Table: Noncompliance Reports in Response to FOIA2019-419 08:17 Monday, July 29, 2019 1

EstNbr EstName NR# Date Task TaskName Regs Description Status

P1241 Tyson Foods,

Inc.

MGJ31

070509

09N-1

05/09/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) Between 05:40 and 06:00, 

 observed seven or eight chicken carcasses

on the evisceration line and a condemn barrel that

contained chickens that were various shades of

red indicating that either they were poorly bled

out or had not had not been killed properly, i.e.

cadaver.  She immediately stopped the line,

notified an evisceration lead person, then notified

, who immediately went to the

 room to observe the chickens that were

to enter the scalder.  observed

three live breathing chickens between the back-up

killer and the entrance of the first operational

scalder, during this time the Line was

not running.  The chickens would have entered

the scalder had not

taken a regulatory control action.  

discussed the establishment’s failure to maintain

good commercial practices with

.  

 stated that the at the kill machine

had malfunctioned and that the back-up killer was

unable to keep-up.  To prevent any live chickens

between the killer and the first scalder from

entering the scalder, placed an

employee before the first operational scalder to

decapitate the remaining chickens on the 

 line ensuring that none of them entered the

scalder alive.  He then directed the maintenance

department inspect and repair the

killer. Operations resumed after the killer was

repaired.

(b) (6)

CLOSED

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

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

(b) (6)

(b) (4)

(b) (4) (b) (4)
Table: Noncompliance Reports in Response to FOIA2019-419 08:17 Monday, July 29, 2019 2

EstNbr EstName NR# Date Task TaskName Regs Description Status

P1307 Mar-Jac

Poultry-AL

KIL3013

052007

N-1

05/03/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) At approximately 15:50, I was informed by a CSI

that she had observed chickens on line 2 with

extremely red necks and even some with heads

attached that were red and showed signs of

improper bleeding.  I immediately went to

observe chickens on line 2, and observed

numerous chickens which fit the description that

the CSI described.  At 16:00, I proceeded to the

scalding area to observe chickens entering the

scalder.   I observed the line for approximately 2-3

minutes, during which time I saw four chickens

enter the scalder with their eyes blinking and their

necks arched, which indicated that they were

alive.  I concluded that the establishment's

process was out of control.  I immediately went to

the live hang room, and took regulatory control 

action by instructing the employees to stop

hanging chickens on line 2.  I then notified the

Live Hang Supervisor of my findings.  I went to the

auto rehang area to look for the chickens that had

entered the scalder alive, and observed the back

up rehanger remove six chickens from the line

that were a deep red color and place them into

the condemn barrel.

CLOSED
Table: Noncompliance Reports in Response to FOIA2019-419 08:17 Monday, July 29, 2019 3

EstNbr EstName NR# Date Task TaskName Regs Description Status

M6137+P6

137

Foster Farms BXL311

805133

1N-1

05/31/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) At 0746 hours on 05/31/2019 I was notified by

 there were four cadavers hanging on

the Line 4 pre-sorter rack.  notified

me that he went over to investigate the Line 4

pre-sorter station with as they

had both noticed the pre-sorter light on. 

 notified me that when he got to the

station there were already three cadavers hanging

on the rack and the pre-sorter was just pulling off

the fourth.  The cadavers had been moved to a

condemn barrel where I examined them.  Four

carcasses had no evidence of any cut marks, had

purple heads and necks and red to pink skin. 

There was also one carcass with a miscut (cut on

the back of the neck) and had evidence of not

being sufficiently bled out such as reddening of

the skin, neck and head.  had

notified me that had radioed

for and he said he

was “working on it.” I went to observe Line 4 at

the pre-sorter station and at 0758 hours I

observed the pre-sorter pull off another cadaver

with no evidence of a cut mark.  I requested 

 to go back to live hang and investigate.  I

then stopped the kill line and requested for a

supervisor to come to Line 4 pre-sorter station. 

 notified me that they were

already taking corrective actions, but did not

specify the exact actions taken.  

 then came and told me that they had

already stopped hanging and were taking

corrective actions.  I allowed them to restart the

line to run the birds out. The line was stopped for

approximately 2-3 minutes.  

reported to me that prior to 

coming to speak to me, he and 

 had met at the stunners and noticed the line

was stopped.  did not observe

anyone working on the machinery or attending to

the area at the time.  

 also arrived at the stunner and

OPEN

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

(b) (6)

(b) (6)

(b) (6)

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

(b) (6)

(b) (6)

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

(b) (6)
Table: Noncompliance Reports in Response to FOIA2019-419 08:17 Monday, July 29, 2019 4

EstNbr EstName NR# Date Task TaskName Regs Description Status

asked what was going on.  Shortly after

restarting the line, I then observed a gap on Line

4.  At approximately 0808 hours I observed birds

back on Line 4 at the pre-sorter station.  From

approximately 0809 to 0813 I observed six more

cadavers.  Four cadavers had no cut marks at all

and two had very superficial cuts to the skin with

no evidence of the carotid artery being cut.  I

immediately stopped the kill line again and

request for a supervisor. At 0816 hours I notified

 of the forthcoming

noncompliance.  I notified 

that a cluster of birds came through even though

he had previously indicated to me that they had

stopped hanging.  I explained that whatever

measures he put in place was not sufficient to

prevent birds from going into the scalder alive. He

assured me that they were not hanging but

needed the line to be running to work on the

machinery.  I notified to tag live

hang to ensure no more birds could be hung and

requested that he notify supervision that they are

not allowed to hang until corrective actions are

provided in writing.  I allowed them to start the

line back up at this time.  The line had been

stopped for approximately 4 minutes.  At

approximately 0818 hours I observed another gap

in the line.  From our discussion at the time it was

unclear why there were two gaps in the line with

birds in between if live hang was said to be

stopped the supervisor’s directions.  

notified me that he observed maintenance

attending to the machinery only once the kill line

was started back up at approximately 0817

hours.  At approximately 0900 hours 

 presented me with

corrective actions in writing stating that

procedures were reviewed with the back-up knife

employee and the knife machinery was adjusted. 

At approximately 0905 hours the Line 4 kill line

was released by to production.

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

(b) (6)
Table: Noncompliance Reports in Response to FOIA2019-419 08:17 Monday, July 29, 2019 5

EstNbr EstName NR# Date Task TaskName Regs Description Status

M45134+P

45134

Birdsboro

Kosher Farms

Corp.

