 

conveyor belt. Employees were not hanging chickens on 

showing him which employee was throwing the chickens. 

had a conversation with the employee. I later discussed

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

(b) 

(6)

shackles yet. I notified area , of the issue, 

the same issue with the , and 

. 
....... 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 56 

EstNbr EstName Task_Code MOI# 

P17340 Pilgrim's 04C05 UQB15150 

50922G 

Date 

22MAY2018 

Description 

While doing a Good Commercial Practices task on 5-21-18, on 

1st shift at Pilgrims of Hickory, KY, I observed two (2) live birds 

enter the scalder of Line 1.  I began observing the birds enter the 

scalder of Line 1 at 1330.  At 1332, I observed the first bird enter 

the scalder.  Its head was raised, the eyes were open and it 

moved its head. I observed a second bird enter the scalder at 

1334.  It, also, had its head raised and eyes open. I continued 

to observe the birds entering the scalder of Line 1 for three 

more minutes without seeing another live bird. At 1339, I 

informed 

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

that I had seen two live birds enter 

the scalder of Line 1.  radioed for the live hang 

supervisor and I informed the supervisor of the live birds 

entering the scalder.  I also informed Plant Manager Todd Hicks. 

These two 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.” 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 57 

EstNbr EstName Task_Code MOI# 

P17340 Pilgrim's 04C05 UQB21160 

70706G 

Date 

06JUL2018 

Description 

While doing a Good Commercial Practices task on 7-5-18, on 1st 

shift at Pilgrims of Hickory, KY, I observed one live bird enter the 

scalder of Line 2.  It had its head up and eyes open. I had begun 

observing the birds enter the scalder of Line 1 at 11:41:01 and 

observed the live bird enter the scalder approximately 40 

seconds later.  I continued observing the birds enter the scalder 

for 3 more minutes—until the last one entered before the lunch 

break.  There was not a supervisor on the evisceration floor 

when I left the scalder room and I did not find 

in live hang or at the unloading docks. I informed Mr. Roberts 

about the live bird entering the scalder after lunch and that I 

would issue a MOI.  I stated I had not seen evidence of a loss of 

process control as I had not seen any other birds enter the 

scalder.  While talking with 

(b) (6)

about the live bird 

entering the scalder, we also discussed that the roof of the fan 

shed was not long enough to protect the ends of the trailers 

from the weather, i.e. the sun beating on them.  Yesterday, I had 

discussed with first 

(b) (6)

and then, briefly, with

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

 that it might be prudent to unload the last two 

cages of the trailers first when they move them into the 

unloading docks because those birds are suffering from heat 

exhaustion, more than the others, due to the sun beating on 

them. 

(b) (6)

said they had discussed this with the forklift 

drivers and they were implementing this. At approximately 

13:00, 

(b) (6)

informed me that he had stopped live 

hang on the old side because the process was out of control.  He 

stated dead birds were piled everywhere and numerous live 

birds were on the floor.  I went to live hang at approximately 

13:15 or 13:20 and found he had released it and the associates 

were hanging birds again.  However, live hang had become 

much worse in the minutes between him releasing it and me 

entering it.  There was a pile of dead birds on the wall by the 

neck puller.  It was at least 1 1⁄2 feet high and 2 1⁄2 feet in length. 

There were only two people (that I could see) trying to take care 

of the pile of dead birds and keep the live birds off the floor.  I 

observed one of the men pull 1 live bird from the edge of the 

pile and I observed another live bird get hit by a dead bird that 

one of the live hang associates threw off the belt. I verbally 

issued a RCA and had live hang stop again.  Having no way of 

knowing how many birds died on premises and how many died 

elsewhere, my concern was if live birds are being injured or 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 58 

EstNbr EstName Task_Code MOI# Date Description 

smothered by the number of dead birds thrown off the belt and 

into a pile. A live hang supervisor came in; I informed her that 

conditions back here were unacceptable and stated a prudent 

establishment would have a plan in place in the event that 

numerous dead birds came down the belt.  It was obvious 

the two people were not going to be able to remove that 

number of dead birds quickly.  More people were assigned to 

removing the birds and keeping the live birds picked up.  I 

stayed and observed the removal of the pile of birds and did not 

see any other live birds mixed with the dead birds or any other 

mishaps with live birds.  Mr. Todd Hicks entered the live hang 

room and went out to speak with the supervisor.  When they 

re-entered, I stated I would be writing a MOI on this incident. 

Later in the day, at approximately 16:30, I spoke with 

(b) (6)

about the number of dead birds. 

Regardless, of whether the birds died at a house, in transport or 

on premises, there should be a plan in place in the event of 

numerous dead birds arriving.  A prudent establishment knows 

the number of dead birds arriving can be drastic in the extreme 

heat of the summers and in the extreme cold of some winters. 

Based on weather forecasts and notification of conditions from 

the poultry houses, receiving and live hang should be prepared 

for what might arrive. I also informed 

(b) (6)

that the roof 

of the fan shed was not long enough to protect the birds from 

the extreme weather conditions, especially the last cages on the 

trailers.  I stated one can see marked indications of heat 

exhaustion among the birds—severe panting, flapping wings, 

eyes wide with distress and panic while others are almost dead 

and barely breathing.  It is much worse in the back two cages 

that have no protection from the sun. 

(b) (6)

stated it 

might be better if those two cages came in empty on these 

extreme heat days.  I agreed. These incidents, a live bird 

entering the scalder and live birds on the floor comingling with 

piles of dead birds and being hit by thrown dead birds along 

with evidence of heat exhaustion in the holding fan shed, 

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.” Respectfully, 

(b) 

(6)

(b) (6)
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1111 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 59 

EstNbr EstName Task_Code MOI# 

P17340 Pilgrim's 04C05 UQB10060 

95725G 

Date 

25SEP2018 

Description 

On the morning of 9/25/18, while performing a good 

commercial practices task on 3rd shift, I observed a live bird, as 

evidenced by its elevated head and turning of its head, enter the 

scalder on Line 1 at 5:21.  I observed three more minutes and 

did not see another live bird.  I left to notify a supervisor and 

found 

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

nearby at the end of the 

picking line.  I informed  of the live bird entering 

the scalder and we stood there until it came out of the pickers. 

and informed him of the above incident. I stated I had 

not seen evidence of a loss of process control as I had not seen 

any other live birds enter the scalder. Federal Register 

Docket # 04-037N titled "Treatment of Live Poultry Before 

Slaughter" states that "The Food Safety and Inspection Service 

(FSIS) is reminding all poultry slaughter establishments 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, which means they 

should be treated humanely." 

(b) (6)

removed it from the line and I informed him I 

would be writing a MOI. I went back to the entrance of the 

scalder and observed for approximately 5 minutes and did not 

observe any further issues.  I also observed the entrances of the 

scalders of Line 2 and Line 3 as part of the task and did not 

observe any deficiencies. At 5:47, while finishing the good 

commercial practices task, I met 

(b) (6)
• 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 60 

EstNbr EstName Task_Code MOI# 

P17766 Southern Hens, 04C05 SSN281606 

Inc 0007G 

Date 

07JUN2018 

Description 

Nathan Ahrens, Plant Manager On June 7, 2018 at 

approximately 1526 hours, I, 

(b) (6)

, observed less 

than Good Commercial Practices while performing a routine 

Ante-mortem and Good Commercial Practices task at P-17766. 

On the back loading docks, two workers were aggressively 

tossing cages containing live hens onto the conveyer belt that 

feeds into the live hanging room. The cages were being tossed 

from stacks ~10ft high, as well as ~3.5ft from left to right. I 

observed two cages being turned upside down prior to landing 

on the conveyer belt, and one cage forcibly opened while 

landing letting lose 3 of the hens held in the cage. The metal 

unloading chutes were not in use at the time. At the time of the 

incident there was no supervisor present. Plant Manager Nathan 

Ahrens and 

(b) (6)

were immediately 

informed of this mistreatment. 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 Information will be sent to the Jackson 

District Office for further review. Thanks for your attention to 

this matter. Respectfully, 

Supervisory Public Health Veterinarian USDA FSIS OFO Jackson 

District CC: 

Gregory Brookhouser, DDM Larry Davis, DM 

(b) (6) (b) 

(6)

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

         

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 61 

EstNbr EstName Task_Code MOI# 

P17766 Southern Hens, 04C05 SSN581207 

Inc 1020G 

Date 

20JUL2018 

Description 

July 20, 2018 Mr. Nathan Ahrens Plant Manager P-17766 

Southern Hens Inc. 329 Moselle-Seminary Rd. Moselle, MS 

39459 Re:  MOI, Good Commercial Practices Mr. Ahrens, On 

July 20, 2018, P-17766 presented 5 trailers/partial trailers of live 

birds for slaughter that were from the previous day’s scheduled 

slaughter (Thursday July 19, 2018) that were presented but not 

slaughtered on 7/19/2018.  One of these “carry-over” trailers 

had a significant increase in the number of Dead on Arrivals 

(DOAs) when presented for slaughter on 7/20/2018 compared 

to the number of DOAs observed on the same trailer/lot on 

7/19/2018.  It is apparent based on the increase in the number 

of DOAs from the same lot of birds from the previous day to the 

next that they died from some cause other than slaughter or 

euthanasia.  In accordance with Federal Register 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.  Thank 

you for your attention to this matter. 

Circuit 9009 Jackson District CC: 

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

Dr. Larry Davis, DM Dr. Gregory Brookhouser , DDM 

(b) (6)
        

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 62 

EstNbr EstName Task_Code MOI# 

P17766 Southern Hens, 04C05 SSN221707 

Inc 4530G 

Date 

30JUL2018 

Description 

Mr. Nathan Ahrens Plant Manager Southern Hens, Inc. 329 

Moselle-Seminary Rd. Moselle, MS 39459 Mr. Ahrens, At 

approximately 0718 hours, the following less than Good 

Commercial Practices in Poultry (GCPIP) incident was observed 

at P17766, Southern Hens Inc, Moselle, MS while performing 

the routine PHIS Poultry Good Commercial verification task. 

Two (2) live chickens were observed in the Dead on Arrival 

(DOA) bin along with 2 DOAs.  The transfer belt from the live 

hang to the DOA bin was operating unattended. 

and 

were notified. Allowing live bird(s) to enter the 

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

DOA bin and comingle with DOAs can lead to entrapment, 

suffocation and death.  Live birds may accidentally enter the 

offal chute and be carried by the flowing water into offal pit, 

through the augers, and into the offal trailers.  This can cause 

needless suffering and death.  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. Mr. Nathan 

Ahrens Plant Manager and 

(b) (6)

discussed 

briefly the less than GCPIP incident in the evisceration 

department at approximately 0830 hours. No response to the 

less than GCPIP incident was given at this time.  Mr. Ahrens was 

advised a GCPIP Memorandum of Interview would be issued to 

management pending review by 

(b) (6)

. 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)

39046 cc:  Dr. Larry Davis, DM Dr. David Thompson, DDM

 Dr. Gregory Brookhouser, DDM Mr. William Griffin, 

DDM 

(b) (6)

(b) (6)
-

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-

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 63 

EstNbr EstName 

P18557 Sanderson 

Farms, Inc. 

Task_Code 

04C05 

MOI# 

QNA45110 

74824G 

Date 

24JUL2018 

Description 

, and observed no more nonconformance in a 150-bird 

sample.  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 

, of the observed 

nonconformance, during a brief meeting held in the picking 

room at approximately 1124. I pointed the cadaver out to him, 

as it passed by on the #1 picking line.  I also informed him that a 

Memorandum of Information (MOI) was going to be 

documented for this observation. 

(b) (6)

removed the 

cadaver from the line and took it to the employee that was 

working on line #1.  The employee explained that there were 

several birds in a row that were hung by only one leg and had 

not been through the kill machine properly.  He stated that he 

thought that he had gotten all of the affected birds. 

informed me that, according to the Sanderson Farms Inc. 

employee performance protocol, written documentation of this 

incident was to be placed into the employee's folder. I 

reevaluated the line operation, after my discussion with 

(b) 

(6)

, 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 there were different personnel backing up the kill 

machine from those usually staffing these positions. 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 1121 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 

(b) (6)

On July 24, 2018 at approximately 1121, 

(b) (6)

(b) (6)
-

1111 ■ 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 64 

EstNbr EstName Task_Code MOI# Date Description 

the Jackson District Office. Respectfully, 

cc: and 

. 

(b) (6)

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

P18873 Tyson Foods, 04C05 WUA14180 20SEP2018 

Inc. 92320G 

Establishment P18873, Tyson Foods, Vienna, Georgia, 

September 19, 2018, 2020 hours.  In attendance: 

At approximately 2010

(b) (6)

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

hours on Wednesday, September 19, 2018, I, , 

was performing a Good Commercial Practice inspection at the 

cage dump area.  At the end of the platform where cages are 

conveyed to be dumped onto the live hang belt, I observed that 

a live chicken was perched on the platform (not within a cage). 

The next cage to be dumped onto the live hang belt was 

conveyed over the top of this chicken.  After the cage was 

dumped, I observed that the chicken which had previously been 

perched on the platform had been crushed.  The chicken was 

lying on its side and was bloody.  I cannot state with certainty 

that the chicken was dead, but I observed no signs of life.  After 

the cage had been dumped and moved from that area of the 

platform, a plant associate apparently saw the crushed bird and 

placed it on top of the next cage to be dumped onto the live 

hang belt.  After my observations, I immediately requested to 

(b) (6)

see 

(b) (6)

.  I related my observations to

 came to my office and related that all plant personnel 

who could be responsible for operating the cage dumping 

system on both shifts will receive mandatory training on their 

responsibility to observe for loose birds and protect them from 

injury in the dumping process. USDA-FSIS wishes to remind the 

establishment that live poultry should be handled in a manner 

that is consistent with good commercial practices, they should 

be protected from mistreatment, and they should not die from 

causes other than slaughter. 

and explained that allowing live chickens to be 

crushed or to die other than by slaughter was inconsistent with 

Good Commercial Practices.  At approximately 2052, 

(b) 

(6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 65 

EstNbr EstName 

P192 Pilgrims Pride 

Corporation 

P192 Pilgrims Pride 

Corporation 

Task_Code 

04C05 

04C05 

MOI# 

OOB10060 

84301G 

OOB46140 

81808G 

Date 

01AUG2018 

08AUG2018 

Description 

On 7/31/18 at 0805 I ) met with L

 in the USDA office to notify 

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

was performing Antemortem verification at start of 

operations he observed a trailer of empty cages parked out in 

the open near the scale. The trailer had a single live bird resting 

in one of the cages. 

(b) (6)

was 

notified of the inspector’s findings The trailer #799 was traced 

back to grower T & W Farm from yesterday’s production, 

7/30/18. No carry over lot from today’s production is associated 

with T & W Farm. Records indicate the last cage from trailer 

#799 was dumped at 1706. This is not an acceptable outcome 

consistent with good commercial practices. The bird was not 

slaughtered as intended, culled or euthanized, nor was it 

returned to the farm. 

management that a GCP MOI was being issued for the plant’s 

failure to take appropriate action with a live bird from 

yesterday’s production. This morning at 0505 while 

(b) (6)

On August 7, 2018 at 1820, I went to the live receiving area to 

perform a Good Commercial Practices task.  Upon entering the 

yard, I observed four trucks with full loads of birds that were not 

under the shed and were not near any misters.  On closer 

observation, I saw that several birds on each truck were panting, 

a clear sign of respiratory distress.  I waited a few minutes to see 

if anyone was coming to tend to the birds.  At 1828, I notified 

the shift manager that the birds were in distress.  He informed 

me that someone would be there right away to hose them until 

they could get them into the shed.  I went back on the yard and 

waited five minutes.  No one came and even more birds were 

panting by this time.  I then went back and informed the shift 

manager that I would be writing an MOI due to the plant’s 

failure to maintain Good Commercial Practices in accordance 

with Federal Register 04-037N. 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 66 

EstNbr EstName 

P192 Pilgrims Pride 

Corporation 

P19514 Tyson Foods, 

Inc. 

Task_Code 

04C05 

04C05 

MOI# 

OOB51220 

94311G 

UMF32130 

61804G 

Date 

11SEP2018 

04JUN2018 

Description 

On September 11, 2018 at 1530, I went to the live receiving 

area to perform a Good Commercial Practices task. Upon 

entering the yard, I observed a truck with a full load of birds 

directly in the sun with no covering or water source.  As soon as 

I approached the truck, I noticed that many of the birds were 

panting.  I immediately asked one of the live receiving 

employees to get the supervisor.  After waiting for ten minutes

(b) (6)

 showed up and I informed him that I 

would be documenting this failure to maintain good commercial 

practices in an MOI.  He then hooked up the water hose and 

instructed his employee to begin spraying the birds.  Within 

minutes after that, the truck was moved to the shed where the 

birds would be near misters and out of direct sun. Federal 

Register 04-037N encourages those involved in the slaughter of 

poultry to abide by Good Commercial Practices. 

At approximately 13:00 hours, I observed the cage dump 

employee dump birds from five cages.  For all of the actions, the 

employee dumped the cage of new birds on top of the 

remaining foot and one half of remaining birds from the 

previous cage dump. 
I I 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 67 

EstNbr EstName Task_Code MOI# Date Description 

P19688 Sanderson 

Farms, Inc. 

04C05 KJA122208 

5109G 

09AUG2018 . 
-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 68 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL490405 

3721G 

Date 

21MAY2018 

Description 

was immediately notified and informed that 

these observations would be documented.  During a 500 bird 

verification following these observations no other live birds were 

seen entering the scald vats. Live bird(s) entering the scald 

system live is a less than Good Commercial Practices and results 

At approximately 2302 hours on May 20, 2018 while 

performing the Good Commercial Practices and Ante Mortem 

task, the following was observed in the kill area under the 

shackle lines as they exit live hang.  A live bird was observed 

lying on its back on the ground under the lines.  Upon closer 

observation two digits had been freshly amputated from its 

right leg and had bright red, fresh blood present.  The bird was 

breathing and had a strong heartbeat; upon lifting its head it 

began blinking.  I started to gently move the bird from being 

directly under the line to prevent further harm and at that time 

noticed a tear in the birds left side and intestines began to spill 

out.  I left the bird and immediately went to the live hang area 

to try to locate a supervisor.  In the live hang break room a lead 

was located and I asked if he could please come with me to 

immediately euthanize the bird to prevent further 

suffering/discomfort.  The bird was euthanized at approximately 

2305.  At that time I asked if he could please radio a supervisor 

for me to inform them of the incident and that a GCP MOI 

would be documented.  A short time later a meeting was held 

with 

(b) (6)

to inform him of 

the above observations. 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 0158 a USDA Food Inspector requested the 

SPHV to observe a retained bird on evisceration line two.  This 

bird was a cadaver that had the head attached with only the 

skin and trachea cut; no vasculature penetrated.  Due to these 

findings an additional Good Commercial Practices task was done 

at the entrance to the scald vats.  At approximately 0203 on 

evisceration line two a relatively small bird (compared to the 

other birds in the lot) had the same appearance as the bird 

previously observed (the skin was cut, but not the vasculature), 

the bird was breathing, lifting its head, flapping its wings and 

blinking.  This bird bypassed both of the head pullers prior to 

the scald vat and went in alive. 

(b) (6)
 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 69 

EstNbr EstName Task_Code MOI# Date Description 

in adulterated product. 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 21, 2018 Cc: Dr. David 

Thompson, DDM 

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

(b) (6)
 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 70 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL142305 

2130G 

Date 

30MAY2018 

Description 

At approximately 0400 hours on May 29, 2018 while 

performing the Good Commercial Practices and Ante Mortem 

task, the following was observed at the entrance to the scald vat 

of evisceration line one.  A live bird that had a small superficial 

cut to the rostral most aspect of the beak tip that did not 

penetrate any major vasculature was observed entering the 

scald vat.  This bird was relatively small compared to the 

average size of the other birds in the lot, the first head puller on 

this line was blocked with heads and a carcass and the bird 

lifted its head bypassing the second head puller.  The bird was 

rhythmically breathing, lifting its head/looking from side to side, 

flapping its wings and blinking.  500 bird verification was done 

immediately afterwards and no other live birds were observed 

entering the scald vat. 

(b) (6)

was 

notified of my observations immediately and that a GCP MOI 

would be documented.  A meeting was held with Third Shift

 a few minutes later to inform him 

of the above observations. 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. 

Live bird(s) entering the scald system live is a less than Good 

Commercial Practices and results in adulterated product. 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 

(b) (6)

District Office.  Respectfully submitted on May 29, 2018 

Cc: Dr. David Thompson, DDM 

(b

) 

(6)

(b

) 

(6)

(b) (6)
 

1111 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 71 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL350206 

0805G 

Date 

05JUN2018 

Description 

After giving the 0300 set of USDA Food Inspector breaks on June 

4, 2018 an additional Good Commercial Practices and Ante 

Mortem task was done due to the increase in cadavers observed 

on evisceration line two.  The following was observed at the 

entrance to the scald vat of evisceration line two at 

approximately 0337.  A live bird, which was much smaller than 

the average size of the rest of the birds in the lot, had a small 

superficial cut to the right side of its neck that did not penetrate 

the major vasculature was observed entering the scald vat.  The 

bird bypassed over the top of both of the head pullers due to its 

small size and it was lifting its head and neck in an attempt to 

right itself.  The bird was rhythmically breathing, lifting its 

head/looking from side to side, flapping its wings rapidly and 

blinking.  After making this observation I immediately 

completed a 500 bird verification and no other live birds were 

observed entering the scald vat. 

and were 

notified of my observations and that they would be 

(b) (6)

(b) (6)

documented in a GCP MOI. The establishment is responsible 

for ensuring that birds under their control on the official 

premises are treated in accordance with good commercial 

practices and in a manner that will minimize excitement, 

discomfort, injury and/or death by means other than slaughter. 

Live bird(s) entering the scald system live is a less than Good 

Commercial Practices and results in adulterated product. 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 4, 2018 

Cc: Dr. David Thompson, DDM 

(b

) 

(6)

(b

) 

(6)

(b) (6)
• 

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1111 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 72 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL470406 

3312G 

Date 

12JUN2018 

Description 

and pointed out the bird to him.  The maintenance 

.  After giving the 0300 set of USDA Food 

Inspector breaks an additional Good Commercial Practice 

Verification Task was done due to seeing an increase in cadavers 

on the line. 