FKJ581

405140

6N-1

05/02/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) On May 2, 2019 at approximately 1200 hours,

after lunch I, , was informed that the

company was currently slaughtering truck number

3.   I used one of the line inspector’s phone to

contact confirm

that during the morning antemortem inspection

he had only inspected two chicken trucks and one

truck containing ducks.  I reviewed the Poultry

Inspection-Lot Tally Sheet located at the line

inspectors station #1 to confirm that the company

was slaughtering a third truck. The current truck

did not have the benefit of antemortem

inspection.  I took immediate regulatory control

and shut off the evisceration and both kill lines.  I

informed Mr. Carlos Urieta, Plant Manager that

the third truck currently being slaughtered was

not inspected.  After confirming, his kill

department pulled the truck out of the unloading

bay.  The cages that had been removed but had

not been slaughtered were inspected by 

while I inspected the partial truck chickens

(approximately 2/3 full).  Background: The

production schedule for Thursday, May 2, 2019

provided by the plant indicated that three trucks

of chicken were to be slaughtered.  At

approximately 0600 hours performed the

scheduled daily antemortem inspection on the

two chicken trucks found at the inspection site. 

Later when the third truck arrived, plant personnel

failed to alert FSIS IPP.  This failure did not provide

IPP the opportunity to perform antemortem

inspection as required by 9 CFR 381.70(a) and 9

CFR 382.65(b) prior to slaughter activities.  Mr.

Urieta was verbally informed of the

non-compliance.

CLOSED

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 1

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

35 M112 Tyson Foods, Inc VBL291206

4426G

26JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized I observed a live chicken in one of the cages that

was set aside for rework. I notified the lead to

take corrective actions and discussed the issue

with . 

See MOI VBL150061926G for details of discussion

at weekly meeting with establishment.

80 M1234 Mountaire Farms Inc. QUI232004

3116G

16APR2019 04C05 Poultry Good

Commercial

Practices

Finalized On 4/15/2019 at approximately 3:45pm hours

while performing Good Commercial Practices

(GCPs) with ; as we were

walking towards the live bird conveyor belt and

noticed an associate tossing several birds by the

leg from one side of the table to the other side of

the table. It appeared that no birds were injured.

According to the establishment’s Animal Welfare

Programs, no birds should be tossed. I

immediately stopped the line and asked for a

supervisor. I notified 

and Plant Manager Carl Barnes of the issue and

 told the associate that it was an

improper way of handling live birds. 

told the associate to gently push the bird to the

other side. On 04/16/2019, I was notified by

 that the

establishment made some adjustments do their

conveyor belt. They decided to add a white 

divider to keep birds on one side of the conveyor

belt.

(b) (6)(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 2

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

35 M13556 Tyson Foods Inc TDB012306

5903G

03JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Establishment P13556, Tyson Foods, Inc.  June 3,

2019,1943 hours.  In attendance: 

. On June 3, 2019

at approximately 1943 hours, while observing

conditions in the DOA trailer bay in the poultry

live hang department, I, climbed

the ladder and observed one live bird in the DOA

trailer. I climbed back down the ladder notified

 of my findings. She then

climbed up the ladder to verify, then notified

 Slaughter that there was a live

bird in the DOA trailer. informed

the live hang lead and requested him to remove

the bird. then took the bird and

elected to euthanize the bird. On June 4,2019 at

approximately 1845 hours and

I went to speak with GPM Bob Taylor about the

live bird in the DOA trailer. 

and I recommended that Mr. Taylor 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. Mr. Taylor informed us

that the employees were retrained on the

handling of the birds. We notified Mr. Taylor that

this would be documented in a MOI.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 3

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

90 M17250 Tyson Foods, Inc. UQI081404

1101G

01APR2019 04C05 Poultry Good

Commercial

Practices

Finalized On Monday, April 1, 2019 at approximately 1247

hours I performed a good commercial practice

verification in the picking room. I positioned

myself at a point where I can directly view both

lines entering the scald vats. On picking line 2,

within two minutes of continuing my check I

observed one live bird of average size, still

breathing with no visible neck cuts, entering the

scald vat. The bird was hanging normally with its

head straight down blinking its eyes. I stopped the

picking line as it reached the scalders because

there were no other interventions to prevent the

bird from drowning if I had not intervened.   

While the picking line was down, I asked the

picking room attendant to locate management.

arrived in the picking room first. I notified him of

my findings and the forthcoming MOI.  

removed the live bird from the line and I released

regulatory control and restarted the line. After

discussing my findings with management I

performed an immediate retest at approximately

1255 hours; it passed.  After management

assessed the incident I had a brief discussion with

 about his assessment

and his further planned actions. I informed him

that I would be documenting a GCP MOI and

forwarding it to the District Office and the District

Veterinary Specialist in case additional follow-up

is recommended. stated that he

increased his monitoring for the remainder of the

shift. He also stated that he correlated with the

2nd shift supervisor to perform 7 additional

checks for the rest of the day. Sincerely, 

      

      

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 4

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

Gregory BrookHouser, DVM – Deputy District

Manager - AL
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 5

Dist

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Task

Code TaskName Status MOI Agenda

90 M17250 Tyson Foods, Inc. UQI461104

4216G

16APR2019 04C05 Poultry Good

Commercial

Practices

Open On Tuesday, April 16, 2019 at approximately

0913 hours I performed a good commercial

practice verification in the picking room. I

positioned myself at a point where I can directly

view both lines entering the scald vats. On picking

line 1, I observed one live bird of average size, still

breathing with no visible neck cuts, entering the

scald vat. The bird was hanging normally with its

head straight down blinking its eyes. I stopped the

picking line as it reached the scalders because

there were no other interventions to prevent the

bird from drowning if I had not intervened.   