(b) (6)

and an 

establishment maintenance worker were present during the 

following observation.  At approximately 0338 on June 12, 2018 

on evisceration line one near the entrance to the scald vat a live 

bird with no cut to the neck was observed that was “chirping”, 

blinking, flapping its wings, looking from side to side and alert. 

It had its head lifted and by-passed both of the establishments 

head pullers.  I immediately got the attention of 

(b) (6)

was notified of my 

observations immediately and that a GCP MOI would be 

documented and in turn notified 

(b) (6)

At approximately 2356 hours on June 11, 2018 while 

performing the Good Commercial Practices and Ante Mortem 

task, the following was observed at the entrance to the scald vat 

that feeds evisceration line two.  A live bird that had a small 

superficial cut to the neck that did not penetrate any major 

vasculature was observed entering the scald vat.  This bird was 

relatively small compared to the average size of the other birds 

in the lot.  The bird had its head retracted very close to its body 

by-passing both of the head pullers.  The bird turned its head 

around and attempted to bite/peck while on the line.  The bird 

was rhythmically breathing, lowering and then retracting its 

head, flapping its wings and blinking.  500 bird verification was 

done immediately afterwards and four additional live birds were 

present on the picking line (line two).  One bird had a cut to the 

right eye only, one bird was hung by one leg and had a cut to 

the back side of its head and two birds had cuts to their beak 

tips.  These birds were all flapping their wings, lifting their 

heads, blinking and rhythmically breathing.  No major 

vasculature was penetrated on any of these four birds, they all 

by-passed the first head puller but were decapitated by the 

second head puller prior to entering the scald vat and thus did 

not enter the scald vat live.  An additional 500 bird verification 

was done immediately following these observations and no 

additional live birds were observed on the evisceration line or 

entering the scald vat.  A supervisor could not be located for 

notification that was over live hang or the kill area. 

(b) 

(6)
 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 73 

EstNbr EstName Task_Code MOI# Date Description 

worker who was shown the bird as well then ran to the entrance 

to the scald vat and attempted to remove the bird.  The bird was 

submerged into the scald vat before the establishment 

employee was able to remove the bird from the shackle.  He 

then brought the bird over to 

(b) (6)

.  The bird 

remained unconscious for several moments before regaining 

consciousness.  The bird was later returned to production.  An 

additional 500 bird verification was done and no additional live 

birds were seen entering the scald vat.  A brief meeting was held 

with 

(b) (6)

to discuss these observations, 

cadavers and to inform him that this bird would be added to the 

GCP MOI from earlier in the shift. 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.  Live bird(s) entering the scald system live 

is a less than Good Commercial Practices and results in 

adulterated product. 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 12, 2018 

Cc: Dr. David Thompson, DDM 

(b

) 

(6)

(b

) 

(6)

(b) (6)
 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 74 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL021906 

3617G 

Date 

17JUN2018 

Description 

On June 15, 2018 at approximately 0127 during a Good 

Commercial Practice / Ante-Mortem Verification task the 

following was observed by 

(b) (6)

at the 

entrance to the scald vat that feeds evisceration line one.  A 

relatively small bird (compared to the remainder of the lot) was 

observed on the line blinking, flapping its wings, moving its head 

from side to side and lifting its head.  It lifted its head over both 

of the head pullers and went into the scald vat live; there was a 

superficial cut on the neck that was ineffective.  A few moments 

later the live hang lead came to the area with a radio and was 

asked to please radio 

(b) (6)

with 

my observations and that a GCP MOI would be documented; 

later this was followed up in person by giving notification to 

First Processing 

(b) (6)

.  Immediately 

following the above observations a 500 bird verification was 

done and no other birds were seen entering the scald vat alive. 

The establishment is responsible for ensuring that birds under 

their control on the official premises are treated in accordance 

with good commercial practices and in a manner that will 

minimize excitement, discomfort, injury and/or death by means 

other than slaughter.  Live bird(s) entering the scald system live 

is a less than Good Commercial Practices and results in 

adulterated product. 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 15, 2018 

Cc: Dr. David Thompson, DDM 

(b

) 

(6)

(b

) 

(6)

(b) (6)
 

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 75 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL170206 

2618G 

Date 

18JUN2018 

Description 

On the shift of June 17, 2018 at approximately 0136 during a 

Good Commercial Practice (GCP) and ante mortem task at the 

entrance to the scald vat that feeds evisceration line one the 

following was observed.  A bird that was smaller than the 

average size bird in the lot had its head retracted and bypassed 

both of the head pullers, it was blinking, turning its head from 

side to side and flapping its wings.  It was breathing and entered 

the scald vat alive.  Immediately following these observations a 

500 bird verification was done and no additional birds were 

seen entering the scald vat alive. 

was informed of these observations and that 

(b) (6)

they would be documented in a GCP MOI. The establishment is 

responsible for ensuring that birds under their control on the 

official premises are treated in accordance with good 

commercial practices and in a manner that will minimize 

excitement, discomfort, injury and/or death by means other 

than slaughter.  Live bird(s) entering the scald system live is a 

less than Good Commercial Practices and results in adulterated 

product. 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 in accordance with 

Good Commercial Practices 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 17, 2018 

Cc: Dr. David Thompson, DDM 

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

(b) (6)
 

- ■ 

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 76 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL062306 

5019G 

Date 

19JUN2018 

Description 

On the shift of June 19, 2018 at approximately 2207 during a 

Good Commercial Practice (GCP) and ante mortem task at the 

entrance to the scald vat that feeds evisceration line two the 

following was observed.  A bird that was smaller than the 

average size bird in the lot had a superficial cut to its neck, the 

first head puller on the line was blocked with heads and it 

retracted its head bypassing the second head pullers, it was 

blinking, turning its head from side to side and flapping its 

wings.  It was breathing and entered the scald vat alive. 

Immediately following these observations a 500 bird verification 

was done and no additional birds were seen entering the scald 

vat alive. 

(b) (6)

was informed of 

these observations and that they would be documented in a 

GCP MOI.  The establishment is responsible for ensuring that 

birds under their control on the official premises are treated in 

accordance with good commercial practices and in a manner 

that will minimize excitement, discomfort, injury and/or death 

by means other than slaughter.  Live bird(s) entering the scald 

system live is a less than Good Commercial Practices and results 

in adulterated product. 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 in 

accordance with Good Commercial Practices 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 20, 2018 

Cc: Dr. Larry Davis, DM Dr. David 

Thompson, DDM 

(b

) (b) (6)

(b) (6)

(6)
 

- ■ 

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 77 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL420206 

4819G 

Date 

19JUN2018 

Description 

On the shift of June 18, 2018 at approximately 0139 during a 

Good Commercial Practice (GCP) and ante mortem task at the 

entrance to the scald vat that feeds evisceration line one the 

following was observed.  A bird that was smaller than the 

average size bird in the lot had the back of its head skinned and 

retracted its head bypassing both of the head pullers, it was 

blinking, turning its head from side to side and flapping its 

wings.  It was breathing and entered the scald vat alive. 

Immediately following these observations a 500 bird verification 

was done and no additional birds were seen entering the scald 

vat alive. 

(b) (6)

was informed of 

these observations and that they would be documented in a 

GCP MOI. The establishment is responsible for ensuring that 

birds under their control on the official premises are treated in 

accordance with good commercial practices and in a manner 

that will minimize excitement, discomfort, injury and/or death 

by means other than slaughter.  Live bird(s) entering the scald 

system live is a less than Good Commercial Practices and results 

in adulterated product. 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 in 

accordance with Good Commercial Practices 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 19, 2018 

Cc: Dr. Larry Davis, DM Dr. David 

Thompson, DDM 

(b

) (b) (6)

(b) (6)

(6)
 

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 78 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL330406 

3821G 

Date 

21JUN2018 

Description 

On the shift of June 20, 2018 at approximately 2210 during a 

Good Commercial Practice (GCP) and ante mortem task at the 

entrance to the scald vat that feeds evisceration line one the 

following was observed.  A bird that was smaller than the 

average size bird in the lot had a superficial cut to its neck, it 

retracted its head bypassing both of the establishments head 

pullers, and it was blinking, turning its head from side to side 

and flapping its wings.  It was breathing and entered the scald 

vat alive.  Several minutes after making this observation, a 500 

bird verification was done.  At approximately 2220 a larger sized 

bird with a superficial cut to the lateral most aspect of the neck 

was observed on the line that feeds evisceration line two that 

was blinking, lifting and turning its head, flapping its wings and 

breathing.  It retracted its head over both of the head pullers 

and entered the scald vat alive.  Immediately following this 

observation an additional 500 bird verification was done and no 

additional birds were seen entering the scald vat alive.  A Live 

Shackle Lead with a radio was found and was informed of these 

observations and that they would be documented in a GCP 

MOI. 

.  The establishment is

Later in the shift the above was discussed with 

(b) (6)

responsible for ensuring that birds under their control on the 

official premises are treated in accordance with good 

commercial practices and in a manner that will minimize 

excitement, discomfort, injury and/or death by means other 

than slaughter.  Live bird(s) entering the scald system live is a 

less than Good Commercial Practices and results in adulterated 

product. 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 in accordance with 

Good Commercial Practices 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 21, 2018 

Cc: Dr. Larry Davis, DM Dr. David Thompson, DDM 

(b) (6)

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

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 79 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL062306 

3725G 

Date 

25JUN2018 

Description 

On the shift of June 25, 2018 at approximately 2209 during a 

Good Commercial Practice (GCP) and ante mortem task at the 

entrance to the scald vat that feeds evisceration line two the 

following was observed.  A bird that had a superficial cut to its 

neck, it retracted its head bypassing both of the establishments 

head pullers, and it was blinking, lifting its head and flapping its 

wings.  It was breathing and entered the scald vat alive. 

Immediately following this observation a 500 bird verification 

was done and no additional birds were seen entering the scald 

vat alive.  A

(b) (6)

 was informed of 

these observations and that they would be documented in a 

GCP MOI.  Later in the shift the above was discussed with Third 

Shift 

(b) (6)

.  The establishment is 

responsible for ensuring that birds under their control on the 

official premises are treated in accordance with good 

commercial practices and in a manner that will minimize 

excitement, discomfort, injury and/or death by means other 

than slaughter.  Live bird(s) entering the scald system live is a 

less than Good Commercial Practices and results in adulterated 

product. 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 in accordance with 

Good Commercial Practices 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 26, 2018 

Cc: Dr. Larry Davis, DM Dr. David Thompson, DDM 

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 80 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL221907 

0612G 

Date 

12JUL2018 

Description 

On the shift of July 11, 2018 at approximately 0358 during a 

Good Commercial Practice (GCP) and ante mortem task at the 

entrance to the scald vat that feeds evisceration line one the 

following was observed.  A bird that had a cut to only one side 

of the neck, very low, near the base of the beak, was blinking, 

lifting its head and flapping its wings.  It lifted its head over both 

of the establishments head pullers.  There is now an 

establishment employee stationed by the entrance to the scald 

vats to monitor for live birds and operate the on/off switch for 

the lines, he had previously asked that I would hold up one 

finger or two fingers to indicate if I saw a live bird on either line 

and which line it was.  Once I observed the live bird by-pass the 

last head puller and the establishment employee did not notice 

the bird to be able to intervene I held up one finger just prior to 

the bird entering the scald vat.  The employee stopped the line. 

Upon closer examination of the bird it was still blinking, 

flapping, lifting its head, rhythmically breathing and responsive 

to touch (the line was stopped at this time).  I confirmed to the 

establishment employee that a live bird was on the line.  A few 

minutes later the Live Receiving / Live Shackle Lead came to the 

area, removed the bird from the line, humanely euthanized and 

condemned the bird.  Once 

arrived the above observations were told to him and he was 

notified that these observations would be documented in a GCP 

MOI because without USDA intervention the bird would have 

entered the scald vat alive.  Immediately following 

notification / the line restarting a 500 bird verification was done 

and no additional birds were seen entering the scald vat alive. 

Later in the shift the above was discussed with Third Shift 

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

.  The establishment is 

responsible for ensuring that birds under their control on the 

official premises are treated in accordance with good 

commercial practices and in a manner that will minimize 

excitement, discomfort, injury and/or death by means other 

than slaughter.  Live bird(s) entering the scald system live is a 

less than Good Commercial Practices and results in adulterated 

product. 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 in accordance with 
 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 81 

EstNbr EstName Task_Code MOI# Date Description 

Good Commercial Practices 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 12, 2018 

Cc: Dr. David Thompson, DDM 

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

(b) (6)
-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 82 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL252207 

1213G 

Date 

13JUL2018 

Description 

and notification was given that it 

would be documented in a GCP MOI.  The establishment is 

responsible for ensuring that birds under their control on the 

official premises are treated in accordance with good 

commercial practices and in a manner that will minimize 

excitement, discomfort, injury and/or death by means other 

than slaughter.  Live bird(s) entering the scald system live is a 

less than Good Commercial Practices and results in adulterated 

product. 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 in accordance with 

Good Commercial Practices 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. 

On the shift of July 12, 2018 at approximately 2256 during a 

Good Commercial Practice (GCP) and ante mortem task at the 

entrance to the scald vat that feeds evisceration line two the 

following was observed.  A bird that was much smaller than the 

average size bird in the remainder of the lot had a cut to only 

one side of the neck, very low, near the base of the beak, was 

blinking, lifting its head and flapping its wings.  It lifted its head 

over both of the establishments head pullers.  Once I observed 

the live bird by-pass the last head puller and the establishment 

employee did not notice the bird to be able to intervene that is 

stationed by the entrance to the scald vats where the on/off 

buttons are for the lines I held up two fingers just prior to the 

bird entering the scald vat.  The employee stopped the line. 

Upon closer examination of the bird it was still blinking, 

flapping, lifting its head, rhythmically breathing and responsive 

to touch.  I confirmed to the establishment employee that a live 

bird was on the line and asked if he could please radio a 

supervisor for me.  A few minutes later the Live Receiving / Live 

Shackle Lead came to the area, removed the bird from the line, 

humanely euthanized it and condemned the bird.  The line was 

restarted and a 500 bird verification was done and no additional 

birds were seen entering the scald vat alive. The above 

observations were then discussed with 

(b) (6)
 

 

■ 

■■ 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 83 

EstNbr EstName Task_Code MOI# Date Description 

Respectfully submitted on July 13, 2018 

Cc: Dr. Larry Davis, DM Dr. David Thompson, DDM 

(b) (6) (b

) 

(6)

(b) (6)

P20245 Equity Group 

Kentucky 

Division, LLC 

04C05 ISL002108 

1620G 

20AUG2018 

was notified once the verification was complete that a 

GCP MOI would be documented. 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.  Live bird(s) entering the scald system live 

is a less than Good Commercial Practices and results in 

adulterated product. 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 in accordance 

with Good Commercial Practices 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 August 20, 2018 

On the shift of August 19, 2018 at approximately 0137 while 

performing the Good Commercial Practices and Ante Mortem 

task for a recent lot change, the following was observed at the 

entrance to the scald vat that feeds evisceration line two.  A live 

bird was observed that was blinking, rhythmically breathing, 

moving / turning its head and flapping its wings; the bird had 

retracted its head over the first head puller on the line and then 

lifted its head up and over the second head puller that was on 

the line. As the bird was about to enter the scald vat I held up 

two fingers, as I had been previously been asked to do by the 

establishment, to indicate that there was a live bird present on 

line two that was about to enter the scald vat.  Line two did not 

immediately come to a stop, and the live bird entered the scald 

vat. 

(b) (6)

came to the area and 

was informed of the observations.  500 bird verification was 

done immediately afterwards and no other live birds were 

observed entering the scald vat. 

(b) (6)

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

Cc: Dr. David Thompson, DDM Dr. 

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 84 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL542008 

4422G 

Date 

22AUG2018 

Description 

On the shift of August 22, 2018 at approximately 2018 while 

performing the Good Commercial Practices and Ante Mortem 

task close to the start of operations, the following was observed 

in live hang at the end of the belt that feeds evisceration line 

two.  There was a large live bird that was trapped at the end of 

the belt, its head and neck were stuck under a metal guard bar 

and its head was sticking through under the guard bar to the 

opposite side of the belt.  There was no one tending to the birds 

or a supervisor in the area when I approached.  The birds head 

was covered in blood and I used my flashlight to examine it 

closer.  I gently touched the bird just behind the eye to 

determine if it was responsive and it began blinking and 

attempted to free itself but could not.  The bird was wedged 

tightly under the bar and had an additional dead on arrival large 

bird compressing it further against an additional metal plate at 

the end of the belt; the belt was continually running, pressing 

the bird further into the metal guard and the metal plate at the 

end of the belt.  Upon closer examination with the flashlight the 

bird was completely skinned from the base of the beak to mid 

breast level, all vasculature and the crop was out and exposed. 

The wound was fresh with bright red frank blood.  The bird was 

removed from the belt and humanely euthanized under USDA 

guidance when an establishment employee and supervision 

were located.  I informed 

(b) (6)

of 

my observations and showed him the location where the bird 

was injured that contained fresh blood and feathers all along 

the edges. 

(b) (6)

was informed that this would be 

documented in a GCP MOI; birds being observed with their 

necks and even part of their breast skinned has been discussed 

previously with management in several past weekly HACCP 

meetings. At approximately 0330 while performing an 

additional Good Commercial Practices and Ante Mortem task at 

the entrance to the scald vats due to a recent lot change the 

following was observed at the entrance of the scald vat that 

feeds evisceration line two.  A much smaller bird than the 

average bird in the remainder of the lot was observed on line 

blinking, lifting its head, flapping vigorously and rhythmically 

breathing.  It lifted its head over both on-line head pullers, after 

by-passing the second head puller the establishment employee 

stationed in that location gently looked at the birds neck with 

one hand with the line in motion and then released the bird as it 
 

•■ 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 85 

EstNbr EstName Task_Code MOI# Date Description 

continued to approach the scald vat entrance.  I then held up 

two fingers, as I had been previously asked to do by the 

establishment, to indicate that there was a live bird on line two. 

The bird continued to flap its wings and lift its head as it entered 

the scald vat demonstrating signs of life and sensibility.  The line 

was not stopped until the bird had already entered the scald 

vat. 

(b) (6)

came to the area and 

was informed of my observations.  The bird was located in the 

scald vat and removed.  The bird was now deceased from 

drowning and was examined closer; there was a cut to the neck 

that did not penetrate the major vasculature needed for proper 

exsanguination and slaughter.  A 500 bird verification check was 

done as soon as the line was restarted and no other live birds 

were seen entering the scald vat.  Once the verification was 

complete 

(b) (6)

was given notification that my 

observations would be added to the GCP MOI that was 

discussed previously in the shift. 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. Live bird(s) entering the scald system live 

is a less than Good Commercial Practices and results in 

adulterated product. 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 in accordance 

with Good Commercial Practices 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 August 23, 2018 

Cc: Dr. David Thompson, DDM 

(b

) 

(6)

(b

) 

(6)

(b) (6)
1111 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 86 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL440209 

1307G 

Date 

07SEP2018 

Description 

came to the area and was informed of my observations. 

The bird was located in the scald vat, removed, examined closer 

and then condemned.  The bird was now deceased from 

drowning and was examined closer; there was a cut to the 

center portion of the neck that did not penetrate the major 

vasculature running along the lateral aspect of the neck needed 

for proper exsanguination and slaughter. A 500 bird verification 

check was done as soon as the line was restarted and no other 

live birds were seen entering the scald vat. Notification was 

given that my observations would be documented in a GCP 

MOI. While giving the 0300 set of USDA Food Inspector breaks 

an increased number of cadavers were seen on the evisceration 

line and I was informed by the Food Inspectors that they had 

just started to see an increase in cadavers.  After completing 

USDA Food Inspector breaks an additional Good Commercial 

Practices verification task was done at the entrance to the scald 

vats.  At approximately 0327 at the entrance to the scald vat 

that feeds evisceration line one a live bird was observed that 

was blinking, moving its head from side to side, attempting to 

right itself, flapping vigorously and rhythmically breathing.  This 

bird had lifted its head over both head pullers and went by 

unnoticed by the establishment employee stationed in the 

position to stop the lines for live birds.  After bypassing the 

second head puller and approaching the scald vat I held up one 

finger to indicate there was a live bird on line one.  The line got 

stopped just prior to the bird entering the scald vat.  The bird 

On the shift of September 6, 2018 at approximately 2038 while 

performing the Good Commercial Practices and Ante Mortem 

task, the following was observed at the entrance to the scald 

vats.  At the entrance to the scald vat that feeds evisceration line 

one a live bird was observed blinking, lifting its head, attempting 

to right itself, flapping vigorously and rhythmically breathing.  It 

lifted its head over both on-line head pullers, after by-passing 

the second head puller the establishment employee stationed in 

that location did not stop the line to prevent it from entering 

the scald vat.  I then held up one finger, as I had been previously 

asked to do by the establishment, to indicate that there was a 

live bird on line one, just prior to the bird entering the scald vat. 

The bird continued to flap its wings and lift its head as it entered 

the scald vat alive.  The line was not stopped until the bird had 

already entered the scald vat. 

(b) (6)
 ■ 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 87 

EstNbr EstName Task_Code MOI# Date Description 

continued to flap its wings and try to right itself as I approached 

for a closer examination.  When I placed my hand on the bird’s 

chest it was taking deep, rhythmic breaths and had a strong 

heartbeat.  The bird had a cut to the side of the head that did 

not penetrate the neck at all and thus not penetrating any 

major vasculature needed for proper exsanguination and 

to remove the bird from the line and take it out of production. 

Supervisor Groce was given immediate verbal notification that 

my observations would be documented in a GCP MOI.  Once the 

line was restarted a 500 bird verification check was done and no 

other live birds were observed entering the scald vat. 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. Live bird(s) entering the scald 

system live is a less than Good Commercial Practices and results 

in adulterated product. 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 in 

accordance with Good Commercial Practices 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 7, 2018 

slaughter. 