While the picking line was down, I motioned for

the backup opener to come to my vantage point

to cut the carotid arteries. After the kill cut was

made I restarted the picking line.  Upon leaving

the picking room I notified Live/Evis GPM of my

findings and the forthcoming MOI.  After

discussing my findings with management, I

performed a retest after the lunch period at

approximately 1013 hours that subsequently

passed. After management assessed the incident

I had a brief discussion with 

 about his assessment and his further

planned actions. I informed him that I would be

documenting a GCP MOI and forwarding it to the

District Office and the District Veterinary

Specialist in case additional follow-up is

recommended. stated that he increased

his monitoring for the remainder of the shift. He

also stated that he will correlate with the 2nd

shift supervisor to perform 4 additional checks for

the rest of second shift. Sincerely, 

      

 

       Gregory BrookHouser,

DVM – Deputy District Manager - AL

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 6

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Task

Code TaskName Status MOI Agenda

25 M18866 Jennie-O Turkey Store Sales, LLC WJL58150

45904G

04APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Good Commercial Practices Meeting of Interview. 

Establishment p551, Jennie-O Turkey Store.  

Meetings to discuss a good commercial practices

concern were held on 04/03/2019 at 2:50 pm and

04/04/2019 at 9:00 am.  In attendance: 

, for the

establishment; and , for FSIS. 

At 2:45 pm on 04/03/2019, I, 

made the following observation in live hang.  The

establishment uses an enclosed conveyor system

to convey live turkeys from trailers into the

establishment.  The establishment also uses

atmospheric stunning in this conveyor system to

render turkeys unconscious.  I was standing where

stunned turkeys come out of the conveyor system

and are then hung on the picking shackle line.  I

observed the front half of a turkey carcass exit this

conveyor system.  This included the head, neck,

back, breast, and wings.  The back and abdomen

posterior to the ribs, the pelvis, and the legs were

missing.  I examined the front half of the carcass

and it appeared the carcass had been torn in half

just posterior to the ribs.  The injury appeared

recent or fresh.  There were no signs the carcass

was a DOA. A plant employee set aside the

partial carcass.  I went to get the 

, and showed him the partial carcass.  I

asked him what happened to this carcass.  I asked

if there were any pinch points or places a carcass

could get hung up in the conveyor system.  He

said he would investigate and let me know.  I said

to that there are numerous

cameras in live hang, perhaps something was

caught on tape that would show what happened. 

Later that afternoon told me the

carcass was a dead on arrival bird that had been

hung on the shackle line and subsequently got

hung up on the chutes or slides that are used

when turkeys are unloaded from the trailers. 

Then the carcass was torn in half.  Later again that

(b) (6)

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 7

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Task

Code TaskName Status MOI Agenda

afternoon told me he had been

misinformed.  He said the bird had been caught

between the truck hoist and the west wall and

when the hoist was moved up or down, the bird

was torn in half. At 9:00 am on 04/04/2019 I

had another conversation with .  He

told me the bird had been wedged between the

hoist and the wall and this was how it was torn in

half.  said all the employees in live

hang were instructed to carefully watch for any

birds falling down on to the hoist, especially if the

birds get wedged between the hoist and the wall,

and to be sure any such bird is removed.  

 said the videotape had been reviewed

and nothing definitive was seen on the tape. 

 P551, Jennie-O

Turkey Store Willmar, MN 56201

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

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 8

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Task

Code TaskName Status MOI Agenda

25 M18866 Jennie-O Turkey Store Sales, LLC WJL54140

63024G

24JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Establishment p551, Jennie-O Turkey Store. At

0345 on June 21, 2019, I, ,

made the following observation in live haul. The

establishment uses a truck hoist for raising and

lowering trucks and trailers to unload the live

birds. While standing at the front of the truck on

the driver side, I observed a bird that appeared to

be wedged between the truck hoist and the wall. 

Looking closer I observed a bird was wedged

between the hoist and the wall and was partially

gutted with approximately 3 ft. of the bird's

intestines hanging down on the outside of the

bird carcass. I went to find 

, and showed him the bird

that was still wedged between the truck hoist and

the concrete wall. tried to pull the bird

free with no success. then located

, and 

lowered the truck hoist down as it was raised up

to unload birds from the second from the bottom

row on the trailer. A live hang employee then

pulled on the bird, had to raise and lower

the lift while the employee pulled and pushed the

bird to be able to get it free from between the

truck hoist and the wall. This took approximately

2 minutes of pushing and pulling the bird and a

combination of raising and lowering the hoist to

free said wedged bird. The bird was disposed of

into the inedible trailer after it was freed. 

A similar incident happened on 04-04-19, where a

bird was wedged between the truck hoist and the

wall as mentioned in MOI WJL5815045904G. 

 P551, Jennie-O

Turkey Store Willmar, MN 56201

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 9

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Task

Code TaskName Status MOI Agenda

25 M18866 Jennie-O Turkey Store Sales, LLC WJL41050

64527G

27JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Good Commercial Practices Meeting of Interview 

Establishment P551, Jennie-O Turkey Store A

meeting to discuss good commercial practices

concern was held on 06/26/19 at 5:10 am. In

attendance: 

for

FSIS. A meeting to inform of

good commercial practices concerns was held on

06/26/2019 at 7:20 am. In attendance was 

and

 for FSIS On 06/24/2019

while observing live haul at 0505 hours, I found

many coop doors of the trailer open. Two turkeys

on the right side of the trailer and two turkeys on

the left side of the trailer were out of their

respective coops and sitting on the mezzanine.

Other coop doors were open, but no additional

turkeys had exited the trailer. The employees who

unload the trailers were on a 30-minute break at

the time of my inspection. I found the supervisor

of live haul and explained the

situation to him. He went to the truck and placed

all turkeys back in the coops and shut all the coop

doors which had been left open. The truck is on a

hoist system which raises it or lowers it to enable

unloading of the turkeys. The mezzanine is

approximately 12 inches from the side of the

trailer and is approximately 12 feet in height from

the ground. On 06/25/2019 while observing live

haul at 0515 hours, I again found many coop

doors open while the unload employees were on

break. There was a total of 2 turkeys out of cages

on the right side of the trailer, and sitting on the

mezzanine, close to the edge. One of the turkeys

was upside down laying on his back.  The turkey

was not breathing well. Respiration was shallow

and diminished, less than 28 breaths per minute. I

turned the turkey over, back on his feet, and he

began taking deeper breaths with an increase in (b) (6)

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

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 10

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Task

Code TaskName Status MOI Agenda

the respiration rate.  I could not find live haul

personnel, but did locate the 

, and advised

him of the conditions in live haul. He met me in

live haul where I showed him the open coops and

loose turkeys. He had an employee replace the

turkeys into coops and shut all open coop doors. 