(b) (6)

came to the area 

Cc: Dr. David Thompson, DDM 

Dr. Larry Davis, 

(b) (6)(b

) 

(6)

(b) (6)

DM 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 88 

EstNbr EstName Task_Code MOI# Date Description 

P20245 Equity Group 

Kentucky 

Division, LLC 

04C05 ISL481909 

3917G 

17SEP2018 On the shift of September 16, 2018 at approximately 0345 

while performing the Good Commercial Practices and Ante 

Mortem task, the following was observed at the entrance to the 

scald vats.  At the entrance to the scald vat that feeds 

evisceration line one a live bird was observed blinking, lifting its 

head, attempting to right itself, flapping vigorously and 

rhythmically breathing.  It lifted its head over both on-line head 

pullers, after by-passing the second head puller the 

establishment employee stationed in that location did not stop 

the line to prevent it from entering the scald vat.  I then held up 

one finger, as I had been previously asked to do by the 

establishment, to indicate that there was a live bird on line one, 

just prior to the bird entering the scald vat.  The establishment 

employee stopped line one.  Upon closer examination the bird 

was responsive, rhythmically breathing and had a cut to the side 

of the head; there was no cut penetrating the major vasculature 

of the neck needed for proper exsanguination and slaughter. 

The employee removed the live bird from the line; it was 

euthanized several minutes later and condemned.  A 500 bird 

verification check was started as soon as the line was restarted 

and at approximately 0347 an additional live bird was observed 

on the same line that appeared in the exact manner as the one 

described above (flapping vigorously, blinking and trying to right 

itself).  After the signal was given to the establishment employee 

to stop the line just prior to entering the scald vat it took some 

additional time to approach the bird for a closer examination 

due to the floor being slick and an open drain.  On closer 

examination the bird was still breathing; this bird also had a cut 

to the side of the head not penetrating any major vasculature. 

The live shackle lead came to the area to remove the bird from 

the line and at that time the bird was taking agonal breaths. 

The bird was removed, euthanized and condemned.  An 

additional 500 bird verification check was done once the line 

was restarted and at approximately 0350 there was a third live 

bird that had a cut to the side of the head, none to the neck, 

that did not require USDA intervention that the establishment 

removed from the line prior to entering the scald vat live.  Once 

the line was restarted an additional verification was restarted 

and approximately one minute into the verification the line was 

stopped due to mechanical issues and USDA was informed that 

the line would be down for a prolonged time and verification 
 ■ 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 89 

did not get to get completed prior to the end of the shift.

 Notification was given to 

that my observations would be documented in a GCP MOI. The 

(b) (6)

EstNbr EstName Task_Code MOI# Date Description 

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. Live bird(s) entering the scald 

system live is a less than Good Commercial Practices and results 

in adulterated product. 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 in 

accordance with Good Commercial Practices 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 17, 2018

 Cc: Dr. David Thompson, DDM 

Dr. Larry Davis, 

(b) (6)(b

) 

(6)

(b) (6)

DM 
 

-

-

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 90 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL270209 

5720G 

Date 

20SEP2018 

Description 

was notified after each 

observation and that they would be documented in a GCP 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 in accordance with 

Good Commercial Practices 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 

Thompson, DDM 

Dr. Larry Davis, DM

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

(b) (6)

September 20, 2018 Cc: Dr. David 

On the shift of September 19, 2018 while performing the Good 

Commercial Practices (GCP) and Ante Mortem task, the 

following was observed at the entrance to the scald vats: At 

the entrance to the scald vat that feeds evisceration line one at 

approximately 2008 I observed one live bird enter the scald vat 

that was blinking its eye, arching its neck and turning its head 

from side to side.  The cut on the bird appeared to be low to the 

beak base, towards the eye and superficial.  At approximately 

2218 I observed one live bird enter the scald vat that feeds 

evisceration line one that was blinking its eyes, attempting to 

right itself and flapping its wings vigorously.  At approximately 

0144 I observed one live bird enter the scald vat that feeds 

evisceration line one that was blinking its eyes, arching its neck; 

it lifted its head over the head pullers and turning its head from 

side to side.  The cut to this bird appeared the same as the first 

bird observed entering the scald vat.  At approximately 0146 I 

observed an additional live bird enter the scald vat that feeds 

evisceration line one that appeared in the exact manner as the 

one observed at approximately 0144. 

(b) (6)
 

 

• 

-

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 91 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL202109 

5923G 

Date 

23SEP2018 

Description 

was notified that my 

observations would be documented in a GCP 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 in accordance with Good 

Commercial Practices 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 

Thompson, DDM 

Dr. Larry Davis, DM

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

(b) (6)

(b) (6)

September 24, 2018 Cc: Dr. David 

On the shift of September 23, 2018 while performing the Good 

Commercial Practices (GCP) and Ante Mortem task, the 

following was observed at the entrance to the scald vats: At 

the entrance to the scald vat that feeds evisceration line two at 

approximately 2032 I observed one live bird enter the scald vat 

that was blinking its eye, arching its neck and turning its head 

from side to side; it lifted its head over both of the 

establishments on-line head pullers.  The cut on the bird 

appeared to be high on the neck and superficial on the skin, the 

bird was much smaller than the average size bird in the lot. 

(b) 

(6)
 

-

-

-

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 92 

EstNbr EstName 

P20245 Equity Group 

Kentucky 

Division, LLC 

Task_Code 

04C05 

MOI# 

ISL421809 

1130G 

Date 

30SEP2018 

Description 

was notified that my observations would 

be documented in a GCP 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 in 

accordance with Good Commercial Practices 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. 

On September 27, 2018 while performing the Good Commercial 

Practices (GCP) and Ante Mortem task, the following was 

observed at the entrance to the scald vats: At the entrance to 

the scald vat that feeds evisceration line two at approximately 

0326 I observed one live bird enter the scald vat that was 

blinking its eye, arching its neck, flapping its wings and turning 

its head from side to side; it lifted its head over both of the 

establishments on-line head pullers.  The cut on the bird 

appeared to be superficial to the skin; the bird was much 

smaller than the average size bird in the lot.  At approximately 

0330 I observed a second live bird enter the scald vat that feeds 

evisceration line two.  This bird appeared exactly the same as 

the first bird that entered described above. 

(b) (6)

Respectfully submitted on September 28, 2018 

Cc: Dr. David 

Thompson, DDM 

Dr. Larry Davis, DM 

(b) (6)

(b) (6)(b) (6)
- • 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 93 

EstNbr EstName 

P20251 Tecumseh 

Poultry, LLC 

Task_Code 

04C05 

MOI# 

PBM30130 

60815G 

Date 

15JUN2018 

Description 

On 06/15/18, at approximately 0819 hours, while performing a 

routine Poultry Good Commercial Practice Verification task, I, 

(b) (6)

, observed one instance of bird 

mistreatment on a bottom module on a “veggie” trailer, 

numbered T-796 in the loafing shed. One chicken had its left 

foot caught between the floor board and the compartment 

door. The foot was broken where it was stuck and had bled a 

puddle of blood onto the compartment below. The puddle of 

blood was approximately 6 inches in diameter. The hemorrhage 

appeared to have stopped but the blood puddle was not dry. I 

met with 

(b) (6)

at 0823 hours to show 

her the mistreatment. She took images of the bird’s leg and 

asked the scale house personnel to release the bird. Once the 

bird was released, she had the bird humanely euthanized. 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. Sincerely, 

(b) 

(6)
-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 94 

EstNbr EstName 

P20251 Tecumseh 

Poultry, LLC 

Task_Code 

04C05 

MOI# 

PBM59130 

62418G 

Date 

18JUN2018 

Description 

On 06/14/18, at approximately 0913 hours, while performing a 

routine Poultry Good Commercial Practice Verification task, I, 

(b) (6)

, observed one instance of bird 

mistreatment on a “veggie” trailer, numbered T32 in the loafing 

shed. The top module had a compartment with a stuck bird. The 

bird’s left hock was pinched, in a space approximately 1 to 1.5 

cm, between the floor board and the metal bar of the 

compartment’s side, causing the distal part of this leg, starting 

from the hock, to be in the compartment below the bird. The 

toes and foot of the left leg were swollen and ischemic (purple 

in color). The shank of the bird was located between the floor 

board (on top of the leg) that the bird laid on and a metal beam 

from the compartment underneath. I observed the chicken 

attempted to move several times and was not able to remove its 

leg from this position. I met with 

(b) (6)

at 

0930 hours to show her the mistreatment. She stated that she 

would either have this trailer slaughtered first or ask for 

assistance from the scale house personnel to free this bird. 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. 

Sincerely, 

(b) (6)
-

-

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 95 

EstNbr EstName Task_Code MOI# Date Description 

P20251 Tecumseh 04C05 PBM55130 25JUL2018 

Poultry, LLC 73825G 

On 07/25/2018, at approximately 1139 hours, I, 

, met with to inform her of 

(b) (6)

(b) (6)

several instances of bird mistreatment that I had observed while 

performing a routine Poultry Good Commercial Practice 

Verification task. I informed her of the “veggie” trailer numbers 

with the birds that were stuck. On trailer T797, one bird had its 

left wing tip stuck and was not able to remove its wing from the 

position after several attempts. On trailer T325, one bird had its 

right paw stuck out of the module compartment and a small 

area of bloody abrasion was observed on the metatarsal pad. On 

trailer T323, 2 birds were stuck at the level of the tibia, 1 was 

stuck at the paw, and another one was stuck at the tibiotarsal 

level with an abrasive injury along the cranial aspect of its 

tibiotarsus. 

(b) (6)

stated that she would 

have the scale house operator look for these birds to release 

them.  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.  Sincerely, 

(b) (6)
-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 96 

EstNbr EstName 

P20251 Tecumseh 

Poultry, LLC 

Task_Code 

04C05 

MOI# 

PBM25150 

85921G 

Date 

21AUG2018 

Description 

On 08/21/18, at approximately 0603 hours, while performing a 

routine Poultry Good Commercial Practice Verification task, I, 

(b) (6)

, observed one instance of bird 

mistreatment on a top module on a "veggie" trailer in the 

loafing shed. One chicken had its right hock caught between the 

metal door and side bar, causing active hemorrhage that was 

seen dripping onto doors of the compartments below. Large 

areas of blood can be observed on five (5) of the doors of the 

compartments immediately below where the chicken was stuck. 

I alerted the establishment’s 

(b) (6)

to the 

mistreatment. She requested assistance from the scale house 

personnel and they were able to release the chicken’s leg from 

the door. 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. 

Sincerely, 

(b) (6)
-

-

- ■ 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 97 

EstNbr EstName 

P208 George's 

Processing, Inc. 

Task_Code 

04C05 

MOI# 

XIC272107 

4820G 

Date 

20JUL2018 

Description 

also informed me that he would hold a more formal 

meeting with live hang employees at a later time to address live 

bird handling and good commercial practices.  After the DOAs 

were cleared from the live hang floor and further measures 

(additional industrial fans) were implemented to help 

maintain bird viability in the live receiving area the live hang 

operations were resumed at approximately 1935 hours.  I noted 

that the fans and misters in the live receiving area which were 

being used to help cool the live birds in cages on the transport 

trailers appeared to be functioning properly.  As I monitored live 

hang operations I noted that the number of DOAs had greatly 

decreased and were not accumulating in large numbers on the 

live hang floor.  Establishment employee handling of live birds at 

this time was acceptable. 

of my concerns for the intermingling of 

live birds with dead birds and the inappropriate handling of live 

birds by plant employees. 

(b) (6)

immediately 

discontinued live hang operations to allow for the removal of 

DOAs from the area.  As I observed he also held a brief meeting 

with all establishment personnel who were working in the area 

to address the proper handling of live birds.  At that time 

(b) 

(6)

July 20, 2018, approximately 1900 hours; outside temperature 

96 degrees F.  While walking through the live hang area I 

observed too numerous to count (several hundred) DOA 

carcasses on the live hang floor at the end of the live hang belts. 

I also noticed that there were several live birds intermingled 

with the DOAs on the floor.  As I watched 

establishment personnel work to remove the DOAs from the live 

hang area I observed several of the employees handle live birds 

by the neck or wing and throw them several feet through the air 

to land on the live hang belts.  At this time I notified 

(b) (6)
-

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 98 

EstNbr EstName 

P208 George's 

Processing, Inc. 

Task_Code 

04C05 

MOI# 

XIC051309 

0704G 

Date 

04SEP2018 

Description 

At approximately 1202 hours while observing the poultry 

handling and slaughter process, I observed the following solitary 

instance of failure to adhere to the poultry good commercial 

practice requirements: I observed the dumper operator dump a 

coup of birds. After dumping a bird was left on the rollers at 

approximately the center of the dumper. As the bird was trying 

to walk on the rollers, the dumper operator rolled the next 

coup, hitting and pushing the bird to the very front of the 

dumper, smashing it against the front of the stop for the cages. I 

waved and yelled to get the dump operators attention and he 

came to that end, moved the coup back from the bird, and took 

the bird who had been walking fine previous but was now 

struggling to walk on the left leg and the right let was dangling 

and was obviously fractured and/or dislocated and placed it 

onto the live hang belt through the front of the dumper. I 

immediately went to 

(b) (6)

office and notified him of the 

issue and forthcoming MOI. I showed him what I had observed 

and where. He provided additional instruction to the dumper 

operator. I observed two other live birds on the ground, one 

below each dumper. At approximately 1215 hours, I met with 

(b) (6)

, and discussed my 

observations above. I stated an MOI would be generated 

because while there were issues with good commercial practices 

observed, this was a single solitary instance. I discussed with 

him that previous weekly meeting minutes show concerns over 

issues relating to dumping and birds being observed alive and 

dead below the dumpers. He stated 

(b) (6)

had already 

gotten with him and they were going to address it with those 

responsible for operating the dumper. 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 99 

EstNbr EstName 

P208 George's 

Processing, Inc. 

Task_Code 

04C05 

MOI# 

XIC041909 

1328G 

Date 

28SEP2018 

Description 

September 28, 2018 at approximately 1642 hours, while 

observing the scalding and picking process on Kill Line #2 I 

observed two consecutive live, conscious birds enter the scalder. 

The birds did not appear stunned and there was no evidence of 

a cut on the neck or head of either bird. Due to the height and 

speed of the line I was unable to safely remove the live birds 

from the kill line before they entered the scalder. I immediately 

observed the stun and kill operations for both kill lines and 

determined that the slaughter process was not out of control. I 

then notified 

who immediately investigated the incident and counseled the 

Kill Line #2 backup killer. I monitored scalding and picking 

operations on both kill lines for an additional 10 minutes and 

did not observe any more live birds enter the scalder.  At that 

time I notified 

(b) (6)

of my 

findings. Live poultry entering the scalder reflects poor 

commercial practices and is noncompliant with 9 CFR 381.65(b) 

which 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". 

(b) (6)
-

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 100 

EstNbr EstName Task_Code MOI# 

P21234 Perdue Foods 04C05 XGI041108 

LLC 4831G 

Date 

31AUG2018 

Description 

Perdue Foods P-21234 Date: 8/31/2018 Time:12:14PM While 

verifying Good Commercial Practices at approximately 11:26am 

in the poultry live bird receiving area, I observed the lifeless 

body of a bird underneath the 4th trailer parked in the shed. 

The bird's body was completely mangled, gut exposed and 

its head was missing. It is reasonably likely to conclude that the 

bird was ran over by one of the drivers and over looked. 

Yesterday,  I had verbally warned the designated driver for the 

day and the supervisor 

(b) (6)

that there was a live bird 

under the shed and to remove it before the trailer was pulled 

out. I placed a cone in front of the trailer, a practice 

that the previous 

(b) (6)

used, to remind the 

driver to get out and survey the area before pulling off. I 

reminded the supervisor to tell all of his drivers that this 

observation step should be taken every time before a 

driver pulls out a trailer from the shed. I verbally informed

 of what I had observed and told him that I 

would be documenting my findings in an MOI, due to the 

regulatory requirement 9 CFR 381.65, which states that live 

poultry should be handled in a manner that is consistent with 

good commercial practices. This MOI will be forwarded to my 

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

, the District Office, and the 

District Veterinary Medical Specialist in case additional 

follow-up is recommended. Respectfully, 

(b) (6)
■ 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 101 

EstNbr EstName Task_Code MOI# 

P21234 Perdue Foods 04C05 XGI010909 

LLC 3628G 

Date 

28SEP2018 

Description 

Perdue Foods P-21234 Date: 9/28/2018 Time: 10:01 AM 

While verifying Good Commercial Practices at approximately 

8:34 am, I observed a large opening on the side of one of the 

crates, sitting on cage dumper number 3. The crate was missing 

the metal barrier and the birds were all visually exposed and 

free to escape.  I immediately went to look for an attendant to 

let them know but could not find one. As I was walking back 

toward the cage dumper I saw that the operator had returned, 

and before I could tell him not to move the crate, I witnessed 

one of the birds get crushed by the cage dumper and fall to the 

ground. Also, at the same time, there was a bird that had 

escaped and was sitting on top of the same crate, and when the 

crate started to move, the jerking motion caused the bird to fall 

to the ground. The bird fell directly on its head and immediately 

started to show CNS signs (torticollis, falling/circling to the side, 

not being able to rise). The bird died less than a minute later. I 

reminded 

(b) (6)

that someone should always 

be outside to monitor the birds and make sure they are 

not freely moving around or through the machinery, or on the 

ground. I also verbally informed 

(b) (6)

of the 

mistreatment of the birds I had observed, and told him that I 

would be documenting my findings in an MOI. This MOI will be 

forwarded to my 

(b) (6)

, the 

District Office, and the District Veterinary Medical Specialist in 

case additional follow-up is recommended. Respectfully, 

(b

) 

(6)
-

-

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 102 

EstNbr EstName 

P218 Pilgrim's Pride 

Corporation 

Task_Code 

04C05 

MOI# 

WOD1122 

072323G 

Date 

23JUL2018 

Description 

On 7/23/2018, while performing the PHIS Good Commercial 

Practices task, I 

(b) (6)

observed the following 

conditions at Establishment P218, Pilgrim’s Pride in Lufkin, Tx. 

There were too numerous to count Dead on Arrival (DOA) birds 

entering the establishment. At the time of my observations 

establishment personnel were appropriately handling/sorting 

the dead birds and disposed of approximately nine yellow 

condemn barrels full of DOAs (over 300 birds). I proceeded to 

the outside back dock area where the birds are caged on truck 

trailers to verify that the fans and misters were all functioning 

properly. Upon inspection of the birds, there were multiple dead 

birds in the cages and the live birds could be seen panting 

excessively. With temperatures over 100 degrees for the day, 

the birds were dying of heat exhaustion. Although 

establishment management were handling the DOAs in a 

manner so as not to enter production and maintained process 

control this MOI is being documented because of the excessive 

amount of DOAs found at the establishment. Establishment 

management stated that the birds arrived from Hammock 

Farms and M&G Farms and that there was a total of 1500 DOAs. 

The establishment is reminded that it is important to treat 

poultry in a way that minimizes accidental injury and death 

prior to humane euthanasia. This includes the transportation, 

loading/unloading and storage of chicken before slaughter. 

Although, non-regulatory, USDA expects the establishment to 

employ handling methods consistent with Good Commercial 

Practices. Plant Management is asked to consider these USDA 

concerns and prevent future occurrences.  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 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 103 

EstNbr EstName 

P218 Pilgrim's Pride 

Corporation 

Task_Code 

04C05 

MOI# 

WOD3922 

090704G 

Date 

04SEP2018 

Description 

was called to the area and shown 

the trapped birds. Upon further inspection, two of the birds 

were deceased and one was weak but still alive. The birds had 

matted dirty feathers with generalized bruising on most of their 

bodies; it appeared that the birds had been stuck there for some 

time. 

(b) (6)

humanely euthanized the live bird and 

removed all three birds from the belt. Further inspection of the 

belt showed that there was a gap between the belt and a barrier 

that allowed the birds’ foot to get caught, trapping it 

underneath the belt. Maintenance was notified and installed a 

new board to cover the belt leaving no spaces for birds to get 

stuck. The belt was inspected and the dumping operations 

resumed at 1820 hours. Plant Management is asked to 

consider these USDA concerns of good handling practices 

particularly to the design/setup of the conveyor belt equipment 

as well as establish and implement effective preventive 

measures to avoid future occurrences. 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.  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 MOIs 

can be FOIA requested by individuals from the general public. 

Documented by 

On September 4, 2018 at approximately 1540 hours while 

performing a PHIS Poultry Good Commercial Practices 

task USDA 

(b) (6)

observed the following while 

outside at the establishment’s dumping operations. There were 

three birds stuck, each by one leg, underneath the conveyor belt 

at the junction where the two belts meet on line 2. Regulatory 

control was taken and the dumper operator was instructed to 

stop dumping live birds onto the belt. 

(b) (6)

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 104 

EstNbr EstName Task_Code MOI# Date Description 

P2186 GEORGE'S 04C05 YJO041307 31JUL2018 

FOODS, LLC 1131G 

Establishment P-2186, George’s Foods July 31, 2018, 12:00 

hours. In attendance: ; 

. At approximately 07:17 

(b) (6)(b) 

(6)

about these other two 

carcasses. I told him there must be some problem that needed 

immediate attention. Then I went to watch carcasses exiting the 

first picking machine to watch for any additional uncut 

carcasses that may have exited the scalder. I observed from 

on Tuesday, July 31, 2018, the Food Inspector on Evisceration 

Line 1, Station 1 called for me to show me a carcass she had 

held back. It was a cadaver with the head still intact on the 

carcass. The head and neck had a deep red color, and there was 

no cut on the neck. While I was examining this cadaver, the 

Food Inspector on Evisceration Line 2, Station 2 called for me 

and showed me a carcass that had just arrived at her inspection 

station. It was another cadaver, with the same appearance as 

the first. As I was exiting this area of the Evisceration 

Department with these two carcasses to show them to the Live 

Hang Supervisor or Lead and see if the slaughter process was 

under control, the Food Inspector on Line 2, Station 1 told me 

he had just condemned a carcass as a cadaver. I glanced in the 

condemn barrel at his station and saw that a red carcass was in 

the barrel. I continued to the 

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

area and showed the 

two uncut cadavers to the . He told me he 

would speak with the backup kill man. When had I returned to 

the Evisceration Department and placed the two cadavers into 

condemn barrels, I retrieved the cadaver from the barrel for Line 

2, Station 1 and found that this carcass, too, had no cut on the 

neck, the head was still on the carcass, and the head and neck 

were deep red. While I was placing this cadaver back into the 

condemn barrel, the Food Inspector on Line 2, Station 2 hung 

back a fourth cadaver with the same appearance as the other 

three. At this time, approximately 07:23, I returned to the 

(b) 

(6)

07:25 to 07:30 and did not see any more cadavers. I again 

spoke with 

(b) (6)

, and he told me that the carcasses in 

question had passed the kill machine and the backup kill man at 

the time when another employee was giving the regular backup 

kill man a relief break. 

(b) (6)

told me that for the rest of the 

shift, he would not have this employee give any more breaks. 

Rather, he himself would give the breaks. The fact that these 

birds were not cut means that the requirements of 9 CFR 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 105 

EstNbr EstName Task_Code MOI# Date Description 

381.65(b) were not met: "Poultry must be slaughtered in 

accordance with good commercial practices in a manner that 

will result in thorough bleeding of the carcasses and ensure that 

breathing has stopped prior to scalding. Blood from the killing 

operation must be confined to a relatively small area". Since 

none of these four birds had been cut, it is clear that they were 

not bled at all and that they entered the scalder still breathing. 

This is a serious concern. Humane handling is a critical factor of 

Good Commercial Practices, and all precautions should be taken 

by the establishment to adhere to such. Since this cluster of 

uncut birds appears to be an isolated incident, and it does not 

appear that there was an ongoing loss of process control, this 

incident will not be registered on a noncompliance record. 

However, the production of multiple uncut cadavers is 

unacceptable, and steps should be taken to prevent recurrence. 

I recommended to 

(b) (6)

that establishment 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 and provided him a copy of this document. 

confirmed that 

(b) (6)

gave the 

(b) (6)

remaining relief breaks to the backup kill man during the shift. 

He also told me that the situation would be addressed with the 

employee who was responsible for the incidence of uncut 

cadavers. A copy of this MOI will be sent to the Veterinary 

Medical Specialist at the Raleigh District Office. 

, P-2186 Harrisonburg, VA 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 106 

EstNbr EstName Task_Code MOI# 

P22000 Prestage Foods, 04C05 WOC14080 

Inc. 80806G 

Date 

06AUG2018 

Description 

observed one cadaver bird each while performing 

their post mortem inspection on line 1 and line 2. These 

carcasses were observed about 40 minutes apart with in the first 

two hours of start of slaughter operations. Food inspector

On August 3, 20118, Inspectors 

(b) (6)

(b) (6)

observed two cadaver carcasses during the shift. One of 

them had no knife cut on the neck and the other one had a 

miscut resulting in improper bleeding and condemned as 

cadaver. 

(b) (6)

observed another cadaver 

carcass later in the shift. This carcass also did not have a knife 

cut on the neck. His observations were the following. The skin 

was hyperemic leading to the bright cherry red color. Signs were 

consistent with a bird died other than slaughter. These 

carcasses were condemned as cadaver and 

was notified of these findings. Upon

(b) (6)

each notification 

(b) (6)

claimed to provide additional 

help and or additional supervision of kill machine area. I 

discussed establishment’s responsibility to follow Good 

Commercial Practices with 

(b) (6)

and advised him that 

preventing mistreatment of poultry decreases the production of 

adulterated carcasses. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 107 

EstNbr EstName Task_Code MOI# Date Description 

P2632 Pilgrims Pride 04C05 GAA51020 24AUG2018 

Corporation 80024G 

Establishment P-2632, Pilgrims, August 23, 2018, 1315 hours. In 

attendance: ; 

; ; 

; 

; ; 

; At approximately 

0520 hours shortly after the start of the shift, I was walking 

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

(b) (6)

(b) (6)

(b) (6)

(b) (6)

of having gone through the killer machine or in front of the 

backup killer. I immediately pointed this out to 

and directed him to stop the 

hanging process. I applied tag# B42 065016 to the live area. The 

(b) (6)

alongside the evisceration lines and observed several birds (too 

numerous to count) on line 1 at the auto rehanged area with 

heads still attached to the body, dark red in color,  and no signs 

CSIs that were also present when I observed this, took a total of 

34 birds off the line and the establishment employees took an 

unknown number of birds with the same presentation off the 

line. The cause of this was that the stunner was not adjusted to 

the height of the birds. The birds were not being stunned as 

they were passing through the stunner. Some were killed via the 

killer machine, back up killer, and some not at all. The backup 

killer failed to stop operations when he observed this out of 

control situation. Management stated that they will retrain 

their personnel on Animal Welfare and some will have 

disciplinary action taken against them. I reminded the 

establishment management that the PPIA and Agency 

regulations require that live poultry be handled in a manner that 

is consistent with good commercial practices and that they not 

die from causes other than slaughter. I recommended that they 

review the Federal Register Notice Vol. 70, No. 187, published 

September 2005 [Docket No. 04-037N] for FSIS 

recommendations concerning treatment of live poultry during 

slaughter and confirmed that they were familiar with this 

document. I notified management officials 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, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 108 

EstNbr EstName 

P2882 Perdue Foods 

LLC 

P308 Koch Foods of 

Mississippi LLC 

Task_Code 

04C05 

04C05 

MOI# 

VYF321708 

0520G 

SPL551408 

0931G 

Date 

20AUG2018 

31AUG2018 

Description 

On August 20, 2018 at approximately 1153 hours I was 

performing a Good Commercial Practices task outside loading 

area for slaughter.  I noticed a bird that appeared to have its 

feathers and skin partially removed on its back beside the 

conveyor. I talked to the employee managing the conveyer and 

they stated that this bird had been dragged under the loader 

machine and was placed on the side until an employee could 

euthanize him. When asked why the bird has not been 

euthanized according to the establishment’s procedures, the 

employee stated that he was not sure how to euthanize the bird 

and was afraid of performing it incorrectly. A plant employee 

euthanizes the bird in my presence. 

was notified about the incident. This 

(b) (6)

observation is an isolated poultry mistreatment event and no 

other observations have been noted after reviewing records. 

P-308 Koch Foods of Mississippi LLC Dear 

(b) (6) , 

Today at approximately 0642 hour, I observed a Good 

Commercial Practice failure at the large bird DOA bin. While 

performing portions of a routine Good Commercial Practice 

check in the live hang area, I observed a pile of DOAs inside the 

large bird DOA catch bin just past the conveyor. Upon further 

observations, I observed a live bird commingled in with the 

DOAs. The bird was still breathing and could have been in 

imminent danger of suffocating had the DOA conveyor belt 

been turned on. This occurred on the big bird side along the 

north side of the holding shed. I asked the team member 

to come remove the bird from the bin. I 

informed the and 

of the good commercial practice 

(b) (6)(b) 

(6) (b) (6)

issue. My observation leads me to conclude that had I not 

observed, discovered, or otherwise intervened, it is reasonable 

to conclude that the bird would have been crushed or 

suffocated and as such died by means other than slaughter. It 

has been discussed with management previously about the 

concerns of the treatment and conditions relative to the 

establishment handling of birds. 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 109 

EstNbr EstName 

P32182 Sanderson 

Farms, Inc. 

Task_Code 

04C05 

MOI# 

DZL431606 

5012G 

Date 

12JUN2018 

Description 

Approximately at 2120 hours on 6/08/18, I 

along with 

(b) (6)

, observed in the picking room 

there was an excessive amount of paws on the floor. Paws 

where dropping from the paw line, and the paw belt where 

backed up causing the paw line to not operate properly which 

caused the operation to be out of control. 

Infante and 

(b) (6)

was notified of these findings. After speaking with the

(b) (6)

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

 about this issue 

being out of control and to stop the paw line he stated that he 

could not stop the paw line and continued letting the paw line 

run as the paws continuously piled up excessively on the floor. 

An Employee of 

(b) (6)

came and tried to 

help address the problem right away. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 110 

EstNbr EstName Task_Code MOI# 

P325 Tyson Foods, 04C05 YDM44000 

Inc. 82903G 

Date 

03AUG2018 

Description 

while checking for additional birds in the bin; she had a 

live hang employee empty the barrel to ensure there were no 

birds at the bottom of the barrel. 

(b) (6)

stated the barrel 

was there to catch litter.  There were no additional birds found 

in the condemn bin.  The live birds were removed from the DOA 

bin and the dead birds were removed and the heads were 

removed.  Preventive measures were to keep an additional 

person on the floor in order to monitor the DOA bins for the rest 

of the week.  The area was released when process control was 

regained. The establishment is asked to ensure establishment 

employees handling live animals are aware of the requirements 

to check all animals for life before they are condemned as dead. 

Employing humane methods of handling consistent with Good 

Commercial Practices can help produce an unadulterated 

product.  Copies of this Memorandum of interview will be 

asked the Live Hang Supervisor to remove the birds 

and check the other side of the line), a yellow condemn barrel 

was inside of the large metal DOA bin located at the end of the 

Live Hang belt.  A live bird was observed laying on top of the 

yellow condemn barrel on its' back.  The metal DOA bin was not 

full, but employees were observed to be picking birds off of the 

floor and tossing them into the bin without checking them for 

life. 

(b) (6)

accompanied 

to the area and observed the conditions.  When the bird was 

observed in the condemn barrel, regulatory control action was 

taken and both lines were stopped to allow the plant to regain 

process control in the area. 

(b) (6)

also expressed concern 

with the level of noise in the Live Hang Department.  The radio 

was on and the music was playing very loudly.  She stated that 

loud music can be a distraction which can lead to the creation 

of conditions such as those observed tonight. 

provided corrective actions stating that he would sort the birds 

in the DOA bin.  The live bird in the DOA bin was removed by 

(b

) 

(6)

On August 1, 2018 at approximately 2145 hours while 

conducting a GCP task, 

(b) (6)

observed the 

following conditions in the Live Hang department.  One live bird 

was observed in the plastic sheeting on the side of the dump 

belt at the entry to the live hang area (where the DOA monitor 

is usually located). 

(b) (6)

removed the bird.  Two additional 

birds were observed wedged beneath the stairstep at the last 

hanging station at the entry to the live hang department 

(b) (6)

(b) (6) (b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 111 

EstNbr EstName 

P34308 Sanderson 

Farms, Inc. 

Task_Code 

04C05 

MOI# 

PHY031006 

3114G 

Date 

14JUN2018 

Description 

distributed to the establishment, inspection file and the District 

Veterinary Medical Specialist per FSIS Directive 6100.3.  The 

issue will also be discussed at the next weekly meeting. 

On Wednesday June 13, 2018 at approximately 1100 hours I

 of my observation. Hanging the birds incorrectly 

can cause death injury or prevent thorough bleeding or result in 

excessive bruising.  My observation was also verbally brought 

management personnel at the week management and USDA 

meeting that afternoon.  Management was verbally notified 

of my findings.  He then made any necessary 

adjustments to the kill line 2 machine.  After the adjustment I 

observed 10 mis cuts in 3 minutes.  During this time, I also 

observed the backup cutters chasing down birds that had been 

hung incorrectly in the shackle, and once rehung correctly then 

proceeding to cut the jugular vein in the neck. At 1220 hours 

the miscuts for kill line 2 had decreased to 9 in three minutes 

and 10 seconds.  At this time, I entered the live hang area and I 

observes numerous employees hanging for kill line two hanging 

birds incorrectly in the shackle.  I informed 

(b) (6)

(b) (6)

observed the following in “hot” rehang 

area while observing the establishment operating process.  I 

observed TNTC whole carcasses on the floor in the “hot” rehang 

area and the rehang table that feeds evisceration lines three and 

four had carcasses piled up and they were continuing to fall on 

the floor.  Establishment personnel were in the process of trying 

to clear product from the table as product continued to fall on 

the table and floor.  Throughout establishment management’s 

efforts product continued to fall on the floor.  At this time, I 

took regulatory control action and informed 

(b) (6)

to 

stop the line.  The line remained stop until the establishment 

reestablished process control.  I observed establishment restore 

process control and regulatory control was released.  At 

approximately 1115 hours, after leaving the “hot” rehang area I 

then proceeded to the kill lines.  At this time, I observed the 

backup cutter on kill line 1 was “sawing” the miscuts that come 

his way.  He would perform a sawing motion on the birds that 

were presented with no cuts.  On kill line 2 I observed the 

backup cutter employee cut 20 mis cuts in 2 minutes and 55 

seconds.  I verbally informed 1st shift processing 

(b) (6)

that the observation would be documented in a MOI. 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 112 

EstNbr EstName 

P40183 Sanderson 

Farms, Inc. 

Task_Code 

04C05 

MOI# 

PEH151407 

4116G 

Date 

16JUL2018 

Description 

tried to get the employee to stop the line, but again the 

employee could not stop the line prior to the bird entering the 

scalder.  The dead bird was retrieved and I was able to confirm 

that no cut had been made to the bird’s neck.  Both supervisors 

were shown my findings.  The establishment elected to place 

two back-up cutters on Line #1. 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. 

At approximately 1758 hours while conducting a Good 

Commercial Practices task I observed the following: I observed 

a live bird enter the scalder on Line #1.  Prior to the bird 

entering the scalder, I noticed that it was alert and it’s neck was 

tucked into its chest.  I did not see any blood in the cervical 

region of the bird.  I notified the back-up cutter.  She was not 

able to stop the line until after the bird had already entered the 

scalder. I notified 

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

) of my 

concern and ).  He 

was able to retrieve the bird from the scalder.  Upon 

examination of the expired bird, I noticed that the laceration to 

the bird’s neck was superficial.  The cervical vessels had not 

been cut and they were still intact.  The bird’s skin had a bright 

red color.  At 2001 hours, I continued my inspection to see if 

the corrective action was effective.  At approximately 2003 

hours, I observed another bird enter the scalder.  This bird 

appeared to not have any cuts in the cervical region. 

(b) 

(6)
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 113 

EstNbr EstName 

P40183 Sanderson 

Farms, Inc. 

Task_Code 

04C05 

MOI# 

PEH272007 

4223G 

Date 

23JUL2018 

Description 

On 7/23/2018 at approximately 2037 hours while conducting a 

Good Commercial Practices task near the scalder on Kill Line #1 I 

observed the following: I observed a bird enter the scalder that 

was breathing.  This bird was alert with its eyes open and had 

its neck flexed in a ventro-caudal position.  I alerted the nearby

(b) (6)

 of my observations. 

When the bird was retrieved, no cut was observed in its cervical 

region.The establishment elected to place two back-up cutter on 

Kill Line #1 to prevent future occurrences. 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. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 114 

EstNbr EstName Task_Code MOI# 

P468 Peco Foods, Inc. 04C05 JVD491008 

5414G 

Date 

14AUG2018 

Description 

While performing a Good Commercial Practices Task at 

approximately 1100 hours on August 13, 2018, I 

, noticed a red condemn barrel used by the establishment 

(b) (6)

outside by the tool building located near the live bird dumping 

area. The barrel contained three live birds on top of one dead 

bird. The live birds were stressed as evidenced by panting and 

were outside in temperatures of approximately 86 degrees. l 

immediately notified 

supervisor 

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

, who notified 

. The live birds were taken inside to be 

processed at this time and the dead bird was disposed of, and 

the barrel was removed from the area. I discussed the situation 

with 

(b) (6)

. They 

informed me that this likely came from the sanitation crew 

collecting birds from underneath the dumping areas after 

production. The last production period ended at approximately 

2330 hours on August 11, 2018. The establishment does have 

an animal welfare program that states multiple times that 

abuse/mistreatment of poultry will not be tolerated. I explained 

that this was unacceptable and will result in a Good Commercial 

Practices MOI. 

(b) (6)
.... 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 115 

EstNbr EstName Task_Code MOI# 

P468 Peco Foods, Inc. 04C05 JVD541309 

5110G 

Date 

10SEP2018 

Description 

At approximately 1045 hours on 9/10/18 while performing a 

Good Commercial Practices Task, I 

(b) (6)

noticed 

that the condemn barrels located by the first sorter on Line 1 in 

the picking room contained a total of 17 cadavers as evidenced 

by the dark red coloration of their necks and the lack of a cut on 

their necks. As I was evaluating the birds on Line 1 getting to the 

sorter, I saw one cadaver as evidenced by bright red 

discoloration of its entire carcass. I did not see any more 

cadavers on this line over the next several minutes. I also 

evaluated the backup cutter position on Line 1 and did not 

witness any birds getting past the cutter that were not properly 

bled. Since I did not witness any more cadavers at this time and 

the issue appeared to be under control, I did not take a 

regulatory control action to stop production. I spoke to 

, and 

, about the situation. They were not aware that 

(b) (b) (6)

there had been an issue but stated that the problem must have 

begun after returning from lunch break at approximately 0930 

hours. They agreed with me that this was completely 

unacceptable and informed me that they will investigate the 

cause of this situation and will work to prevent this from 

recurring. They stated that they will get with their preliminary 

sorters from each line and have them stop the line any time 

they see a cadaver make it to them so the supervisors can 

investigate the cause. In addition, they will have them sign off 

each time they see a cadaver. There was a similar incident 

reported by 

(b) (6)

, on the first shift that occurred on 

6/13/18 in which he found 18 cadavers in the condemn barrels 

by the kill room sorter on Line 1. This was documented in a 

weekly meeting MOI on 6/21/18. There was also a similar 

situation in which I witnessed at least five cadavers within five 

minutes on Line 1 at the first sorter station in the kill room on 

6/7/18. This incident was also documented in a weekly meeting 

MOI on 6/7/18. 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. I spoke 

with 

(b) (6)

, and informed him that 

an MOI would be issued. 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 116 

EstNbr EstName 

P46897 IHSAN FARMS, 

IIC 

P46897 IHSAN FARMS, 

IIC 

Task_Code 

04C05 

04C05 

MOI# 

SVH49110 

63825G 

SVH08100 

72511G 

Date 

25JUN2018 

11JUL2018 

Description 

At 1119 while performing a poultry good commercial practices 

task in the slaughter area, the following was observed: There 

was a single live bird that was under foot beneath the end of the 

live bird conveyor nearest to the slaughter cone line.  The man 

(wearing a green hat) who slaughters the birds (knife in the right 

hand) picked up this bird with his left hand around the bird's 

neck and tossed the bird onto the belt.  Immediately I 

informed Mr. Ted Z (acting plant manager) of this poultry 

welfare concern.  This problem of handling birds by means other 

than by their legs/feet has been an ongoing concern at this 

establishment.  Previous poultry welfare MOIs have been 

written for the same issue: 4/5/18 (SVH3712044605G) 

2/28/18 (SVH1106021928I) 12/4/17 (SVH3713120204I) 

6/27/17 (0002609062521I)(this particular incident was also 

observed by 

(b) (6)

). 

Est. P46897, Ihsan Farms LLC, July 11, 2018, 0908 hours. In 

attendance: 

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

, Mr. Ted Zadeh, Plant 

Manager. spoke with Mr. Ted Zadeh and showed 

him the following: Adjacent to the live hang conveyor belt 

(where the birds are dumped) located outside the plant, there 

was a red condemn barrel half full of dead birds (DOAs).  Inside 

this barrel was a very much alive bird.  Luckily it was not buried 

beneath the other (roughly 15) birds.  Mr. Zadeh removed the 

bird from the barrel and I told him that a live bird in a condemn 

barrel was a welfare concern due to the fact that the bird could 

be smothered/suffocated (which is not slaughtered in 

accordance with poultry good commercial practices) or come to 

some harm when tossed with the offal / rendering truck. 
1111 

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1111 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 117 

EstNbr EstName Task_Code MOI# 

P476 Pilgrim's Pride 04C05 ODA29140 

90125G 

Date 

25SEP2018 

Description 

Daniel Shaw, Plant Manager Pilgrim's Pride Corporation 

P-0476 616 Kingsbridge Rd. Carrollton, GA 30117 On 

Thursday, September 20, 2018 at approximately 1928 hours 

while performing a Good Commercial Practices Task at P-0476 I, 

, observed an issue with the 

implementation of Good Commercial Practices in the 

evisceration area. I observed at the rehang table for line number 

one, three cadaver birds. Each cadaver was observed with an 

(b) (6)

engorged head intact with the neck to which there was no cut 

visible. I immediately notified 

and 

(b) (6)

. I 

(b) (6)

held the three cadavers on a hold rack in the evisceration 

department to show both and . 

stated he would have the employees involved do some 

form of retraining. No other cadavers were observed. This 

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

(6)

issue will be discussed with management at the next USDA 

weekly meeting on September 27, 2018. There was no 

P476 Pilgrim's Pride 04C05 ODA41170 27SEP2018 Daniel Shaw, Plant Manager Pilgrim's Pride Corporation 

90827G P-00476 616 Kingsbridge Rd. Carrollton, GA 30117 On 

Wednesday, September 26, 2018 at approximately 0015 hours 

receiving area. I observed one live bird inside of the DOA bin 

the DOA bin. The bird was euthanized and placed back inside of 

the DOA bin. No other live birds were observed in the DOA bin. 

area again to prevent a reoccurrence. The topic will also be 

discussed again at the next UDSA weekly meeting on September 

27, 2018 at 1630 hours and the minutes will be documented in 

immediate response given by establishment management. 

Respectfully, 

(b) (6)

while performing a Good Commercial Practices Task at P-00467 

I, , observed an issue with the 

implementation of Good Commercial Practices in the live 

(b) (6)

among an approximately half full bin of other deceased birds. I 

notified , who 

immediately notified . 

Both and observed this live bird within 

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

This issue was discussed with 

shortly after the occurrence. He stated that he will 

retrain the supervisor and superintendent over the live receiving 

(b) (6)

the corresponding MOI. Respectfully, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 118 

EstNbr EstName Task_Code MOI# 

P481 Tyson Foods, 04C05 VHF35030 

Inc. 64028G 

Date 

28JUN2018 

Description 

, observed the following good commercial practice 

failure: While observing incoming trailer #186 during 

antemortem inspection I observed multiple caged over carrying 

capacity in relation to weather and size of birds being 

transported. At the time of observation roughly 10 out of 22 

cages were filled to or above capacity with no open floor space 

seen. Birds inside the cages were panting heavily with frequent 

attempts to move due to discomfort. In three of the cages the 

birds were crawling on top of each other, panting, and unable to 

settle. In the running of this trailer a USDA food inspector 

observed a carcass displaying pathology consistent with 

heatstroke on the line. This carcass was condemned based on 

current agency recommended guidelines for heat stroked birds. 