On 06/26/2019 while observing live haul while

employees were on break, I found coop doors

open on both sides of the trailer.  On the right

side of the trailer, I found one loose turkey. It was

located at the rear of the trailer. The turkey was

suspended between the mezzanine and the trailer.

Its tail was on the edge of the mezzanine while his

legs were clutching a coop door and its head and

neck were extended upward toward the next

higher coop. I immediately left the area and found

a live haul employee, but also went to find 

 was with 

, and I asked both men to meet me in

live haul immediately to witness the condition of

the turkey.  When they arrived, the turkey was

still positioned as it had been. A live haul

employee ran to the turkey and replaced it in the

coop. He also shut all the coop doors. During the

week of 06/16 to 06/20 I found coop doors open

while employees were on break. I also found loose

turkeys beneath the truck while it was hoisted in

the air and being unloaded. There was a total of 3

loose turkeys that I observed during that week. I

was not present at the 06/21/19 weekly meeting,

but I spoke with about my concerns of

the coop doors and loose turkeys. He brought

these issues up at the weekly establishment

meeting, along with his own concerns about the

increase in loose turkeys in live hang that he had

witnessed. Observations of this were recorded

during the Des Moines 

 visit with on 05/01/19.

During her exit meeting she documented her

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

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 11

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Task

Code TaskName Status MOI Agenda

observation of “multiple open cage doors during

unloading and uneven distribution of birds in

some cages.” The above lists multiple

occurrences of establishment P551 live haul

failing to prevent and manage live birds in coops

on a hoist above ground from exiting coops while

unattended creating a significant risk of serious

injury if a fall from the mezzanine occurred. It is

the responsibility of the establishment to employ

methods of handling and slaughter consistent

with Good Commercial Practices in a way that

minimizes injury to poultry.
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 12

Dist

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Task

Code TaskName Status MOI Agenda

05 M18909 Foster Farms JDD282206

2012G

12JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized I met with 

 for an exit meeting after my daytime

GCP visit. The establishment was compliant to 9

CFR 381.65(b) during my observations. We

discussed my concern about the high

temperatures in the holding shed, where I

observed one trailer load of light hen turkeys held

prior to entering the shackle barn. Nearly all the

birds were breathing with beaks open and at an

increased respiratory rate, and a lot were standing

up instead of resting in the cages. I observed

approximately 4 hen turkeys that were resting on

their keel and not panting. The multiple

thermometers in the holding barn registered 95

degrees. The establishment has 4-5 fans per fan

bank that cover 2 trailer-width sections. Water

misters were on but there was minimal air and

water flow on sides of the modules that were

furthest away from the fans. Adequate measures

for heat management are a concern for good

commercial practices, and heat stress in turkeys

can diminish meat quality on harvest. I have

observed good climate management in other

facilities. I recommended that the establishment

veterinarian team evaluate the holding shed

during hot weather to assess weather

management. stated he would

investigate this and consult with the corporate

veterinarians.

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 13

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Task

Code TaskName Status MOI Agenda

50 M2130 Cooper Farms Processing HEF260304

3117G

17APR2019 04C05 Poultry Good

Commercial

Practices

Open On April 15th 2019 at approximately 0330 hours,

I, , while performing

antemortem inspection outside in the cooling

sheds, observed a trailer of live turkeys with a

column of cages that were not properly secured

by the metal bar that runs from top to bottom,

allowing the doors of these cages to swing freely

open. I observed one loose live turkey that was

sitting on the ground directly beneath the

unsecured cages. I informed a nearby live haul

employee, who returned the live turkey to the

cages before securing them properly. The topmost

trailer cages are not reachable without the aid of

steps or a ladder and present a significant

distance from these cages to the concrete floor of

the cooling sheds, and there is relatively heavy

vehicle traffic in and around the area.

(b) (6)
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25 M248B Butterfield Foods Company GXN39150

52031G

31MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P215, Butterfield Foods Co., May 31, 2019,

0805 hours. In attendance: 

. At approximately 0753 hours, while

performing a routine Poultry Good Commercial

Practices verification task in the picking room, just

after the feather picker machines, I observed a

bright red de-feathered bird carcass with a dark

purple head and lower neck on the line

immediately after exiting the picker. Upon further

examination of the carcass, I did not observe a

neck cut. I observed the line for approximately

five minutes and observed two additional

carcasses with no neck cuts and four carcasses

with shallow neck cuts that did not sever

the blood vessels in the neck. All of these

carcasses were bright red with dark purple heads.

These birds entered the scald tank alive and died

other than by slaughter. I observed an

establishment employee place all seven cadaver

birds in the red barrels in the pinning room. I

immediately spoke with 

, in the unloading

room, who called for 

. I spoke with at

approximately 0805 hours regarding the seven

cadaver birds. In response, informed

me that he slowed the kill line, increased the

amperage on the stunner, and notified the

back-up killers of the cadavers. stated

that he had started the kill line slower than the

normal speed at the start of the shift due to the

size of the birds in the lot. He said that he had

observed the kill line at the start of the shift and

had not observed any cadaver birds. In the kill

room following the stunner, I saw several birds

with legs not completely in the shackles due to

the size of the birds. This resulted in their heads

being higher than the kill blade. These birds had

to be cut by hand by the back-up cutters. (b) (6)

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

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 15

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Following corrective actions, I

observed the line after the picking machines for

an additional five minutes and did not observe

any cadaver birds. 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. Poultry must be slaughtered in a

manner that will result in thorough bleeding of

the carcasses and ensure that breathing has

stopped prior to scalding.