At approximately 2145 hours night shift 

(b) (6)

Due to the conditions in these cages I alerted 

, and 

. The plant took immediate action in 

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

unloading the trailer and performed a headcount on a randomly 

selected cage from #186. The head count was found to be 

within normal limits, but due to the weather and increased size 

of the birds being run there likely was more activity in the cages 

than one would normally suspect. The Live Haul Supervisor was 

called and informed about the issue. He then instructed the 

catch crews to be mindful of bird numbers being placed into the 

cages and to be err on the side of caution when filling cages. 

This issue has previously been discussed with plant 

management as it is not within good commercial practices for 

birds to overheat or be overly stressed during their 

transportation to the slaughter facility. A google search revealed 

the temperature at the time of observation to be 88F. Fans and 

misters were as is appropriate for the current weather 

conditions, but due to bird density IPP still observed a carcass 

with heat stoke pathology. Repeated incidences such as this are 

an issue and can result in further action being taken by FSIS 

personnel. 
1111 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 119 

EstNbr EstName Task_Code MOI# 

P481 Tyson Foods, 04C05 VHF13030 

Inc. 93812G 

Date 

12SEP2018 

Description 

, 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. At the initial time 

of observation no plant personnel were stationed at the cull 

basket. As I proceeded to investigate the bin further one plant 

employee approached the basket to cervically dislocate birds. 

This employee, however, was unable to keep up with the 

workload as a bird was being added approximately every 2-3 

birds he culled. During observation multiple gasping birds were 

On 9/11/18 at approximately 0426 hours the night shift 

(b) 

(6)

seen pressed to the bottom of the pile. I notified 

, of the issue. immediately 

(b) (6)

(b) (6)

directed a second employee to start culling the birds. The 

chickens were euthanized via cervical dislocation and their 

carcasses were placed in the condemn barrels located at the end 

of the line, as is normal for this establishment. 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

(b) (6)

corrective actions taken by . It was stressed to the 

(b) (6)

livehang employees by plant supervision if they observe a large 

volume of birds in the cull basket they are to drop a shackle and 

assist with cervical dislocation until the process is back in 

control. 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. 
--

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 120 

EstNbr EstName 

P509 Koch Foods LLC 

P510 House Of 

Raeford Farms 

Task_Code 

04C05 

04C05 

MOI# 

IPG500007 

1926G 

RHB29080 

52425G 

Date 

26JUL2018 

25MAY2018 

Description 

The following occurred on the shift beginning 07/25/2018.  At 

approximately 0023 hours, I observed less than good 

commercial practices.  I observed an establishment employee in 

the Hang Station hanging live birds in a rough manner in 

comparison with the other employees next to him.  Live hanging 

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

was suspended, and , and 

, were immediately notified of 

the situation.  Hanging resumed at approximately 0025 hours. 

(b) (6)

and 

(b) (6)

were referred to the National 

Chicken Council Guidelines, as well as Federal Register / Vol. 70, 

No. 187 Docket #04-037N titled Treatment of Live Poultry 

Before Slaughter. 

At approximately 5:38am on 05/25/2018 while conducting a 

Good Commercial Practices Verification Task I observed a bird 

on the line which had his head elevated and was about to enter 

the first scalder. I stopped the line immediately before the bird 

made it to the scalder, and pointed it out to 

who removed the bird from the line. The bird’s head was 

(b) (6)

elevated, eyes were open, and he was breathing.  I did not see 

any cuts on the bird’s neck.  I discussed the issue with the 

, and 

reminded him that according to Good Commercial Practice 

requirements poultry are to be slaughtered in a manner that 

ensures breathing has stopped before scalding. The bird was 

not bled out and could have entered the scalder while still 

(b) (6)

breathing if I had not observed it and stopped the line. 

reported he discussed the concern with the back-up 

(b) 

(6)

cutter. The uncut bird was taken to the live bird hanging line.  I 

returned to the area prior to the first scalder and continued 

monitoring birds on the line.  I saw no further issues.  I later 

spoke with the Plant Manager, Nicole Reynolds, about the issue 

and reminded her that there was a GCP MOI documented on 

nightshift approximately three weeks ago, and a third one 

documented on dayshift approximately four weeks ago. I 

discussed that the MOI would also be sent to the DVMS. 

Respectfully, 

(b) (6)
him the bird which by that time was no longer breathing.  

 added a second back up cutter to the line and contacted

(b) 

(6)

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 121 

EstNbr EstName 

P510 House Of 

Raeford Farms 

Task_Code 

04C05 

MOI# 

RHB12070 

64313G 

Date 

13JUN2018 

Description 

At approximately 5:46am on 06/13/2018 while conducting part 

of a Good Commercial Practices Verification task near the 

entrance to the first scalder I observed a bird on the line moving 

and flapping its wings. I stopped the line before the bird 

reached the scalder. 

(b) (6)

removed the 

bird from the line and brought it to me.  The bird had a visible 

neck cut but was still breathing. 

who was back in the live 

The bird was taken to 

(b) 

(6)

hang area by the cutting blade.  I informed him that the bird 

was still breathing when removed from the line right before the 

scalder.  I reminded him that according to Good Commercial 

Practice requirements poultry are to be slaughtered in a manner 

that ensures breathing has stopped before scalding.  I showed

(b) (6)

 regarding 

the issue. 

(b) (6)

checked the system and discussed that 

he made adjustments to the stunner.  The expired bird was 

returned to the line. No further issues were noted.  I also 

discussed the issue with the Plant Manager, Nicole Reynolds. 

The last GCP check by the plant according to their records 

labelled Humane Handling listed 0 live birds going into the 

scalder at 2:33pm.  The latest GCP MOI was documented on 

05/25/18. Respectfully, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 122 

EstNbr EstName 

P510 House Of 

Raeford Farms 

Task_Code 

04C05 

MOI# 

RHB44100 

70706G 

Date 

06JUL2018 

Description 

Ms. Nicole Reynolds, Plant Manager, P-510 House of Raeford 

Rose Hill, NC 28458 Ms. Reynolds At approximately 0826 

while performing the Good Commercial Practices Verification 

task, I observed a live bird about to enter the scalder.  The bird 

at the time of my observation had normal rhythmic breathing, 

eyes open and blinking with the head elevated.  I immediately 

stopped the line before the bird could enter the scalder and 

pointed it out to 

(b) (6)

, who removed 

the bird.  After removing the bird from the line, it was observed 

that there was a small cut on the neck which was not deep 

enough to allow the bird to bleed out properly. 

, and

, were notified of my findings and shown

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

the live bird.  and were also notified of 

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

the pending MOI and the establishment’s failure to comply with 

9 CFR 381.65 (b) which states: Poultry must be slaughtered in 

accordance with good commercial practices in a manner that 

will result in thorough bleeding of the carcasses and ensure that 

breathing has stopped prior to scalding. 

was also notified and confirmed my findings. 

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

took 

the bird to live hang and showed it to the backup cutter.  Mr. 

Owens also placed a second backup cutter on the line.  Cervical 

disarticulation was performed on the bird. Additional 

monitoring of birds entering the scalder showed no further 

issues at this time. Ms. Reynolds this is the 5th incident of live 

birds entering into the scalder in the past 90 days.  The other 4 

have been documented on MOI’s RHB1207064313G dated 

6/13/18, RHB2908052425G dated 5/23/18, RHB0921050002G 

dated 5/2/18 and RHB0208043824G dated 4/24/18. Ms. 

Reynolds this MOI will be forwarded to the District Veterinary 

Medical Specialist (DVMS) in case additional follow-up is 

recommended.  If you have any questions or concerns 

. Respectfully, 

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

(b) (6)

regarding the above, please contact , or Mr. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 123 

EstNbr EstName 

P510 House Of 

Raeford Farms 

Task_Code 

04C05 

MOI# 

RHB29120 

83601G 

Date 

01AUG2018 

Description 

Ms. Nicole Reynolds, Plant Manager, P-510 House of Raeford 

Rose Hill, NC 28458 Ms. Reynolds At approximately 1012 

while performing the Good Commercial Practices Verification 

task, I observed a live bird about to enter the scalder.  The bird 

at the time of my observation had normal rhythmic breathing, 

eyes open and blinking with the head elevated.  I immediately 

stopped the line before the bird could enter the scalder and 

pointed it out to 

(b) (6)

, who 

removed the bird from the line.  After removing the bird from 

the line, it was observed that there was a small cut on the neck 

which was not deep enough to allow the bird to bleed out 

properly. 

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

, took the bird back 

to live hang to show it to the backup cutter. 

performed cervical disarticulation on the bird and made a deep 

cut on the neck to allow proper bleeding. 

(b) (6)

then hung 

the bird back on the line at the end of the bleed tank. I 

discussed my finding with 

, and notified him of the pending MOI and the 

(b) (6)

establishment’s failure to comply with 9 CFR 381.65 (b) which 

states: Poultry must be slaughtered in accordance with good 

commercial practices in a manner that will result in thorough 

bleeding of the carcasses and ensure that breathing has stopped 

prior to scalding. 

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

was also notified and 

confirmed my findings.  stated that they had 

problems with the kill blade earlier that morning and that he 

would have maintenance look at it and would put a second 

backup cutter on the line. 

(b) (6)

informed me that 

adjustments had been made to the kill blade and would 

continue to have 2 backup cutters on the line for the remainder 

of the shift. Additional monitoring of birds entering the scalder 

showed no further issues at this time. Ms. Reynolds this MOI 

will be associated with MOI RHB4410070706G documented on 

7/6/18 for a similar incident of a live bird entering into the 

scalder.  MOI RHB441007076G also references 4 other incidents 

of live birds entering the scalder and were documented on 

MOI’s RHB1207064313G dated 6/13/18, RHB2908052425G 

dated 5/23/18, RHB0921050002G dated 5/2/18 and 

RHB0208043824G dated 4/24/18. Ms. Reynolds this MOI will 

be forwarded to the District Veterinary Medical Specialist 

(DVMS) in case additional follow-up is recommended.  If you 

have any questions or concerns regarding the above, please 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 124 

EstNbr EstName Task_Code MOI# Date Description 

contact or 

. Respectfully, 

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

(b) (6)

P510 House Of 04C05 RHB05120 09AUG2018 At approximately 0536 hours on 08/09/2018 while conducting 

Raeford Farms 80709G a Good Commercial Practices Verification Task I observed a bird 

on the line with his head elevated which was about to enter the 

first scalder. I immediately stopped the line before the bird 

reached the scalder, and discussed the issue with 

.  removed the bird 

from the line. The bird’s eyes were open, it’s head was elevated, 

(b) (6)

(b) (6)

and it was breathing.  The bird did not have any visible cuts on 

it’s neck. I discussed with 

(b) (6)

that according to the 9 CFR 

Good Commercial Practice regulations poultry are to be 

slaughtered in a manner that ensures breathing has stopped 

before scalding. The bird did not have a cut on it’s neck, was 

not bled out, and could have entered the scalder while still 

breathing if I had not observed it and stopped the line.  I 

discussed with him that the issue would be documented on a 

MOI and reminded him there have been numerous similar issues 

in the past documented on MOIs. 

(b) (6)

discussed the 

issue with the back-up cutter, added another back-up cutter 

onto the line, and contacted the maintenance supervisor.  The 

uncut bird was taken to the live hang area and placed on the 

line.  discussed that they were dealing with varying 

sizes of birds in the current lot.  The nightshift 

monitored the system and then 

adjusted the stunner.  The establishment’s records labelled 

(b) (6)

(b) (6)

Humane Handling listed 0 live birds going into the scalder 

according to the four most recent entries. The latest entry 

documented was 2:28am on nightshift.  I returned to the area 

prior to the first scalder to continue monitoring birds on the line 

and saw no live birds enter the scalder.  I also spoke with the

reminded him that there were six previously documented GCP 

(b) (6)

about the issue and 

MOIs since April 2018.  I discussed that this GCP MOI would also 

be sent to the District Veterinary Medical Specialist (DVMS) in 

case additional follow-up is needed. Respectfully, 

(b) (6)
1111 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 125 

EstNbr EstName 

P510 House Of 

Raeford Farms 

Task_Code 

04C05 

MOI# 

RHB18090 

82822G 

Date 

22AUG2018 

Description 

, regarding the issue, 

and he also spoke with the two backup cutters regarding 

verifying adequate neck cuts. 

(b) (6)

made an 

adjustment to the cutting blade and discussed that he also 

made an adjustment to the stunner.  I returned to the area prior 

to the first scalder to monitor birds on the line and saw no 

further issues.  The most recent GCP check documented by the 

plant according to their records labelled Humane Handling was 

at 0200 hours.  It listed 0 live birds going into the scalder.  The 

most recently documented GCP MOI was on 08/09/18. I 

discussed the issue with Plant Manager, Nicole Reynolds, and 

that there have been numerous GCP MOIs since April 2018.  She 

reported she spoke with

(b) (6)

 and is planning to have the 

production and maintenance departments monitor the line each 

morning to verify it is running correctly and help prevent live 

birds from entering the scalder. I notified Ms. Reynolds that this 

MOI will be forwarded to the District Veterinary Medical 

Specialist (DVMS) at the District Office in case additional 

follow-up is recommended. Respectfully, 

was also present. I pointed out the bird to him and the 

line was stopped before the bird reached the scalder.  He 

removed the bird and a second bird approximately three 

shackles from that bird showed signs of movement. I instructed 

him to also remove that bird.  I verified both birds were 

breathing.  They each had visible neck cuts and one of the bird’s 

cuts appeared shallow. 

(b) (6)

performed cervical 

disarticulation on each of the birds.  I reminded him that 

according to Good Commercial Practice requirements poultry 

are to be slaughtered in a manner that ensures breathing has 

stopped before scalding.  He contacted the 

(b) (6)

At approximately 0542 hours on 08/22/2018 while conducting 

part of the Good Commercial Practices Verification task near the 

entrance to the first scalder I observed a bird on the line moving 

its head and flapping its wings. 

(b) (6)

(b) (6) (b) (6)
• 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 126 

EstNbr EstName Task_Code MOI# Date Description 

P510 House Of 04C05 RHB51120 05SEP2018 At approximately 0543 hours on 09/05/2018 while conducting 

Raeford Farms 93605G the Good Commercial Practices Verification task near the first 

scalder I observed a bird on the line moving and vigorously 

flapping it’s wings.  I pointed the bird out to 

.  The bird was removed from the line by . The bird 

had a visible neck cut but was still breathing.  The 

was notified of the issue and was 

reminded that GCP regulations require birds to be no longer 

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

(b) (6)

breathing when they enter the scalder. Cervical disarticulation 

was performed on the bird. 

was contacted.  He made an 

(b) (6)

adjustment to the cutting blade. I monitored the birds on the 

line and saw no live birds enter the scalder. The most recent 

GCP check documented by the plant according to their records 

labelled Humane Handling was 0214 hours.  It listed 0 live birds 

going into the scalder. The issue was also discussed with the 

Plant Manager, Nicole Reynolds.  Similar GCP MOI’s have been 

documented the most recent one was documented on 

08/22/2018.  A copy of this MOI will be forwarded to the 

District Veterinary Medical Specialist (DVMS) at the District 

Office in case additional follow-up is recommended. 

Respectfully, 

(b) (6) (b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 127 

EstNbr EstName 

P517 Mar-Jac 

Poultry-MS 

Task_Code 

04C05 

MOI# 

QOO32040 

54723G 

Date 

23MAY2018 

Description

(b) (6)

 Mar-Jac Poultry, MS 1301 

James Street Hattiesburg, MS 39401 

(b) (6)

, At 

approximately 0245 hours on May 23, 2018, 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 3rd picker on the north picking line at approximately 

0250 hours.  The cadaver entered the evisceration department 

and was removed at approximately 0251 hours by a plant 

employee on the rehang table at the request of 

.  The associated paws were rejected. 

was notified at 

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

approximately 0252 hours and was 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 0253 hours had no live bird(s) 

entering the scald tank.  This incident was determined to be 

isolated event and not a loss of process control or a systemic 

event. Allowing bird(s) to enter the scald tank while still 

breathing is a less than GCPIP and causes needless suffering and 

death 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. 

and met in the 

(b) (6)

(b) (6)

(b) (6)

office at approximately 0300 hours on May 23, 2018 to discuss 

the less than GCPIP incident.  No response to the less than 

GCPIP incident was given at this time.  Mr. Delai 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 

(b) (6)

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 
                    

        

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 128 

EstNbr EstName Task_Code MOI# Date Description 

abide by Good Commercial Practices (GCPs) as described in 

industry guidelines. Respectfully, 

, Canton, MS 9024 1039 W. Fulton St. Canton, MS 

(b) (6)

39046 cc:  Dr. Larry Davis, DM Dr. David Thompson, DDM 

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

P517 Mar-Jac 04C05 QOO42090 24MAY2018

(b) (6)

 Mar-Jac Poultry, MS 1301 

Poultry-MS 50524G James Street Hattiesburg, MS 39401 Mr. Colee, At 

approximately 0917 hours on May 24, 2018, 

observed less than Good Commercial Practices while 

(b) (6)

performing an Antemortem Inspection and Good Commercial 

Practices check at P517, Mar-Jac Poultry, MS, Hattiesburg, 

MS.  While monitoring the cage dumping process, I observed 

the dumper operator dump a coop of birds on top of the birds 

on the conveyor belt.  This action causes excessive mistreatment 

of the birds and could smother or injure the birds that are 

I then 

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. A copy of this 

Memorandum of Interview will be forwarded to appropriate 

underneath the multiple layers of birds on the conveyor. 

notified , of the observed 

deficiency during a brief meeting held in the USDA office at 

0925 hours.  was advised that a GCP MOI 

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

personnel in the Jackson District Office. Respectfully, 

Relief P247 Hazlehurst, MS cc:  Dr. 

Larry Davis, DM Dr. David Thompson, DDM Dr. Gregory 

Brookhouser, DDM 

(b

) 

(6)

(b) (6)

(b

) 

(6)
 

 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 129 

EstNbr EstName 

P517 Mar-Jac 

Poultry-MS 

Task_Code 

04C05 

MOI# 

QOO19120 

64922G 

Date 

22JUN2018 

Description

(b) (6)

 Mar-Jac Poultry, MS 1301 

James Street Hattiesburg, MS 39401 

(b) (6)

, At 

approximately 0906 hours on June 22, 2018, while verifying 

Good Commercial Practices in Poultry (GCPIP) verification task 

at 00517P (Mar Jac), in Hattiesburg, MS, the following less than 

GCPIP incident was observed at the cage dumper for live birds. 

An employee was observed grabbing several (approximately 

three in each hand) birds, that had not fallen onto the conveyor, 

out of the cages and throwing them onto both the North and 

South conveyors leading to the hanging pens. A similar 

incident was written (QOO4209050524G) on May 24, 2018 

with the respect of mishandling live birds at the dumper. 

Throwing birds is not consistent with GCPIP. Establishments are 

responsible for birds entering the official premises and must 

employ GCPIP to prevent unnecessary suffering, injury or death. 

(b) (6)

This issue was discussed with 

(b) (6)

and

 on June 22, 2018 at 0920. As 

per Federal Register Notice Docket 04-037N, dated September 

28, 2005, “Treatment of Live poultry Prior to Slaughter”, the4 

Food Safety Inspection Service (FSIS) strongly encourages all 

establishments engaged in the slaughter of poultry to abide by 

Good Commercial Practices (GCP’s) as described in industry 

guidelines. Respectfully, 

(b) (6)

Cc: Dr. Larry Davis, DM Dr. David Thompson, DDM Dr. 

Gregory Brookhouser, DDM 

(b) (6)(b

) 

(6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 130 

EstNbr EstName 

P517 Mar-Jac 

Poultry-MS 

Task_Code 

04C05 

MOI# 

QOO35130 

62228G 

Date 

28JUN2018 

Description

 was notified at approximately 0642 

hours and given an opportunity to examine the cadaver.  A 

second verification check of an approximate 500 bird random 

subgroup sample on the north picking line at approximately 

0644 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 

(b) (6)

Mar-Jac Poultry, MS 1301 

James Street Hattiesburg, MS 39401 

(b) (6)

, At 

approximately 0632 hours on June 28, 2018, 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 0636 

hours.  The carcass, with feet attached, was removed from the 

evisceration line at approximately 0638 hours by a plant 

employee at the hot rehang location. 

(b) (6)

than slaughter. 

and 

(b) (6)

met at 

(b) (6)

approximately 0840 hours on June 28, 2018 in the USDA IIC 

office to discuss the less than GCPIP.  No response to the 

incident was given at this time. 

(b) (6)

was advised a 

GCPIP Memorandum of Interview would be issued to 

management pending review by 

(b) (6)

. 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 
        

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 131 

EstNbr EstName Task_Code MOI# Date Description 

industry guidelines. 