05 M27389 Pitman Farms NCO26090

45011G

11APR2019 04C05 Poultry Good

Commercial

Practices

Open

(b) (6)
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05 M27389 Pitman Farms NCO10120

50507G

07MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P27389, Pitman Family Farms, April 24 and

25, 2019. USDA & Est. personnel involved

 

The events in this GCP MOI span over two days

and relate to delayed delivery of the CO2 supply

for the Establishment.   Without CO2 for stunning,

the birds were stunned using the backup electric

stunner on Line #2. was in

communication frequently with various

Establishment personnel regarding these issues,

but most frequently with the individuals listed

above. On 4/24/19 at approximately 0919 hours

I observed one awake bird while standing at a

spot in the last 1/3 of the length of Line #2 that

runs on the blood pit platform.  This position was

before the head-puller and before the scalder, but

after the autokill blade and three establishment

employees used as back up stickers.  I noticed one

bird’s head moving as if it were looking around.  I

placed my hand lateral to the bird’s eye, without

touching the head, and the bird moved its head

away from my hand.  The bird passed through the

head puller and did not enter the scalder alive.  I

informed 

 of my findings and suggested

that if the CO2 gas levels were going to be altered

that the Establishment keep good records and be

certain to follow any procedures in place. I

observed multiple instances over the two days of

birds that were still awake after coming through

the electrical stunner on Line #2 in the live hang

room: On 4/24/19 at approximately 0930 hours

I counted 24/300 birds (8%) awake after leaving

the electrical stunner and then entering the

autokill blade.  The birds were lifting their heads

and rapidly flapping their wings compared to the

wing movements of the other birds.  I did not

count it at this time, but these birds often were

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 17

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the same birds that passed outside of the autokill

blade path, evading the cut at the blade.  These

birds going through the autokill received cuts to

the cervical and head region that were not

perpendicular to the major vessels of the neck,

but instead transverse cuts through the sagittal

plane of the head and neck.    I informed

of my findings.  The

Establishment moved the vertical level of the

electric stunner in response to my findings.    On

4/24/19 at approximately 1730 hours I counted

10/300 birds (3.3%) awake between leaving the

electrical stunner and entering the autokill blade. 

The birds were lifting their heads and rapidly

flapping their wings compared to the wing

movements of the other birds.  I counted 14/300

birds (4.7%) that passed through the autokill

outside of the path of the knife.    On 4/25/19 at

approximately 1000 hours I counted 25/300 birds

(8.3%) awake after leaving the electrical stunner

and then entering the autokill blade.  The birds

were lifting their heads and rapidly flapping their

wings compared to the wing movements of the

other birds.  I observed some of them vocalizing or

attempting to vocalize.  I observed one bird sitting

all the way up with its head touching the shackle

and its own hocks.  I informed 

, of my findings.  The

Establishment moved the positions of the backup

stickers and the extra monitor in response to the

findings.          On 4/25/19 at 1000 hours I

observed birds hanging from the shackle on just

one leg as they left the electrical stunner.  I

counted 4/300 birds (1.3%) hanging on one leg

and then 3/300 (1%) in a second count completed

a few minutes later.  I discussed my findings at the

electrical stunner with

 at 1330 on 4/25/19.  (b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 18

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 explained that those hanging from one

leg had a chance of not getting a full stun.  

 had evaluated the electrical stunners that

day and informed me that they were working. 

On both 4/24/19 and 4/25/19 the Establishment

responded to my findings by altering the

arrangement of the backup stickers after the

autokill and before the head puller and scalder. 

The Establishment also added an additional

person in the same area as a spotter to take birds

that appeared to still be awake after passing the

autokill and backup stickers off the line for a short

period until the spotter was certain the bird was

dead.  The bird would then be put back onto Line

#2 to go into the scalder.  The arrangement

changed a few times, but the one that I observed

that appeared to be most effective was to have

two back up stickers on the first 1/3 of the blood

pit portion of Line #2 and a spotter and another

back up sticker in the middle of the platform on

the last 1/3 of the blood pit portion of Line #2. 

This arrangement appeared to give the most

amount of time to find and remove live birds

before they passed through the head puller and

scalder.  The two-person teams also appeared to

offer the Establishment employees better support

to be effective in removing live birds.       There is

no FSIS regulatory requirement to stun birds

before slaughter and no live birds were observed

entering the scalder.  Est. P27389 is in regulatory

compliance in these matters according to USDA

FSIS.  The Establishment has a special label claim

for animal welfare on some of its products and

the observations listed in this MOI may show that

the Global Animal Partnership (GAP) claims for

these animals was not met for the slaughter

portion, specifically that birds were observed

hanging by one leg and that not all of their birds

were stunned and rendered insensible prior to

slaughter.  See page 37:

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 19

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https://globalanimalpartnership.org/wp-content/

uploads/2018/04/

GAP-Standard-for-Meat-Chickens-v3.1-20180403.

pdf.  USDA collected labels from product

produced from the birds slaughtered on 4/24/19

and 4/25/19 and some of these labels had GAP

“Step 3” printed on the label.  If the label claims

were not met, this could represent a potential

misbranding regulatory non-compliance.  The

Establishment has been informed of the USDA

concerns and both parties are investigating the

matter further at this time.

25 M32130 Dakota Provisions LLC JEB080804

5615G

15APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. 32130, Dakota Provisions, 4/15/19   0715

hours.  

.  At 0440 hours while performing

ante-mortem inspection, I observed 3 dead

turkeys immediately beside trailer #5.  There was

also one turkey lying on the concrete that was

alive.  Upon further observation, the top cage, 3rd

row back on the trailer (driver’s side), had an open

cage door.  I immediately notified 

 of the birds.  The live bird was

placed back into a lower cage on trailer #5.  I did

not see any obvious injuries.  then had the

top cage door shut.  The door was fully

functional.  These birds fell out of the cage to the

concrete below, which is a 12 foot drop.  

 was notified at 0500 hours of the open

cage door.  , was also

notified of the open cage door. I met with 

 at 0715 hours to discuss the open cage

door and the consequences of doors not being

shut when leaving the farms to the

establishment.  I then called 

, and notified him of the events. 

The establishment must employ humane methods

of handling and slaughtering consistent with Good

Commercial Practices in a way that minimizes

injury to poultry.