, Canton, MS 9024 1039 W. Fulton St. Canton, MS

Respectfully, 

(b) (6)

39046 cc:  Dr. Larry Davis, DM Dr. David Thompson, DDM

 Dr. Gregory Brookhouser, DDM Mr. William Griffin, 

DDM 

(b) (6)(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 132 

EstNbr EstName 

P517 Mar-Jac 

Poultry-MS 

Task_Code 

04C05 

MOI# 

QOO26210 

70009G 

Date 

09JUL2018 

Description

(b) (6)

 Mar-Jac Poultry, MS 1301 

James Street Hattiesburg, MS 39401 

(b) (6)

, At an 

approximately 2043 hours while performing a Good Commercial 

Practice in Poultry (GCPIP) at Establishment P-517,  Mar Jac 

Poultry, Hattiesburg, Mississippi a less than Good Commercial 

Practice in Poultry incident (GCPIP) was observed. While 

performing an ante-mortem check which is part of the PHIS task 

for Poultry Good Commercial Practices in the holding shed, I 

observed on one poultry trailer, that consist of two rows of 

eleven coops (11), arranged in such a way where coops were 

double stacked, with a top and bottom row. In this arrangement 

the last two double stacked coops at the very end of the poultry 

trailer, the birds in these last two coops were showing signs of 

heat stress. The birds were showing signs of open mouth 

breathing with neck outstretched. The birds were rapidly 

breathing, to enhance heat loss. The birds appeared to be very 

uncomfortable, signs evidencing signs of heat exhaustion and 

heat stress. There was a remarkable difference in demeanor 

that was presented, from chickens observed in coops at the 

front as compared to those chickens that were situated in last 

two stacks of coops at the very back of the trailer. Observation 

made of the area indicated where the heat stress was evident 

that the fans were either turned off and not operating or were 

nonfunctional. This observation correlated well where birds 

were experiencing heat stress. In addition, where the trailer is 

parked on the south side of the holding shed, for the offloading 

of coops, is along the row of fans that dead ends adjacent to the 

wall of the building. This portion of the holding shed is situated 

in a dead spot where air flow is minimal, because portion of the 

building comes out making an “L” does creating a corner. The 

other areas where poultry trailers were parked in the holding 

shed, for the offloading of coops for slaughter, air flow was good 

and the birds were comfortable, with no signs of heat stress 

being evident. Mr. Jeff Delai was notified of the less than 

desirable condition at approximately 2110. Mr. Jeff Delai 

accompanied me, to the holding shed and was shown the 

environmentally compromised area in which the trailer was 

situated and the inoperable fans in that area of the trailer. In my 

presence action was taken to rectify the situation, in which the 

assistant plant manager, Jeff Delai instructed the shuttle drivers, 

to park the poultry trailers only where there were functional 
1111 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 133 

EstNbr EstName Task_Code MOI# Date Description 

fans that were in operation. Subsequent, to our joint 

investigation by IPP and plant management, Jeff Delai indicated 

that some of the fans had been turned off. I informed Jeff 

Delai, assistant plant manager of my findings and that a MOI 

would be issued. The less than desirable Good Commercial 

Poultry Practice was brought up in the weekly meeting, and is in 

the Weekly Meeting Notes for third shift date 6-28-2018. I 

strongly encourage the establishment to review Federal Register 

Notice Docket No. 04-37N dated September 28, 2005, 

“Treatment of Live Poultry before Slaughter for 

Recommendations concerning 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 in 

Industry Guidelines. A copy of this Memorandum of Interview 

will be forwarded to appropriate personnel in the District Office. 

Respectfully, 

(b) (6)

P-519 SPHV 525 

Wayne Drive Laurel, Mississippi 34990 Jackson District 

601-399-7000 417-389-6418 Cell cc: 

. 

(b) (6)

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 134 

EstNbr EstName 

P517 Mar-Jac 

Poultry-MS 

Task_Code 

04C05 

MOI# 

QOO12040 

92004G 

Date 

04SEP2018 

Description

(b) (6)

 Mar-Jac Poultry, MS 1301 

James Street Hattiesburg, MS 39401 

(b) (6)

, At 

approximately 2053 hours on September 3, 2018, the following 

less than Good Commercial Practices in Poultry (GCPIP) incident 

was observed at P517, Mar-Jac Poultry, MS, Hattiesburg, MS. 

The North dumper operator dumped a cage of birds onto the 

transfer belt causing the birds to pile on top of each other.  The 

transfer belt had not completely emptied, and birds were still 

covering approximately the remaining 3 feet of the belt.  Piling 

birds on top of other birds can lead to suffocation and death by 

means other than slaughter.  Additionally, 3 birds remained 

trapped in the cage.  Two of the birds were caught by the foot 

between the cage and the cage door.  The third bird was 

entrapped on the top tier of the cage.  The dumper operator 

proceeded to raise and lower the cage repeatedly in an attempt 

to dislodge the trapped birds.  The dumper operator on the 

South dumper was notified and the birds were humanely 

removed from their entrapment and placed on the transfer belt. 

No birds were observed to have expired as a direct result of 

piling birds on top of birds. 

and 

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

were notified.  This 

incident was determined to be isolated event and not a loss of 

process control or a systemic event. Piling birds on top of other 

birds can cause suffocation and lead to death.  Birds entrapped 

in cages must be removed using humane care to prevent 

needless suffering and injury.  Both incidents can result 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. 

and 

(b) (6)

met in the USDA IIC office at 

approximately 2115 hours on September 3, 2018 to discuss the 

less than GCPIP incident.  No response to the less than GCPIP 

incident was given at this time. 

(b) (6)

was advised a GCPIP 

Memorandum of Interview would be issued to management 

pending review by 

(b) (6)

. 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 

(b) (6)
        1111 

135 

every effort to treat poultry humanely and abide by Good 

Commercial Practices (GCPs) as described in industry guidelines. 

Respectfully, 

(b) (6)

, Canton, MS 9024 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 

EstNbr EstName Task_Code MOI# Date Description 

1039 W. Fulton St. Canton, MS 39046 cc:  Dr. Larry Davis, DM

 Dr. David Thompson, DDM Dr. Gregory Brookhouser, 

DDM Mr. William Griffin, DDM 

(b) (6)

(b) (6)
        

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 136 

EstNbr EstName 

P517 Mar-Jac 

Poultry-MS 

Task_Code 

04C05 

MOI# 

QOO57230 

90127G 

Date 

27SEP2018 

Description

(b) (6)

 Mar-Jac Poultry, MS 1301 

James Street Hattiesburg, MS 39401 

(b) (6)

, At 

approximately 2229 hours on September 27, 2018, the 

following less than Good Commercial Practices (GCP) incident 

was observed at P517, Mar-Jac Poultry, MS, Hattiesburg, MS. 

The yard truck driver ran over a chicken as the trailer was being 

pulled out of bay #3 at the live holding area.  The bird’s 

intestines were squeezed out of the body cavity, abrasions were 

present on top of the back, respiration was agonal, and the bird 

succumbed almost immediately, but not before suffering 

unnecessarily. 

(b) (6)

was notified of the incident.  This 

was a single isolated incident and was determined not to be a 

systemic loss of process control.  Allowing loose birds on the 

grounds subjects the birds to injury, suffering, and death. 

Transport cages must be in good repair to prevent birds from 

escaping and dying from means other than slaughter.  In cases 

where birds do escape from the cages, the birds must be caught 

and confined in a timely and humane manner.  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. 

, Canton, MS 9024 1039 W. Fulton St. Canton, MS 

39046 cc:  Dr. Larry Davis, DM Dr. David Thompson, DDM 

Dr. Gregory Brookhouser, DDM Mr. William Griffin, 

(b) (6)

and 

(b) (6)

met 

to discuss the less than GCP incident at approximately 2245 

hours on September 27, 2018.  No response to the less than 

GCP incident was given at this time. 

(b) (6)

was advised a 

GCPIP Memorandum of Information would be issued to 

management pending review by 

(b) (6)

. 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, 

(b) (6)

DDM 

(b) (6)

(b) (6)
.. 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 137 

EstNbr EstName Task_Code MOI# 

P519 Wayne Farms 04C05 KMH12140 

LLC 61620G 

Date 

20JUN2018 

Description 

On June 20, 2018, at approximately 12:45 PM, I observed Less 

Than Good Commercial Practice at establishment P-519 Wayne 

Farms in Laurel, MS. While performing a second ante mortem 

inclusive with completing my Good commercial Practice 

verification task, I observed many live birds on nearly 3-4 trailer 

loads open mouth breathing under the live holding shed and live 

receiving. The birds had their necks stretched and were rapidly 

breathing with their mouths opened in weather temperature 

above 85 degrees in Fahrenheit. They appeared to be very 

uncomfortable. This could be symptoms of heat exhaustion and 

heat stress. There was minimal wind movement and the some of 

the fans installed in both the holding shed and live receiving 

were not on and/or was not working. As in comparison to the 

other live birds that were under working fans, these birds 

exhibiting undue stress showed heightened breathing patterns 

by way of their mouths being more opened, and their breathing 

were more rapid, deep, and more forceful than the others. 

They’d often move around in their cages more, which shows 

that they were irritable and uncomfortable. Other trailer loads 

of birds with working fans and misters were resting, much more 

calm, and even some were asleep, as well as breathing 

effortlessly and breathing with their mouth slightly open, which 

could be seen as a normal thing that happens on much warmer 

days. I informed 

(b) (6)

of my findings 

and that a MOI would be issued. 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. FSIS considers one source for 

Good Commercial Practices to be the National Chicken Council 

Guidelines/National Turkey Federation Guidelines. My 

observations were not consistent with guidance in the National 

Chicken Council Animal Welfare Guidelines: A copy of this 

Memorandum of Interview will be forwarded to appropriate 

personnel in the District Office. Respectfully submitted, 

Cc: ; 

(b

(b) (6)

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 138 

EstNbr EstName 

P522 Sanderson 

Farms, Inc. 

(Processing Div) 

Task_Code 

04C05 

MOI# 

IKB251908 

1028G 

Date 

28AUG2018 

Description 

On August 28th, 2018 at approximately 1908 hours, the 

following was observed at P-522, Sanderson Farms, in Collins, 

Mississippi: While conducting a routine Good Commercial 

Practices task, I, 

(b) (6)

, entered the live hang area. I 

observed approximately 20 dead on arrival (DOA) birds piled up 

on the head-puller table at the end of the belt. I could see one 

live bird under this pile, because it's head was sticking up over 

the edge of the table and it was breathing heavily and looking 

around. I alerted 

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

, 

to the situation as he was standing near by. and 

other employees removed the DOAs from the table and 

retrieved the live bird. In the course of removing the DOAs from 

the table, I also observed two more live birds which were 

uncovered from beneath the DOAs. I informed 

, and 

(b) (6)

(b) (6)

, of 

my findings and that a GCP MOI would be issued documenting 

this incident. 

(b) (6)

stated that he reviewed videotapes of 

the incident, in which he observed that the DOAs were piled up 

for a short period of time, no more than 3 minutes, and that the 

employee in charge of managing the DOAs on the table 

returned to the area promptly after emptying his wheelbarrow. 

The treatment of live bird before slaughter is an important 

animal welfare concern. Live birds trapped beneath DOAs may 

suffer from injuries or suffocation, regardless of the length of 

time for which they are trapped. 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. The 

establishment is strongly encouraged to abide by Good 

Commercial Practices.  Respectfully, 

(b) (6)

MPH 

Supervisory Public Health Veterinarian 
 

 

 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 139 

EstNbr EstName 

P522 Sanderson 

Farms, Inc. 

(Processing Div) 

Task_Code 

04C05 

MOI# 

IKB550709 

3917G 

Date 

17SEP2018 

Description 

On September 17, 2018 at approximately 0522 hours while 

conducting a Good Commercial Practice check in the Picking 

Room of establishment P-522, I observed the following: I 

observed one live bird enter the scalder on the inside Picking 

Line.  The bird was alert, blinking its eyes and turned its head as 

if looking at its surroundings.  There were no indications of 

blood or a cut on the neck of the bird. 

, was notified of the pending MOI.  As per 

(b) (6)

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.  Respectively, 

Dr. Gregory 

Brookhouser, DDM 

(b

) 

(6)

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

P522 Sanderson 

Farms, Inc. 

(Processing Div) 

04C05 IKB020709 

1324G 

24SEP2018 On September 24, 2018 at approximately 0502 hours while 

conducting a Good Commercial Practice check in the Picking 

Room of establishment P-522, I observed the following: I 

observed two live birds enter the scalders on the inside Picking 

Line.  Both birds were identified by their alertness to their 

surroundings and with blinking eyes.  I saw no indication of 

blood or a cut on the neck of either bird.  In the presence of 

, 

, and , 

(b) (6)

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

the birds were identified as they exited the scalding system. 

Plant management removed the two birds from the Picking line 

and laid the birds on the floor.  I examined the birds at this point 

and further verified that there were no cuts on the neck of 

either bird.  The birds were disposed of in the drain by the 

Picking Room Supervisor. 

(b) (6)

and 

(b) (6)

were informed of the pending 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 Good Commercial Practices. 

Respectively, s 

Dr. Gregory Brookhouser, DDM 

(b) (6)(b

) 

(6)

(b) (6)
• ........,. 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 140 

EstNbr EstName 

P522 Sanderson 

Farms, Inc. 

(Processing Div) 

Task_Code 

04C05 

MOI# 

IKB130709 

5727G 

Date 

27SEP2018 

Description 

On September 27, 2018 at approximately 0546 hours while 

conducting a Good Commercial Practice check in the Picking 

Room of establishment P-522, I observed the following: I 

observed one live bird enter the scalder on the outside Picking 

Line.  The bird was alert, blinking its eyes and looking around as 

it hung on the Picking Line.  There was no blood or cut on the 

neck of the bird 

(b) (6) , 

and Jason Hancock, Picking Room Supervisor, were notified of 

the pending 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 Good Commercial Practices.  Respectively, 

y s Dr. 

Gregory Brookhouser, DDM 

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

(b) (6)

P559 Tyson Foods, 04C05 UWC40140 15JUN2018 hshdJSHD 

Inc. 61015G 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 141 

EstNbr EstName 

P579 Jennie-O Turkey 

Store Sales, Inc. 

Task_Code 

04C05 

MOI# 

UIO481906 

5512G 

Date 

12JUN2018 

Description 

On 06/11/2018 beginning at approximately 2:05 pm while 

performing a Poultry Good Commercial Practices Task in the 

blood tunnel area, I observed 9 turkeys with torn-skin injuries 

on their backsides.  For all injuries, the exposed tissue was 

moist, and the feathers bordering the torn skin were stained 

with blood; the injury locations included the dorsal aspect of 

the tail, midline over the hips, midline over the middle-back, 

and midline at the base of the dorsal surface of the neck.  The 

size of the injuries ranged from approximately 3 x 2 inches up to 

approximately 8 x 4 inches; most of the injuries were 

approximately 4 x 4 inches in size.  8 of the 9 injured turkeys 

belonged to the first lot, and the other turkey belonged to the 

second lot.  There was an atypically-high amount of blood 

staining on the feathers of the uninjured birds from the first lot; 

there was far less and a more typical amount of blood staining 

on the feathers of the birds from the second lot. I spoke with 

and 

.  They said that the same grower will be supplying 

birds from the same flock tomorrow, and Jennie-O personnel 

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

will be ready to evaluate the situation in case there are similar 

injuries. 

(b) (6)

covering 1st shift at 

P579, observed this related lot on 06/12/2018 and did not 

observe any injuries on birds still in the trucks or when they 

came through the blood tunnel area. On 06/12/2018, Plant 

Manager Jody Long reported that the barn where these turkeys 

were raised recently suffered a power outage during a strong 

thunderstorm.  The sudden loss of light, fans and/or the 

thunderstorm itself caused a panic in the flock, which led to the 

birds piling on top of each other.  Many turkeys were injured 

and killed during this panic.  Mr. Long believes that the 

fresh-looking injuries observed in the blood tunnel on 

6/11/2018 were sequelae to injuries sustained during the 

power-outage and subsequent pile-up. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 142 

EstNbr EstName 

P579 Jennie-O Turkey 

Store Sales, Inc. 

Task_Code 

04C05 

MOI# 

UIO122106 

3315G 

Date 

15JUN2018 

Description 

, who discovered that there had been a 

clog of turkeys recently somewhere in the conveyor belt system 

leading to the CO2 stunner.  I observed turkeys outside still in 

the trailers, and there was no evidence of blood-staining or 

injury.  I alerted Plant Manager Jody Long to the situation. I 

later spoke with 

(b) (6)

about the 

establishment’s response into the incident.  He said that truck 

unloaders worked too fast and put too many birds into the 

conveyor system at one time, resulting in the clog.  The gap in 

the birds was detected by the live hangers, but by then the 

injuries had already occurred.  Going forward, 

(b) (6)

will 

be performing regular checks of the unloading crew to ensure 

they are working at an appropriate pace for the speed of the 

production line and for the type of the turkeys.  Today the birds 

were hens, which are much easier to unload than typical toms. 

This probably contributed to the too-rapid pace and the clog.  In 

addition to monitoring pace, 

(b) (6)

will also adjust the 

number of crew needed to unload based on the type of turkey; 

he will meet with the unloading/live-hang crew to discuss the 

situation. 

(b) (6)

inspected the entire length of the 

conveyor system and did not find any gaps or catches that could 

have caused the clog. 

On 06/14/2018 at approximately 4:15 pm while performing a 

Poultry Good Commercial Practices Task in the blood tunnel 

area, I observed an atypically high amount of blood staining on 

the feathers of the turkeys.  I observed four turkeys with 

torn-skin injuries on their backsides over their hips and 

mid-back; two of these birds’ injuries extended to the right 

hips.  The underlying tissues were moist, and the surrounding 

feathers stained with blood.  In addition, I observed two turkeys 

with similar injuries on their ventral surface, mid-breast.  There 

were many uninjured turkeys with superficially blood-stained 

feathers, primarily on their backsides.  I notified 

(b) 

(6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 143 

EstNbr EstName 

P579 Jennie-O Turkey 

Store Sales, Inc. 

Task_Code 

04C05 

MOI# 

UIO170506 

1115G 

Date 

15JUN2018 

Description 

On 6/12/2018 at about 10:20 am I, Relief PHV Daniel Demaske, 

performed a Poultry Good Commercial Practices Task in the live 

hang area at P579 Jennie-O Turkey Store.  During this task, I 

observed an incident in which carcasses stopped emerging from 

the CO2 tunnel.  The belt was stopped and establishment 

employees opened the far end of the tunnel near the entrance 

and worked to clear a mass of turkey carcasses that had become 

jammed in the tunnel. When the belt was started again, 

carcasses emerged from the near end of the tunnel and 

appeared to be fully stunned from the CO2.  However 8 to 10 of 

the carcasses had wet bloody injuries to their backs and legs 

with missing feathers and torn skin.  At least two carcasses had 

cuts several inches long extending 1-2 inches deep into the 

breast muscle.  I spoke with 

shortly after the incident who said that he wasn’t sure why the 

carcasses had become jammed but that he would review video 

of the incident to try to determine the cause.  I told him I would 

document the incident in an MOI and would also discuss it at 

the next weekly meeting.  I discussed the incident and other 

similar incidents with Plant Manager Jody Long on June 14 in a 

joint meeting with 

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

said that they 

will monitor the speed at which trucks are unloaded and 

instruct employees to not unload too quickly which could 

overload the conveyors and cause these clogs. 

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 144 

EstNbr EstName 

P579 Jennie-O Turkey 

Store Sales, Inc. 

Task_Code 

04C05 

MOI# 

UIO151208 

1710G 

Date 

10AUG2018 

Description 

At approximately 1045, while in the live hang area performing 

the Poultry Good Commercial Practices Task the following was 

observed. Approximately 1 out of every 10 young tom turkeys 

that were on the line prior to the scalder had wounds and 

bruises.  The wounds appeared moist with bright red blood on 

the surrounding feathers indicative of recent trauma.  The 

bruises were cherry red in color.  Several carcasses were 

observed with open wounds on the back taking up the entirety 

of the back of the turkey carcass.  Several wings were observed 

fractured and bruised. Several birds had bruised drums with 

open wounds taking up the entire lateral aspect of the drum. 

The issue was brought to the attention 

, 

(b) (6)

(b) (6)

(b) (6)

, and 

.  For approximately two 

minutes carcasses with these injuries were observed. Further 

observations  throughout the shift revealed no injured birds. 

(b) (6)

stated that there was a blockage 

in the CO2 conveyor which had been cleared. The issue was 

further discussed with 

(b) (6)

who 

reiterated that the establishment had a blockage on the CO2 

conveyor and that he was also going to check why the line was 

not shut off during the blockage. At approximately 1210 during 

a discussion with 

(b) (6)

, he stated 

that the establishment had found that two establishment 

employees were unloading birds too quickly from the trucks. He 

also stated that the establishment recently had a meeting 

concerning this as well so the employees involved will be 

reprimanded. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 145 

EstNbr EstName 

P584 Pilgrim's Pride 

Corporation 

Task_Code 

04C05 

MOI# 

QLM22080 

75219G 

Date 

19JUL2018 

Description 

On July 16, 2018 at approximately 1324 hours, while 

performing a Good Commercial Practices Task, the following 

incident was observed:  A single chicken was pulled apart and 

lying on the ground beneath the coop platform/conveyor.  At 

the time the mutilated chicken was discovered, birds were being 

moved onto the conveyor belt and (because of the angle of the 

metal plate/slide within the transfer system) all chickens within 

the coop were not completely removed.  This allowed several 

birds to perch on top of the slide, preventing them from being 

transferred to the conveyor belt and into the live hang area. I 

observed nine birds on the slide during one coop transfer and 

twelve birds perched on the slide during the next coop transfer. 

During the first coop transfer, I observed two birds on the 

platform directly under the elevated coop and during the 

second transfer, four birds jumped from the slide to the coop 

transfer platform causing the operator to stop and remove 

them. , 

, and Plant Manager Todd Coppedge were 

notified and shown the issue(s). Corrective Action:  Team 

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

Members will closely monitor any loose poultry.  If any poultry 

is observed on the platform, operations will stop and the poultry 

will be removed immediately. Preventive Measure: 

Management will contact Maintenance to evaluate the 

possibility of altering the angle of the Slide so that poultry will 

be completely transferred to the conveyor belt. 

Documented by 

(b) 

(6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 146 

EstNbr EstName 

P6164A Foster Poultry 

Farms 

Task_Code 

04C05 

MOI# 

OIJ491408 

3807G 

Date 

07AUG2018 

Description 

On August 3, 2018, at approximately 1250 hrs, I, 

, conducted a Good Commercial Practices 

(b) (6)

inspection verification task outside the establishment building 

at the cage dump station. I observed a cage module 

resting stationary in full-tilt, approximately 50 degrees.  Inside 

the cage was a live bird; the bird was hanging snagged by its 

foot, between the cage wire and cage door.  The bird 

exhibited visible and audible signs of distress.  A second live bird 

was the same module in another compartment, but did not 

appear in distress.  I observed that the cage dump control 

station was unmanned.  For approximately sixty seconds I 

stayed in the area and observed conditions.  The cage dump 

station remained unmanned. I then immediately left the area to 

find establishment supervision.  In the live hang area I informed

 of my observations at the 

cage dump station. 

informed me that the dumping station is briefly unmanned 

during the hourly rotations of the the live hang employees.  I 

verbally informed 

(b) (6)

that a 

bird left in obvious visible and audible distress was not 

consistent with poultry Good Commercial Practices. I then 

observed 

(b) (6)

humanely loose the snagged bird from 

the cage and deposit it in the cage dump pit, relieved of any 

further signs of distress. 