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

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

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 20

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25 M34145 Kadejan, Inc. JQU160806

2106G

06JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On Wednesday June 5th, 2019 at 0830 hours

while performing a Good Commercial Practices

Task, during slaughter I observed that there were

eight DOA’s that the Establishment had separated

from live birds at receiving. There were a total of

nine batters in the storage area each batter holds

fifteen drawers. Each cage is approximately three

feet long by two feet wide by about 18 inches

high. I observed a batter in the storage area with

birds that were breathing heavy with their mouths

open in the top row of cages and also in the next

row down. The batter was in the building where

the temperature seemed to be slightly higher than

the outside temperature. There were only two

fans, one of the fans was on the outside of the

batters facing in toward the batters and there was

also a fan in the center of the batters facing the

batters, there was very little air movement in the

storage area where the birds were. As I looked at

the other cages I observed that approximately

seventy percent of the birds were mouth

breathing. The outside air temperature at that

time was approximately 64° F. The temperature is

expected to get up to around 84° F today. I went

outside the building to observe the birds in the

batters on the outside. The batters had been

placed in a shaded area with a slight breeze. There

were four batters on the West side of the building

where they got the most shade. There were

eleven batters on the North end of the building

where there was still shade available. As it got

later in the day the shade would give way to the

sun and heat. In one batter I could see that there

were at least five DOAs in two of cages outside

located on the West side of the building. The birds

were loaded so that not all the birds could lay

down in the cage, some were forced to stand. This

was because there was no room in the cage since

the cage had no more room for the birds to lie

down. By 1000 hours there had been 20 DOA’s
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 21

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Code TaskName Status MOI Agenda

separated from the incoming live birds. At the end

of the day there were a total of 59 DOAs, 4262

trimmed birds and 16 condemned by USDA for a

Total of 4337 birds in all. Birds must be loaded

with room to lie down and not so tight that they

are forced to stand.  The birds must have room

from overcrowding (especially in temperate or hot

weather) to prevent diminished ventilation and

heat stress.  A lack of air low, ventilation, and

sufficient space within a cage can lead to heat

stress and the death of birds by means other than

slaughter. The Establishment must employ

humane methods of handling and slaughtering

consistent with Good Commercial Practices in a

way that minimizes injury to poultry. Poultry are

to be handled in a manner that prevents needless

injury and suffering. Employing humane methods

of handling and slaughtering that are consistent

with Good Commercial Practices increase the

likelihood of producing unadulterated Product. 

The Establishment Management has stated they

will send extra batters out on Thursday for

Friday's slaughter, to give extra room to the birds

and allow them better ventilation. Friday

the two extra batters were sent out to the farm,

allowing for more room for each bird. There were

only nine batters inside the building the batters

inside the building were staggered and spread

further apart allowing the two fan to move air

more affectively. There were four batters still

outside on the north side of the building. These

batters were also spread far enough apart to allow

the breeze to get into the birds. Today's slaughter

consisted of 1885  birds that were processed, 8

DOAs, and 19 birds condemned by the plant or

USDA inspection for a total of 1912 birds in all

today. The plant has ordered two more fans for

inside the building and expect them to arrive

some time next week.
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 22

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Code TaskName Status MOI Agenda

60 M45134 Birdsboro Kosher Farms Corp. FKJ541505

4428G

28MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At establishment #45134, Birdsboro Kosher

Poultry, on May 28th at approximately 2:45 pm I

 was called to the 

 stand on the turkey

evisceration line.  Upon examination of the turkey

carcass I saw that the skin incision was lengthwise

(parallel to the line of the neck, not straight across

under the chin) and asymmetrical (only on

the right side of the neck), the left carotid artery

had not been severed, and the other artery had

only been nicked.  The entire neck was heavily

hemorrhaged. There was a small amount of

carcass bruising. The Plant Manager, Carlos

Urieta, was notified and also examined the

carcass.  I explained how my observations led me

to believe the turkey was a cadaver and had not

been slaughtered properly.  This is not consistent

with good commercial practices which requires

that live poultry cannot die from causes other

than slaughter. He left to speak with the rabbi

who was slaughtering at that time (the

establishment slaughters one turkey at a time on

a single line). Before he left, I informed Mr. Urieta

that I would be issuing an MOI for the poultry

mistreatment.

(b) (6)(b) (6)
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35 M5842 Tyson Foods, Inc. NPF54160

42105G

05APR2019 04C05 Poultry Good

Commercial

Practices

Finalized GCP Poultry Mistreatment MOI Day, Date and

Time of Meeting: Friday April 5, 2019 from 1508

until 1530 Place Meeting Held: Est. M5842

SPHV's office Persons Attending: FSIS

Attendees - . Tyson

Foods Attendees –

 Author(s) of this

Meeting Report: Date this

Meeting Report was Written: Friday April 5, 2019 

Subject: GCP Poultry Mistreatment MOI. 

Background concerning this Poultry Good

Commercial Practice (GCP) Non-Regulatory Issue: 

On Friday April 5, 2019, from 1424 to 1433 CST, I

performed a station 1 Poultry Good Commercial

Practices (GCP) PHIS task by observing carcasses

entering the first scald tank on kill line 2 in the

picking room. At 1430 during the check, I

observed 1 live bird that had no cut on its neck,

was conscious, eyes open, neck curved upward,

looking around, panting and alert. This was a very

small for the lot, young chicken. I removed this

live bird from kill line 2 at 1430, immediately

before the bird would have entered the first scald

tank on kill line 2 and placed this young chicken

on the ground where it sat upright, eyes open,

and looking around. I then went into the live hang

room and requested live receiving supervisor Oree

Bradley be called to the picking room then

resumed the station 1 check.  This check was

completed at 1433 with no more live birds

observed.

 arrived on the scene at approximately

1432 and was shown this 1 live young chicken. He

and a team member then took this live young

chicken back to the live hang room.  At this time,

 informed me that both team

members that were usually assigned to be back

up killers had called in earlier and were not at

work today.  At the time the 1 live chicken was

seen, there was 1 backup killer covering both kill

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 24

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lines. I then performed a GCP Station 1 follow up

check #1 on kill line 1 from 1434 to 1443 with no

more live birds observed. I performed follow up

check #2 on kill line 2 from 1444 to 1454 and

observed no live birds. No GCP NCs or

non-regulatory concerns were observed during

these 2 follow up checks. Discussion notes for the

meeting with Plant management on Friday April

5, 2019 from 1508 to 1530 concerning this GCP

poultry mistreatment incident: I met with

establishment

 in the SPHV’s office

from 1508 to 1530 on Friday April 5, 2019. 

 informed me that most of plant

management were still in a meeting but had

already been informed of this incident. During this

meeting I described my observations concerning

this incident as outlined above. I then told 

 that due to the results of the 2 follow up

checks on 4/4/19 (see above) the 1 live bird I had

observed and removed from kill line 2 at 1430

before it entered the first scald tank during the

GCP check that day was deemed by IPP to be an

isolated incident and not a loss of plant killing

process control. Thus, IPP will issue a Poultry

Mistreatment MOI in lieu of a GCP NR concerning

this incident as per guidance in FSIS Directive

6110.1 dated 7/3/2018.

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 25

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35 M5842 Tyson Foods, Inc. NPF36210

54704G

04MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized GCP Poultry Mistreatment MOI Day, Date and

Time of Meeting: Saturday May 4, 2019 from

approximately 2025 until 2100 Place Meeting

Held: Est. M5842 Evisceration GPM office 

Persons Attending: FSIS Attendees - 

. Tyson Foods Attendees 

. 

Author(s) of this Meeting Report: Robert

Washington Date this Meeting Report was

Written: Saturday May 4, 2019  Subject: GCP

Poultry Mistreatment MOI. Background

concerning this Poultry Good Commercial Practice

(GCP) Non-Regulatory Issue: On Saturday May 4,

2019, from 1947 to 1958 CST, I performed a

station 1 Poultry Good Commercial Practices

(GCP) PHIS task by observing carcasses entering

the first scald tank on kill line 1 in the picking

room. At 1950 during the check, I observed 1 live

bird that had no cut on its neck, was conscious,

eyes open, neck curved upward, looking around,

and alert. This was a significantly smaller than

average for the lot, young chicken. I removed this

live bird from kill line 2 at 1950, immediately

before the bird would have entered the first scald

tank on kill line 1 and placed this young chicken

on the ground where it sat upright, eyes open,

and looking around. At this time, I noted that this

bird was dry and had not been stunned.  I got the

attention of the picking room attendant who

requested 

be called to the picking room then resumed the

station 1 check.  This check was completed at

1958 with no more live birds observed. 

 arrived on

the scene at approximately 1952 and was shown

this 1 live young chicken. He then took this live

young chicken back to the live hang room.  At

1959 CST, there was 2 backup harvesters, each

covering one kill line. then

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 26

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performed a GCP Station 1 follow up check #1 on

kill line 2 from 2001 to 2010 with no more live

birds observed. performed

follow up check #2 on kill line 1 from 2011 to

2021 and observed no live birds. No GCP NCs or

non-regulatory concerns were observed during

these 2 follow up checks. Discussion notes for

the meeting with Plant management on Friday

April 5, 2019 from 1508 to 1530 concerning this

GCP poultry mistreatment incident: I met with

establishment

 in the SPHV’s office

from 2025 to 2100 on Saturday May 4, 2019. We

were joined by 

 at approximately 2040.  

informed me that he and had

already been informed of this incident. During this

meeting I described my observations concerning

this incident as outlined above. I then told 

 that due to the results of the 2 follow up

checks on 5/4/19 (see above) the 1 live bird I had

observed and removed from kill line 2 at 0748

before it entered the first scald tank during the

GCP check that day was deemed by IPP to be an

isolated incident and not a loss of plant killing

process control. Thus, IPP will issue a Poultry

Mistreatment MOI in lieu of a GCP NR concerning

this incident as per guidance in FSIS Directive

6110.1 dated 7/3/2018. 

 both stated they are working on plans to

make identification of significantly undersized and

un-stunned birds easier.  They stated they would

keep IPP informed on the progress of these plans.

(b) (6)

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

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

(b) (6) (b) (6)
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80 M737 House of Raeford - Wallace Div DHA28110

40903G

03APR2019 04C05 Poultry Good

Commercial

Practices

Finalized 1140 - When going to complete my Good

Commercial Practice check with 

, we observed several

cadavers in the red barrels at the re-hangers on

line 2.   One of the cadavers had no cut on its

neck.  At 1142 while performing the Good

Commercial Practice task I observed on Line 2, a

live bird with no cut on its neck as evidenced by

their breathing, having eyes open, and showing

coordinated body movements was about to enter

the scalder.  

, who accompanied me when I did the

task was able to retrieve the bird from the line

before it could enter the scald tank. Within a  few

minutes 2 additional live birds as evidenced by

their breathing, having eyes open, and showing

coordinated body movements were observed by

us and removed by .  Both birds

were insufficiently cut enough to prevent them

from entering the scalder alive. 

also removed an additional bird during this time. 

There was no other intervention procedure in

place at the entrance to the scalder, so if the

establishment employee had not been present to

remove the birds from the line, the birds would

have entered the scalder and would have died by

means other than slaughter.  

, stated they had added additional

backup cutter to Line 2 due to the person there

had not been in the job long and would also be

adding a person at the entrance to the scalder.

, was notified of the

MOI. These issues were also discussed with

Cowan Johnson, Plant Manager, on 03/28/2019

in a meeting held in the USDA Office.  Also in this

meeting was discussed the GCP issues found that

morning and on the previous day.

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

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

(b) (6)

(b) (6)
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80 M737 House of Raeford - Wallace Div DHA51080

41703G

03APR2019 04C05 Poultry Good

Commercial

Practices

Finalized On Wednesday, 27 March 2019 at approximately

0530 while going to perform a NPIS Leukosis

check, I observed several cadavers in the red

barrels next to the re-hangers.  After completing

the NPIS Leukosis, I performed a Good

Commercial Practice task and observed 2 live

birds as evidenced by their breathing, having eyes

open, and showing coordinated body movements

was about to enter the scalder on Line 2.  The 2

birds were observed within a few minutes of each

other.  The line was stopped and both birds were

removed by plant employees before they entered

the scalder.  There was no plant employee at the

scalder when the first bird was observed, but

there was when the second bird was observed. 

There was no other intervention procedure in

place at the entrance to the scalder, so if the

establishment employee had not been

notified/present to remove the birds from the

line, the bird would have entered the scalder and

would have died by means other than slaughter. 

, was

notified that a MOI would be issued. These issues

were also discussed with Cowan Johnson, Plant

Manager, and 

, on 03/28/2019 in a meeting held in

the USDA Office.

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 29

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80 M7470 Mountaire Farms Inc. - NC Division YRA460604

5029G

29APR2019 04C05 Poultry Good

Commercial

Practices

Finalized April 26, 2019, at approximately 0715 hours, on

my way, while performing ante-mortem

inspection in the receiving area, I observed a live

bird in the dead-on-arrival (DOA) container. The

bird was underneath several other birds, but I

could see the breast area of the bird rising and

falling with each breath. I verbally notified the

plant’s 

 of my findings and she notified the

. The DOA

container was retained by . The

bird was removed from container by 

. As the bird was

being removed from the container, its wings

began to flap. At that time, the bird was positively

identified as a live bird. arrived in the

receiving area and took corrective action by

having the remaining birds in the DOA container

dumped out onto the pavement. I did not observe

any other living birds in the container. Had this

bird remained in the condition it was found; it

would have been smothered to death and

therefore died by means other than by slaughter. I

notified 

of the plants failure to comply with 9 CFR

381.65 (b) and I would be issuing a Memorandum

of Interview (MOI) for failure to follow good

commercial practices. The PPIA and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and live poultry should not die of causes

other than by slaughter. The Federal Register on

Treatment of Live Poultry before Slaughter gives

recommendations on how to prevent these

occurrences. 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

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

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 30

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pertinent matters discussed concerning this

incident and is true to the best of my knowledge.