(b) (6)

informed me that he 

would take corrective action of retraining employees to not 

depart the cage dump station until they had verified that no 

birds remained in the modules. This MOI is not linked to any 

recently issued MOI; there is not a documented pattern of 

unsatisfactory application of Poultry Good Commercial 

Practices. 

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

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 147 

EstNbr EstName 

P6616 Peco Foods of 

Mississippi 

Task_Code 

04C05 

MOI# 

IRE551008 

5530G 

Date 

30AUG2018 

Description 

, observed an Establishment employee place 

several birds into a condemned barrel in the live hang room for 

the #1 evisceration line.  I observed one of the birds take a 

breath when it was placed into the barrel.  I immediately 

notified this employee that one of the birds remained alive.  This 

employee immediately removed the bird from the condemned 

barrel, confirmed verbally to me that the bird was alive, and 

then he placed the live bird on the conveyor belt to be hung on 

At approximately 1425 hours on today, August 22, 2018, 

(b) 

(6)

the shackles for slaughter.  I was accompanied by 

, , 

, and approximately 4 additional members 

(b) (6)

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

of the Establishment’s Supervisory Team.  Therefore, I was able 

to immediately notify all present officials that the GCP 

nonconformance that occurred would be documented in an 

MOI. 

(b) (6)

verbally stated that all team members that 

are associated with the live hang operation would be retrained 

immediately to follow the procedure of performing a cervical 

dislocation on each bird followed by removal of the head prior 

to being placed into the condemned barrel.  The Establishment 

advises that they have a procedure in place regarding poultry 

GCP for the “ 

(b) (4)

” of birds.  As per Federal 

Register Docket #04-037N, establishments involved in the 

slaughter of poultry are encouraged to abide by Good 

Commercial Practices. 

entered in for This was 

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

originally entered in on the 8/24/2018, was not entered 

through GCP task This is to correct that action. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 148 

EstNbr EstName Task_Code MOI# 

P6651 Tyson Foods Inc. 04C05 MSO55140 

60721G 

Date 

21JUN2018 

Description 

On 06-18-2018 at approximately 1550, at P-6651 second shift,

(b) (6)

 and 

(b) (6)

performed a GCP. A 

weak bird was discarded from live hang onto the dead belt, 

landing in the dead bird pen outside of the live hang area. It was 

breathing and shook its head twice. There was no plant live 

hang employee to retrieve the live weak bird. There were 

approximately ten dead birds already in the pen; it was a very 

hot day with many DOAs presented to the plant at the time. 

Three more dead birds followed and fell onto the live weak bird. 

A plant employee who routinely removes dead birds from the 

pen (to take by wheel barrow to offal) appeared and removed 

the dead birds covering the weak bird. The weak bird had 

already died by suffocation, or by means other than slaughter. 

(b) (6)

, was in the live hang room 

and was verbally notified of the incident and Non- Good 

Commercial Practice. I returned at approximately 1640 and 

observed another live weak bird in the dead bird pen with a 

dead bird’s neck draped over the live weak bird’s neck. There 

was no plant live hang employee in the room to remove the live 

weak bird in the dead bird pen. 

and were verbally notified by

(b) (6)

(b) (6)

weak bird. 

(b) (6)

came out of live hang and saw the 

Dr. Hertha that they would receive a MOI for the incident. As 

per Federal Register Docket #04-037N dated September 28, 

2005 “Treatment of Live Poultry before Slaughter”, the Food 

Safety Inspection Services strongly encourages all 

establishments engaged in slaughtering of Poultry to make 

every effort to treat poultry humanely, and abide by Good 

Commercial Practices as described in industry guidelines. A 

copy of this MOI will be forwarded to the DVMS at the Jackson 

District Office. Respectfully, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 149 

EstNbr EstName Task_Code MOI# 

P6651 Tyson Foods Inc. 04C05 MSO57170 

85607G 

Date 

07AUG2018 

Description 

MOI – P-6651-2 Tyson Foods, Inc. 08-06-2018 On 8/6/2018, at 

16:47 hours, at P-6651 second shift, while performing a GCP, Dr.

(b) (6)

 witnessed a live breathing bird with bright eyes 

and subtle head movement (without neck cut) on line one, 

going to the scalder. 

(b) (6)

stopped the scalder line 

immediately as the bird's head was about to enter the scalder, 

and immediately pulled the bird off its shackle. All 

establishment intervention steps to comply with 9CFR 381.65(b) 

had been surpassed, but for the actions of USDA personnel, the 

live bird's entrance into the scalder was eminent. 

showed the bird to 

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

, who 

was in the live hang dead bird room and notified him verbally, 

of the incident and Non- Good Commercial Practice. Next, 

showed the empty shackle at the scalder 

where the bird was removed. The bird was given to a live hang 

(b) (6)

(b

) 

(6)

employee and put back into process. And the line was turned 

back on. Shortly after, and 

, were verbally notified by that they 

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

(b) (6)

would receive a MOI for the incident. At around 1800 hours, I 

discussed the incident with 

. stated that an employee would be 

stationed at the pre-scalder area as back up until they resolve 

(b) (6)

(b) (6)

the issue in the neck cutting area. As per Federal Register 

Docket #04-037N dated September 28, 2005 “Treatment of Live 

Poultry before Slaughter”, the Food Safety Inspection Services 

strongly encourages all establishments engaged in slaughtering 

of Poultry to make every effort to treat poultry humanely, and 

abide by Good Commercial Practices as described in industry 

guidelines. A copy of this MOI will be forwarded to the DVMS 

at the Jackson District Office. Respectfully, 

(b) (6)
1111 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 150 

EstNbr EstName Task_Code MOI# 

P7101 Tyson Foods, 04C05 LUC251605 

Inc. 2222G 

Date 

22MAY2018 

Description 

, was notified in the live 

receiving area at Tyson Foods, Inc., P-7101 located in Clarksville, 

, was conducting a Good Commercial Practice task.  I 

observed a live bird in the DOA bin.  The bin was over full. There 

were several dead birds behind the bin that had fallen out.  I 

notified an establishment team member about the live bird in 

the DOA bin.  The employee removed the live bird. 

(b) (6)

At approximately 2345 hours, on May 16, 2018, I, 

(b) (6)

Arkansas.  I then returned to the USDA office and informed 

about the incident.  I had to assume Carcass

Inspection activities at CI-1.  notified 

, about my

(b) 

(6) (b) (6)

(b) (6)

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

observation.  She informed that the establishment 

would be receiving an MOI.  She told that 

should stress the importance to live hang team members of live 

birds not being placed in the DOA bin with dead birds, since 

this may lead to birds dying by means other than slaughter 

incident would be discussed in the weekly exit meeting. I, 

, certify that this MOI documents the entire

(b) (6)

(b) 

(6)

(suffocation).  also informed that this 

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

discussion and actions taken surrounding this incident. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 151 

EstNbr EstName Task_Code MOI# 

P7101 Tyson Foods, 04C05 LUC571607 

Inc. 2702G 

Date 

02JUL2018 

Description 

On 06/25/2018 at approximately 2120 hours, while performing 

a GCP task, I observed three birds under the bird dumper’s 

supporting framework. The birds had the appearance of being 

there for a while, with their feathers drenched and covered in 

feces and other debris.  Two of the three birds had broken legs 

and one of the two seemed to be suffering due to its injuries.  I 

notified the 

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

about the 

birds.  , promptly, had the two injured birds removed 

by a Tyson team member.  I did not have the chance to observe 

what disposition was made in regards to the two injured birds.  I 

waited by to observe the removal of the remaining bird by the 

(b) (6)

. Upon my return to the 

Live Hang area, I observed the birds that had been removed, 

from under the dumper, sitting on the Live Hang belt.  The line 

was down early, for Company break, due to mechanical issues. 

Since break had just started a couple of minutes earlier, I knew 

the birds would be idle on the belt for approximately 30 

minutes.  The two injured birds seemed to be suffering.  I went 

back outside, to the dumping area to inform 

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

that the 

birds had been placed on the belt.  entered the Live 

Hang area to tend to the injured birds.  He, with the assistance 

of 

(b) (6)

, humanely euthanized the two injured birds. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 152 

EstNbr EstName 

P7101 Tyson Foods, 

Inc. 

P727 Simmons 

Prepared Foods, 

Inc. 

Task_Code 

04C05 

04C05 

MOI# 

LUC370009 

1911G 

VCF470208 

0129G 

Date 

11SEP2018 

29AUG2018 

Description 

On 09/05/2018 at approximately 2118 hours (lot #4), I was 

conducting an Ante-mortem and GCP (Good Commercial 

Practice) task.  After completing the Ante-mortem portion of the 

task, I chose to observe line 1 for GCP compliance.  I first stood 

behind the back-up kill team member and observed 16 birds 

pass through the kill machine’s blade uncut.  The team member 

successfully caught all 16 birds and bled them properly, as per 

policy.  I then moved down the line to observe for live birds 

entering the scalder.  I did notice that, for this particular lot, the 

birds were very inconsistent in size, with some very large in 

comparison to some very small.  I witnessed two birds enter the 

scalder, which had obvious signs of life still remaining.  One of 

the birds had been cut diagonally across the upper part of his 

head, near the cone; the other bird had been only slightly cut on 

his neck.  I had the line stopped and notified 

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

investigated the incident 

further by examining birds in the condemn barrel at the rehang 

station.  He had pulled two birds from the barrel, consistent 

with the previously described cuts.  The birds were red skinned 

with clotted blood inside the carcasses, which is an indication of 

cadaver birds.  FSIS Notice 44-16, dated 06/27/2016, 

states, “If FSIS personnel observe evidence of an isolated 

instance in which a bird still breathing when it entered the 

scalder, but the system is otherwise under control, there is no 

basis for regulatory control action at that point.  IPP should 

discuss the isolated instance with the establishment and 

document the discussion in a mistreatment MOI.  This serves to 

bring to the establishment’s attention that live poultry must be 

treated in a manner consistent with GCPs.” 

As I was doing my GCP task at 0039,  I observed excessive 

amount of chickens (50-60) on the floor at the end of both line 

one and two. 

(b) (6)

came up to me and 

told me that they had a plan to clean that up and they stopped 

hanging for a few minutes and they proceeded to euthanize the 

chickens and 

(b) (6)

also told me that he slowed the lines 

down to compensate the small birds.  I was able to proceed with 

my GCP task. 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 153 

EstNbr EstName Task_Code MOI# 

P7485 Wayne Farms 04C05 QBM31170 

LLC 72431G 

Date 

31JUL2018 

Description 

On July 30, 2018, at approximately 1830 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 small in 

frame and standing on top of other DOA’s.  The bird was alert 

and appeared to be unharmed.  I notified the forklift driver that I 

needed a supervisor called to the area.  The forklift driver 

entered live hang but was unable to locate anyone.  I then 

requested the truck driver locate a supervisor when he returned 

to the area.  At approximately 1845 hours while I was waiting 

for a supervisor, a second (2nd) live bird came down the DOA 

conveyor belt as other DOAs were being run into the dumpster. 

The bird was large frame, alert and responsive.  As I was 

continued to wait, a lead entered the area and I informed him of 

2 live birds in the DOA dumpster.  He then called for 

.  When management 

arrived, Shift Manger Julio Duran, 

and the were 

present.  I showed my findings to members of management. 

(b) (6)

(b) (6)

(b) 

(6) (b) (6)

immediately removed the birds 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: cc 

(b) (6)

(b) (6)(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 154 

EstNbr EstName Task_Code MOI# 

P7485 Wayne Farms 04C05 QBM18230 

LLC 94524G 

Date 

24SEP2018 

Description 

immediately came to the area.  I showed him the 

live bird in the dumpster and he immediately removed it.  He 

performed rapid cervical disarticulation on the bird.  I informed

On September 24, 2018, at approximately 2250 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 and was sitting on top of other DOAs. The bird 

was alert and appeared to be unharmed. There was no 

denaturant on the bird on any other birds on the top layer in 

the dumpster. I observed the DOA belt to ensure it was not 

operating and it was turned off.  This was cited as part of the 

previous corrective actions from similar incident on July 30, 

2018. I notified the forklift driver that I needed a supervisor 

called to the area. The forklift driver motioned for a 

maintenance person nearby to call for a supervisor. 

(b) (6)

(b) (6)

of the documentation of this 

Memorandum of Information (MOI).  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, 

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

cc: 

cc: 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 155 

EstNbr EstName Task_Code MOI# Date Description 

P764 Perdue Foods, 04C05 CUA04070 28AUG2018 

LLC 85328G 

Establishment P-00764, Perdue Foods, LLC, Salisbury, MD 

(Raleigh district, circuit 8017) In attendance: USDA: 

Plant management: 

, 

, 

Poultry welfare concern: 

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

At 0738 while performing the poultry Good Commercial 

Practices check in the receiving department, the Dead On Arrival 

(DOA) bin was checked.  The bin was about 1/3 full of bird 

carcasses and all were denatured with liberal amounts of blue 

dye.  One bird (on top) was observed for multiple minutes to be 

actively breathing .  It was weak and not apparently conscious. 

This bird also was denatured. 

immediately notified and shown this bird - he elected to 

(b) (6)

was 

euthanize the bird via cervical dislocation. I spoke with 

, , and and 

(b) (6)

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

reminded them that agency regulations require that live poultry 

be handled in a manner consistent with good commercial 

practices and that they not die by causes other than by 

slaughter: birds that are alive and piled up in a DOA tank with 

dead birds could suffocate and/or be rendered while still alive.  I 

notified them that this poultry mistreatment Memorandum Of 

Interview would be forwarded to the District Office and the 

District Veterinary Medical Specialist (DVMS). 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 156 

EstNbr EstName 

P7669 Turkey Valley 

Farms LLC 

P7669 Turkey Valley 

Farms LLC 

Task_Code 

04C05 

04C05 

MOI# 

RZB051306 

4511G 

RZB531207 

1504G 

Date 

11JUN2018 

04JUL2018 

Description 

Est. 7669p, Turkey Valley Farms, June 11th, 2018. In 

attendance: 

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

, Mr. Les Goff, Plant Manager, 

and . At 

approximately 1215 hours a discussion was held concerning 

observations in the live hang department. An increase in birds 

hanging by one leg has been observed in the live hang 

department in the last week. On 6/11/18 at approximately 

1150 hours while performing a routine Good Commercial 

Practices task I observed 15 out of 150 birds (heavy toms) 

hanging by one leg on the line in the live hang department. I 

immediately notified 

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

and took a regulatory control (b) (4)

action to reduce the line speed by 10% from birds per 

minute down to birds per minute. At approximately 1200 

hours, I observed 5 out of 40 birds hanging by one leg. I 

immediately notified 

(b) (6)

and took a regulatory control 

action to reduce the line speed by an additional 10% down to 

48 birds per minute. At approximately 1215 hours, I observed 2 

out of 100 birds hanging by one leg. At this time I discussed the 

issue with Mr. Goff and 

(b) (6)

. The establishment was 

notified on 6/7/18 of an increase in birds hanging by one leg 

during GCP task. We also discussed that the establishment’s 

Good Commercial Practices program states that all birds must 

be shackled with both legs in the shackle and under the 

establishment’s NTIS program, the upper limit is 1% of birds 

hanging by one leg. Mr. Goff stated that they would be keeping 

a closer eye on this issue as they are currently short-staffed.  An 

additional check was performed at approximately 1225 hours, 

at this time I observed 0 out of 100 birds hanging by one leg, 

the line speed was timed at 48 birds per minute. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 157 

EstNbr EstName 

P768 Tyson Foods, 

Inc. 

P7903 Perdue Foods, 

LLC 

Task_Code 

04C05 

04C05 

MOI# 

BFC110209 

4221G 

UYN41190 

82009G 

Date 

21SEP2018 

09AUG2018 

Description 

I 

(b) (6)

, while performing the Good Commercial 

Practices check at 2115 on September 20, 2018 observed a very 

substantial swarm of flies (estimated in the 1,000’s) in and 

around a long green waste management bin.  The bin was filled 

with feed and chicken manure and was sitting under the smaller 

live haul shed where empty live haul trailers are often parked. 

The bin acted as a harborage, breeding, and swarming site for 

the flies.  The bin was on the establishment premises and was 

not far from the frozen and fresh shipping docks.  9CFR 416.2 

states that Establishments must have a pest management 

program to prevent the harborage and breeding of pests 

At approximately 1705 hours, while giving inspector relief 

breaks on evisceration line number three, numerous cadavers 

and poor-bleed-outs were observed at the inspection stations. 

was notified of 

these findings and shown the carcasses involved.  He indicated 

that he would check the process and return when he had 

completed his evaluation.  Within a 

fifteen-minute-period-of-time, numerous other cadavers and 

poor-bleed-outs continued to enter the inspection stations.  This 

issue was discussed with plant management on Monday, August 

6, 2018 and on Tuesday, August 7, 2018 having seen similar 

conditions present at the inspection stations on evisceration line 

number three.  Evisceration line number three was stopped and

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

 was again notified of the issue and shown the 

affected carcasses.  The evisceration and kill line were slowed 

down by twenty-percent.  After completing the relief breaks,

(b) (6)

 and I discussed the findings and he indicated that the 

kill blade was not set up correctly and that maintenance needed 

to adjust the angle of the blade to allow for a more thorough kill 

cut.  Upon verification that the process was back in control, the 

line was permitted to resume to normal processing speed. 
I 

I 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 158 

EstNbr EstName Task_Code MOI# 

P7927 AMICK FARMS, 04C05 YGC331408 

LLC 3927G 

Date 

27AUG2018 

Description 

This Memorandum of Interview documents a situation that 

occurred on the evening of 8/21/18 between approximately 

1840 -1930 hours. On 8/21/18 at approximately 1840 hours I, 

(b) (6)

, entered the paw/giblet area of the 

establishment and noticed that multiple lights were off. The 

establishment was not operating in the area and both 

evisceration lines were stopped at the time. I was informed that 

an air compressor was not operating causing the down time. I 

proceeded into the kill room where I observed that kill line #1 

had no birds hanging on it from the point of the live hang room 

through the kill blade; however, kill line (b) (4)

had live birds 

hanging in the shackles from the live hang room through the 

stunner, and into the kill blade. The stunner for kill line #2 was 

raised up in its operating position and the birds in the stunner 

were hanging with their heads submerged in the water. At the 

time, the kill lines were stopped and there were no backup 

killers present in the area. I entered the live hang area and there 

were no live hang employees in the room other than the line 

leader, Irvine, and he informed me that the employees in live 

hang and the kill room had been sent to lunch following the 

break down. I immediately requested that Irvine call a 

supervisor to the area. I informed him that the stunner for line

(b) (4)

 was still raised and that there were more than 30 birds 

hanging with their heads submerged in the stunner water. He 

immediately went to the area and at approximately 1848 hours 

he lowered the stunner for kill line (b) (4)

. The birds hanging in the 

stunner were not moving and no respiratory efforts were 

observed. One bird from within the stunner was removed from 

the line and placed aside. Upon removal from the stunner, the 

bird was observed to have no rhythmic breathing, no response 

to stimulation, no corneal or nictitating membrane reflex, and 

the bird’s pupils were dilated. This bird was again observed 

approximately 6 minutes later and no rhythmic breathing, 

movement or response to stimulation, or corneal reflex had 

returned and the bird’s pupils remained dilated. These findings 

are supportive that the bird was no longer alive. 

, an

 entered 

the area soon after the stunner was lowered by the line leader 

and I informed them of my observations. stated 

(b) (6) (b) 

(6) (b) (6)

that they had not lowered the stunner initially because the line 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 159 

EstNbr EstName Task_Code MOI# Date Description 

marked the birds in the stunner by tagging the shackles 

of the first and last bird with no rhythmic breathing. He stated 

that they would run the line to make sure that all birds left 

hanging on the line were appropriately stunned and killed, and 

all birds that had died in the stunners would be removed and 

disposed of by the establishment. I discussed with 

and 

(b) (6)

that these findings were not consistent with 

the establishment’s crisis management plan and that allowing 

the birds to remain submerged in the stunner water for a 

prolonged period resulting in death of the birds was not 

operating in accordance with good commercial practices. I 

informed 

(b) (6)

and 

(b) (6)

that I would document 

an MOI to discuss these findings and our conversations. I 

observed the establishment run all birds on the line through the 

stunners and kill blade appropriately and dispose of the 38 birds 

that had died in the stunners. Thank you, 

had been starting and stopping, so they weren’t sure when it 

would start again. However, at the time of my observation the 

employees had been released for their half hour lunch break 

and the stunner still had not been lowered leaving birds with 

their heads submerged in the water. Additionally, many birds 

were left hanging on the line when employees were released 

during the break down to go to lunch. I asked how long was left 

in the lunch break and was told approximately 17 more 

minutes. According to the establishment’s crisis management 

plan, if the establishment is down for greater than 20 minutes, 

all live birds hanging up to the stunners are to be removed from 

the line and placed onto the live hang belt, or back into cages. I 

informed them that these birds would be on the line greater 

than 20 minutes and asked how they planned to proceed. 

(b) 

(6) (b) (6) (b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 160 

EstNbr EstName 

P843 Pilgrims Pride 

P843 Pilgrims Pride 

Task_Code 

04C05 

04C05 

MOI# 

PZA051206 

1001G 

PZA411406 

3704G 

Date 

01JUN2018 

04JUN2018 

Description 

Approximately 1055 hours while I was performing a GCP Task 

designated by 

(b) (6)

I observed alive bird at 

DOA dumpster.  It was on top of the pile and they don’t have 

denaturant on it during that time. This bird was small, tiny, 

breathing, blink his eyes, moving his head and kicking couple 

times approximately for few minutes. During that time there 

was no supervisor around in that area. I asked one of the team 

members to get his supervisor. I pointed out the live bird to 

and his team member. 

(b) 

(6)

The lead person picked the bird up and saw that it was 

breathing, moving its head, and blinking.  He agreed that it was 

alive.  At this time, he had the bird humanely euthanized via 

cervical dislocation. 

(b) (6)

was notified of this issue 

regarding the live bird at DOA dumpster. 

At 0958 hours, while performing a Good Commercial Practice 

(GCP) task, I observed a live bird in a yellow condemn barrel. 

The bird weighed approximately 10 pounds. The bird was still 

breathing. His head was under another bird. The condemn 

barrel was located in the Live Hang Area behind the hangers. At 

that time there was no team member or supervisor in the area. I 

asked a Maintenance Man, who was in the area, to call the Lead 

Person for me. I then showed the Lead Person that the bird was 

still breathing. He removed the bird from the condemn barrel 

and placed it on the line. He did not know how the bird got into 

the condemn barrel. I asked him to call 

. I then notified 

, of the failure to meet regulatory requirements and 

the plant’s Goode Commercial Practices criteria. This is a 

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

repeat MOI for failing to maintain Good Commercial Practices. 

See MOI PZA01120638011, dated 5/31/18. 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 161 

EstNbr EstName Task_Code MOI# Date Description 

P843 Pilgrims Pride 04C05 PZA200906 22JUN2018 

2022G 

Present at incident: USDA: ; 

Pilgrim’s Pride Management: 

, and 

Establishment P843, Pilgrim’s Pride 

(b) (6)

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

Corporation, Marshville, NC. On 6/22/2018, at approximately 

0704 hours, while performing a Good Commercial Practices task 

in the Live Hang Room, I noted a yellow condemn barrel in close 

proximity to the DOA table on the right.  Inside the barrel one of 

the three birds at the bottom was still breathing and I observed 

contractions of the cloacal region.  This bird was upside down 

with its rump in the air and its head was not visible to me while 

making these observations.  The live hang lead was called to the 

barrel and shown the live bird.  The lead removed the bird and 

placed it on a table. 

, arrived and I informed him that this live bird was

(b) (6)

(b) (6)

found smothered in the condemn barrel. 

(b) (6)

called 

, to Live 

Hang Room.  During this time, the bird did not appear alert but 

was breathing and spastically stretching.  The bird died shortly 

after being removed from the condemn barrel and it is likely 

that it succumbed to being smothered. 

(b) (6)

was made 

aware that any live bird not deemed healthy to hang on the line 

for slaughter must be humanely euthanized prior to being 

placed in a DOA condemn barrel.  I later called 

to ensure that she was apprised of the situation and of 

(b) (6)

the fact that a GCP MOI would be written as a result.  A trend 

appears to be developing, as previous memoranda have been 

written on 5/31/2018 and 6/4/2018 for similar findings.  In the 

memorandum dated on 5/31/2018 (MOI# PZA0512061001G), a 

live bird found at the top of the pile in the DOA Bin was 

attributed to ineffective training and the preventive measure 

cited was to ensure retraining of all day shift team members on 

proper DOA handling procedures and proper euthanasia 

technique.  In the memorandum dated on 6/4/2018 (MOI# 

PZA4114063704G), the live bird found smothered in the 

condemn barrel was attributed to human error.  Preventive 

measures listed included: 1. Use of trained personnel to move 

DOAs from the table to a method of transport to the DOA bin, 2. 

Once loaded in the method of transport, DOAs will be taken 

directly to the DOA bin, and 3. Condemn barrels used as the 

method of transport will not be placed in proximity to the DOA 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 162 

EstNbr EstName Task_Code MOI# Date Description 

table until they are actively being loaded.  It is apparent that 

these preventative measures have not been proactive or 

effective in ensuring that birds entering the establishment do 

not die from causes other than slaughter.  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.  It is the 

establishment’s responsibility to ensure that birds are 

slaughtered in accordance with 9 CFR 381.65(b). 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. If you have any questions or concerns 

regarding this MOI, please feel free to contact myself or 

. Respectfully, 

(b) (6) (b

) 

(6)

P935 Allen Harim 04C05 YXA171405 18MAY2018 At approximately 1509 hours on April 27, 2018 while 

Foods, LLC. 0418G performing antemortem and GCP verification I observed 1 loose 

live bird on trailer #62 located in the cooling shed.  At 

approximately 1521 hours I observed 1 loose live bird on trailer 

#6886 and 1 loose live bird on trailer #5780 (3 cage doors were 

open).  These trailers were located just outside the dumping 

area in a high traffic area for trucks and forklifts.  As I was 

waiting for the live hang supervisor I observed a forklift come 

around the 2 trailers at a very high speed.  As he rounded the 

trailers a cage door flew open and 2 live birds were thrown to 

the concrete approximately 6 feet below. 

and 

were notified the observation in which poultry may have 

(b) (6)

(b) (6)

experienced excitement, discomfort or accidental injury while 

being handled in connection with slaughter. 

addressed driving speed with the fork lift drivers especially when 

(b) (6)

making sharp turns. 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. 

(b) (6)

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, 

(b) (6)
 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 163 

EstNbr EstName 

P935 Allen Harim 

Foods, LLC. 

Task_Code 

04C05 

MOI# 

YXA521605 

5821G 

Date 

21MAY2018 

Description 

was notified of the observation in which poultry 

may have experienced excitement, discomfort or injury while 

being handled in connection with slaughter. 

(b) (6)

stated 

that the employee will receive disciplinary action. At 

approximately 1606 hours while traveling to the line to provide 

inspection breaks I observed a carcasses hanging on the 

Veterinary disposition shackles behind line 3, station 2.  Upon 

further investigation, I observed t the carcass had the head 

intact which was red to purple in color and had not received a 

At approximately 1532 hours while verifying Good Commercial 

Practices I observed the second back up kill employee cut into a 

full crop of a bird as it traveled in front of him.  As the bird 

traveled in front of me I observed feed falling out of the cut 

crop, the bird had its head in a raised position and looking 

around.  I did observe that the bird received a cut to the neck as 

blood was dripping from the neck. 

(b) (6)

cut to the neck. and 

were notified of the cadaver and

(b) (6)(b) 

(6)

DOA.  had a second back up kill employee added to line 

(b) (6)

3 for the remainder of the week. It is recommended that 

establishment management review the Federal Register on 

“Treatment of Live Poultry before Slaughter”, published 

September 2015 for FSIS recommendations concerning 

treatment of live poultry prior to slaughter. 

(b) (6)

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, 

(b) (6)
 

Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 164 

EstNbr EstName 

P935 Allen Harim 

Foods, LLC. 

Task_Code 

04C05 

MOI# 

YXA191805 

5524G 

Date 

24MAY2018 

Description 

At approximate 1703 hours, while performing Good Commercial 

Practice verification I observed one live bird enter the scalder. 

(b) (6)

was notified of the 

observation. 

(b) (6)

and I returned to the scalder 

where I pointed out a second live bird enter the scalder.  Mr. 

Gonzalez-Ballar stated that he the bird had a cut to the neck.  I 

explained to him that the regulation states no live birds are to 

enter the scalder.  Both of the birds observed had received a cut 

to the neck however, they were alert with their head slightly 

raised and breathing. 

(b) (6)

made an adjustment 

to the kill blade.  I verified the corrective action by observing no 

live birds out of approximately 735 birds enter 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. 

(b) (6)

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, 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 165 

EstNbr EstName Task_Code MOI# Date Description 

P935 Allen Harim 04C05 YXA130906 05JUN2018 

Foods, LLC. 1905G 

To: Mr. Kevin Gordon, Plant Manager. CC: 

. This memorandum of interview 

(b) (6)

(b) (6)

serves as written notification of occurrence of two Cadaver 

found on USDA line 3 inspections stations 3 and 4 respectively, 

one on each line today June 5, 2018. At approximately 8.35am 

a CSI told me those inspectors on line three station three and 

four hold two carcasses for Veterinary disposition and notified 

me accordingly. Upon arriving at their stations I observed that 

the head of the carcasses are 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.

 and 

(b) (6)

was Present 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 

(b) (6)

concern. Sincerely. 

(b) (6)

CC: 

(b

) 

(6)
(

 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 166 

EstNbr EstName 

P935 Allen Harim 

Foods, LLC. 

Task_Code 

04C05 

MOI# 

YXA272106 

3105G 

Date 

05JUN2018 

Description 

At approximate 1923 hours, on May 31,2018 while performing 

Good Commercial Practice verification, I observed one live bird 

enter the scalder. The bird was alert with its head raised, eyes 

blinking, flapping around, breathing and the bird had been 

placed in the shackle backwards. 

was notified of the observation.  I observed the 

(b) (6)

lines for approximately 10 minutes and did not observe any 

additional live birds enter the scalder. I notified 

and 

of this deviation and a MOI will be issued. It is 

recommended that establishment management review the 

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

Federal Register on "Treatment of Live Poultry before 

Slaughter", published September 2005 for FSIS 

Veterinary Medical Specialist (DVMS) in case additional 

follow-up is recommended. Respectfully, 

Allen Harim Foods, LLC. P-935 Harbeson, DE. 

(b) (6)

P935 Allen Harim 04C05 YXA591806 14JUN2018 At approximately 1916 hours, while performing Humane 

Foods, LLC. 3614G Handling and Good Commercial Practice verification I observed 

a bird dying other than by slaughter. At approximately 1947 

recommendations concerning treatment of live poultry prior to 

slaughter. and were notified that this MOI 

will be forwarded to the District Office and the District 

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

a bird in the cooling shed that had been run over by a trailer 

tire. 

(b) (6)

was notified of 

hours, was notified of the 

observation of a bird dying other than by slaughter. 

stated that the driver who picks up the trailers from 

the cooling shed will be instructed to around and under the 

(b) (6)

(b) 

(6)

trailer(s) prior to removing them from the cooling shed. 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. 

(b) (6)

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, , 

Harbeson, DE. 19951 

(b) (6)

(b) 

(6)
 

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 167 

EstNbr EstName 

P935 Allen Harim 

Foods, LLC. 

Task_Code 

04C05 

MOI# 

YXA051406 

0315G 

Date 

15JUN2018 

Description 

At approximately 1100 hours I observed a live bird, with head 

raised and breathing, at a point past the kill blade and back up 

killer, approximately 6 foot from entering the scalder.  The

(b) (6)

 was standing next to me 

and I pointed the bird out to him. 

(b) (6)

stopped the 

kill line and had the bird removed and placed back on the 

hanging belt.  I then observed approximately 147 birds when I 

observed a second live bird, with head raised and breathing, at 

the same location.  Again the kill line was stopped and the bird 

removed.  I then observed 500 birds with no further observation 

of live birds at the location prior to the scalder. 

provided a verbal preventive of kill blade adjustment, 

replacement of the backup kill person and disciplinary action.

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

 was notified of the forthcoming MOI as, short of 

my intervention, these live bird would have entered the scalder 

still breathing. 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. 

(b) (6)

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. Respectively, 

Allen Harim Foods, LLC. P-935 Harbeson, DE. 19951 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 168 

EstNbr EstName Task_Code MOI# Date Description 

P935 Allen Harim 04C05 YXA351406 19JUN2018 At approximately 2015 hours while providing inspection breaks, 

Foods, LLC. 0819G an inspector called for me and had 3 carcasses hanging on the 

Veterinary disposition shackles behind line 1, station 3.  The 

carcass’s head and neck were dark red to purple and had not 

received a cut to the neck. 

was notified of the observation of bird dying 

other than by slaughter.  contacted the 

of each observation of cadavers on 

line 1, who investigated the cause. later stated 

that the responsible employee was terminated.  It is 

(b) (6)

(b) (6)(b) 

(6) (b) (6)

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 

Harim Foods, LLC. P-935 Harbeson, DE.  19951 

Medical Specialist (DVMS) in case additional follow-up is 

recommended. Respectfully, 

(b) (6)

Allen 

(b) (6)
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 169 

EstNbr EstName Task_Code MOI# Date Description 

P935 Allen Harim 04C05 YXA040806 28JUN2018 

Foods, LLC. 0928G 

At about 5.25 am while performing Ante mortem and GCP I 

observed that the live birds are being piling up on 

each other on the live hang running belt which was not moving 

and birds are falling on the ground. I immediately notified

 in the office he saw and started helping to hang and 

remove the birds form the belt. 

of the 1st process area came and observed the same 

(b) (6) (b) 

(6)

(b) (6)

happing above. He also started helping his team. I remained 

there for about 25 minutes and more than 300 birds were 

counted to be dead due to suffocation and mismanagement. 

The agency regulations do require that poultry must be 

slaughtered in accordance with good commercial practices in 

manner that will result in, so that birds do not suffocate or die 

other than slaughter. It is the agency expectation that all Good 

Commercial Practices be correctly and effectively implemented. 

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.  were notified 

that this MOI will be forwarded to the District Office and the 

(b) (6)

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-2019-18 170 

EstNbr EstName 

P935 Allen Harim 

Foods, LLC. 

Task_Code 

04C05 

MOI# 

YXA310807 

3107G 

Date 

07JUL2018 

Description 

Ante-mortem check performed on lot 1at about 10.40am. No 

concerns. Verified GCP which was in compliance with 

regulations. Dumper and belts in good condition, Birds were 

housed properly, humanely handled; Birds appeared to be in 

good health. DOA’s removed and denatured properly, Stunning 

was having some issues.Notified 

(b) (6)

and they 

fixed the problem.  and Killing was effective, no loose bird in live 

hang, live haul and holding sheds.  This memorandum of 

interview serves as written notification of occurrence of one 

Cadaver found on USDA line 3 inspections stations 3, today July 

6, 2018. At approximately 10.40am a FI on line three station 

three informed me that she observed cadaver carcasses on her 

station and hanged it for Veterinary disposition. Upon arriving at 

their stations 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. No line supervisor 

was present at that time, told to call 

) and notified and showed him 

the cadaver bird. He assured me to take proper measures to 

(b) (b) (6)

(6)

prevent recurrence.  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)
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 171 

EstNbr EstName 

P935 Allen Harim 

Foods, LLC. 

Task_Code 

04C05 

MOI# 

YXA391707 

2610G 

Date 

10JUL2018 

Description 

On 7/5/18 at approximately 2015 hours while performing 

ante-mortem and Good Commercial Practice (GCP) verification, I 

observed a bird in the cooling shed that had been run over by a 

trailer tire.  As I continued the verification task I observed live 

birds roosting on an open cage door.  This open cage was on a 

trailer that was being transported from the cooling shed to the 

live receiving area. 

(b) (6)

was 

notified of the observation of a bird dying other than by 

slaughter. In the past 90 days (4/5/18 through 7/5/18) there 

have been 13 GCP MOIs written which document a trend where 

birds are not being slaughtered in a manner that result in birds 

entering the scalder before their breathing has stopped, or that 

otherwise involves their being handled in a way that results in 

their dying other than by slaughter.  Below are the causes for 

the documentation of the MOIs and the establishment’s 

response for each: 4/6/2018 – Four carcasses with no cut to the 

neck hung back on the Veterinary disposition shackle of line 3. 

Establishment response – Adjustments were made to the kill 

machine.  In addition, the backup killers were verbally 

counseled on proper slaughter practices.  A member of 

supervisor the team will monitor kill machine and back up 

killers’ performance twice on 4/7/18. 4/26/2018 – one live bird 

entered the scalder. Establishment response – The backup killer 

was disciplined according to company policy for poor job 

performance.  In addition modifications were made to the 

stunner and kill machine to improve performance. 

4/27/2018 – One carcass with no cut to the neck hung back on 

the Veterinary disposition shackle of line 3. Establishment 

response – The backup killers and the leads were retrained on 

proper stunning and slaughter practices.  A member of the 

supervisory team will monitor the associates’ job performance 

once on 4/30/18 and 5/1/18 to ensure proper slaughter 

practices are being followed. 5/1/2018 – Five carcasses with no 

cut to the neck hung back on the Veterinary disposition shackle 

of line 3. Establishment response – The backup killer was new 

and not experienced.  A second back up killer will be placed on 

the line for the remainder of the week to assist the new back up 

killer. 5/21/2008 – One carcass with no cut to the neck hung 

back on the Veterinary disposition shackle of line 3. 

Establishment response – The associates were verbally 

counseled on importance of following GCP.  In addition to verbal 
Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 172 

EstNbr EstName Task_Code MOI# Date Description 

counseling, the area supervisor monitored the back up killer’s 

job performance twice on 5/21/18. 5/24/2018 – Two live birds 

observed entering the scalder. Establishment response – Upon 

investigation, it was determined that the foot pusher and 

stunner were not functioning properly causing improper cuts to 

the birds.  Adjustments were made to both the foot pusher and 

stunner to improve proper cuts.  In addition, the back up killers 

received training on 5/29/18 and were also verbally counseled 

that it is their responsibility to ensure that birds are cut properly 

and to notify management immediately if too many birds with 

no cut or improper cuts are coming down the line. 

6/1/2018 – One live bird observed entering the scalder. 

Establishment response – not received 6/5/2018 – One live bird 

entering the scalder. Establishment response – The hangers 

were verbally counseled on proper hanging to ensure birds go 

through the slaughter process correctly.  The auto knife and 

stunner were immediately adjusted to maximize efficiency.  The 

entrance guide bar was also opened to help birds to feed better 

into the kill machine.  In addition, the backup killers received 

their final retraining on animal welfare and ensure birds are cut 

and cut properly.  The area supervisor will monitor that no live 

birds are entering scalder once on 6/7/18 and once on 6/8/18. 

6/5/2018 – Two carcasses with no cut to the neck hung back on 

the Veterinary disposition shackle of line 3. Establishment 

response – not received. 6/14/2018 – Observed a bird in the 

cooling shed that had been run over by a trailer tire. 

Establishment response – not received. 6/15/2018 – Two live 

birds (small bird line) observed approximately six foot from 

entering the scalder.  Management notified, line stopped and 

birds removed from the line. Establishment 

response – Adjustments were made to the kill blade.  In 

addition, the backup killer was disciplined and removed for the 

remainder of the day.  On 6/18/18, the back up killer was 

placed on the line with another back up killer for additional 

training and job performance monitoring before he will be 

allowed to be on his own.  The associates’ job performance was 

monitored twice on 6/18/18 and 6/19/18. 6/19/2018 – Three 

carcasses with no cut to the neck hung back on the Veterinary 

disposition shackle of line 1. Establishment response – Upon 

investigation, it was determined that the back up killer was 

found to be under the influence of toxic substances which 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 173 

EstNbr EstName Task_Code MOI# Date Description 

prevented him from performing his job properly.  All affected 

carcasses were condemned.  The team member responsible was 

terminated due to violation of company policy. 6/28/2018 

–Approximately 300 birds died due to birds piled on top of one 

another causing suffocation and mismanagement. 

Establishment response – Upon investigation, it was determined 

the team member in charge of the control pedal did not press 

all the way down on the pedal which prohibited the belt from 

moving properly.  The Live Receiving verbally coached all team 

members how to depress the control pedal to prevent back up 

from dumper system to hanging belt.  The Supervisor will 

monitor the team members and belts 3 times on 6/29/18. The 

repeated occurrence of birds dying otherwise than by slaughter 

indicate loss of process control for handling birds and thus not 

operating in accordance with Good Commercial Practices. 

and 

were notified of the observation of birds dying other 

than by slaughter.  stated that establishment 

(b) (6) (b) 

(6) (b) (6)

personnel will monitor the area every 30 minutes.  This 

monitoring document will be placed in the cooling shed for 

documentation.  It is recommended that the 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, 

(b) (6)

Allen 

(b) (6)

Harim Foods, LLC P-935 Harbeson, DE. 19951 
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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 174 

EstNbr EstName 

P935 Allen Harim 

Foods, LLC. 

Task_Code 

04C05 

MOI# 

YXA181607 

4013G 

Date 

13JUL2018 

Description 

At approximately 1524 hours while performing Ante-mortem 

and Good Commercial Practice verification I observed 1 live bird 

under approximately 50 DOAs on the stainless steel table at the 

end of the DOA belt.  There was a total of 78 DOAs on the 

stainless steel table at the end of the DOA belt.  I also observed 

the foot of a bird caught between the live hang belt and a green 

belt guide.  The bird’s leg was torn from the hip socket due to 

the pressure of other birds traveling over it while traveling from 

the dumper into the live hang area. 

and 

(b) (6)

(b) (6)

were notified of the observation in which poultry may have 

experienced excitement, discomfort or accidental injury while 

being handled in connection with slaughter. 

(b) (6)

stated 

that the establishment was short staffed in the live hang area. 

He contacted maintenance to investigate the area in which the 

bird’s foot was caught in order to determine how to prevent 

reoccurrence. 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. 

(b) (6)

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, 

(b) (6)

Allen Harim Foods, LLC. 

P935 Harbeson, DE.  19951 
- ■ 

-

-

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Table:Memorandums of Interview (MOIs) in response to FOIA-2019-18 175 

EstNbr EstName 

P935 Allen Harim 

Foods, LLC. 

Task_Code 

04C05 

MOI# 

YXA401307 

2516G 

Date 

16JUL2018 

Description 

At approximately 1949 hours while performing inspection 

verification on Line 3 had 1 carcass hanging on the Veterinary 

disposition shackles behind line 3, station 3.  The carcass’s head 

and neck were dark red to purple and had not received a cut to 

the observation of bird dying other than by slaughter. 

informed me that he would take the carcass for the

(b) (6)

(b) 

(6)

the neck.  was notified of 

relevant Supervisors to observe and  investigate the cause. 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

 was notified that this MOI will 

Medical Specialist (DVMS) in case additional follow-up is 

recommended. Respectfully, 

Harim Foods, LLC. P-935 Harbeson, DE. 

P935 Allen Harim 04C05 YXA321409 28SEP2018 At approximately 1317 hours while verifying Good Commercial 

Foods, LLC. 0028G Practices I observed an establishment employee carrying a live 

bird by one leg, from a trailer parked in the live receiving area, 

to the dumping area.  The employee threw the bird 

approximately 12 feet into the air over the cage around the 

excitement, discomfort or injury while being handled in 

connection with slaughter. 

(b) (6)

stated that the employee 

will receive disciplinary action. It is recommended that 

establishment management review the Federal Register on 

"Treatment of Live Poultry before Slaughter", published 

September 2015 for FSIS recommendations concerning 

treatment of live poultry prior to slaughter. 

(b) (6)

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, 

(b) (6)

Allen Harim Foods, LLC. P-935 Harbeson, 

DE. 19951 

slaughter. 

be forwarded to the District Office and the District Veterinary 

(b) (6)

Allen 

19951 

(b) (6)

dumper belt and it landed on the dumper belt approximately 4 

feet below.  was notified of 

the observation in which poultry may have experienced 

(b) (6)