60 M9977 Tyson Foods Inc. YBL470604

1003G

03APR2019 04C05 Poultry Good

Commercial

Practices

Finalized On 2 April 2019 at P1325, Tyson Foods Inc., at

approximately 1817 hrs while performing a

routine Poultry Good Commercial Practices (GCP)

verification task at the pre-scald area, I observed

the following event. As I was observing chickens in

the pre-scald area, I observed one chicken still

breathing as it entered the scalder. The chicken’s

head was still completely attached and the

chicken was alert with no bleeding cut present on

the neck. I immediately notified

 as we watched

for the chicken to exit the scalder. 

 removed the chicken carcass from the

line as it exited the last picker. The carcass was

deep red in color and the head and neck were

engorged with blood. He confirmed that there

was not a cut on the neck. The back-up kill person

failed to manually cut the neck to permit the

required bleed-out. The regulations (9 CFR

381.65(b)) require that poultry be slaughtered in

accordance with good commercial Practices.

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 a thorough bleeding of the

poultry carcass. Additional discussion of poultry

handling is in Federal Register: Docket No.

04-037N - Treatment of Live Poultry Before

Slaughter. Respectfully, 

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 31

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60 M9977 Tyson Foods Inc. YBL140504

1423G

23APR2019 04C05 Poultry Good

Commercial

Practices

Finalized On 23 April 2019 at P1325, Tyson Foods Inc., at

approximately 0445 hrs while performing a

routine Poultry Good Commercial Practices (GCP)

verification task at the dumper, I observed the

following event. A team member was operating

the dumper to dump cages of live chickens. He

was moving the cage back, then lifting the cage to

dump again. He did this repeatedly leaving a gap

between the cage and dumper each time before

dumping again. I observed a chicken that was still

twitching fall onto the belt. I observed the chicken

as it stopped moving and died. It had blood

dripping from an area on the neck onto the belt.

 came

into the dumping area and I immediately pointed

the chicken out to him and explained that the

team member dumping the cage had moved the

cage back away and then dump again, repeatedly.

He spoke with the team member and I said that I

wanted to get the carcass when it went into the

live hang area. We observed the carcass and it had

a bleeding cut on the neck and also cervical

dislocation in the neck. I immediately found

 and notified him of the event at

approximately 0451 hrs. The establishment said

they would have a meeting with all of the team

members in the live-hang area at the end of lunch.

I reminded 

 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

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 the

establishment that this MOI will be forwarded to

the District Office and the District Veterinary

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 32

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Code TaskName Status MOI Agenda

Medical Specialist (DVMS) in case additional

follow-up is recommended. Respectfully,

50 P1209 Whitewater Processing Co. FFG090804

4704G

04APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P-1209 Whitewater Processing Co. At 0855

hours while observing birds entering the scald

tank as part of a routine GCP task, 

observed the following. One old Breeder turkey

(Hen) was observed to be breathing and

raising it's head on the production line just before

the scald tank. stopped the line and

alerted Plant personnel of the finding, was

removed from the line by plant personnel and

rehung prior to the stunner The line was then

restarted. went immediately to the

office and discussed the finding with  .. I

explained that this issue continues to occur. The

last one occurred four weeks ago (03/07/2019). I

again explained that public perception of this

could lead to problems for the plant and further

corrective actions need to be implemented. She

stated she would discuss this with management

and they would take immediate corrective

measures which included reviewing findings with

plant personnel. I again stressed that it is not a

condition that the birds are not cut but that only

one carotid is cut and the birds are regaining

consciousness prior to bleeding out.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 33

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Code TaskName Status MOI Agenda

50 P1209 Whitewater Processing Co. FFG050805

3901G

01MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At 0855 hours while observing birds entering the

scald tank as part of a routine GCP task

 observed the following. One old Breeder

turkey (Hen) was observed to be breathing and

raising it's head on the production line just before

the scald tank. stopped the line no

plant personnel responded when the bird had

expired restarted the line. 

went immediately to the office and discussed the

finding with  .. I explained that this issue

continues to occur. The last one occurred four

weeks ago (04/04/2019). I again explained that

public perception of this could lead to problems

for the plant and further corrective actions need

to be implemented. He stated he would discuss

this with management and they would take

immediate corrective measures which included

reviewing findings with plant personnel. I again

stressed that it is not a condition that the birds

are not cut but that only one carotid is cut and

the birds are regaining consciousness prior to

bleeding out.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 34

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90 P1235 Wayne Farms LLC GKN51120

54828G

28MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized On May 28, 2019, at 1020, while performing a

routine good commercial practice verification, I

observed one live bird enter the scald vat.   I was

standing in the picking room at the west entrance

of scald vat number one.  Just as a bird was

entering the scald vat, I observed that a second

smaller bird was hung behind it on the same

shackle.  The bird that was hung behind had open,

blinking eyes and was lifting its head.  I notified

 who was in

the immediate area.  The line was stopped and an

attempt at retrieval was made.   When the bird

exited the scald vats, I confirmed that the throat

had not been cut and therefore this bird had died

otherwise than by slaughter.  removed

the bird from the line and condemned it.  I

immediately performed an additional one

thousand bird check and did not observe any

improperly slaughtered carcasses.  I then

proceeded to the kill room and verified that the

stunner and kill machine were functioning as

expected.  stated that he had multiple

new, inexperienced live hangers in the area and

for immediate corrective actions, he instructed an

experienced live hanger to work with each person.

At approximately 1100, I notified 

 of this incident and

forthcoming MOI documentation.  Plant

Operations Manager Brad Trapp was also notified

by phone while I was in office. 

Respectfully, 

      

        

–FLS       Gregory Brookhouser, DVM-DDM

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

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 35

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90 P1235 Wayne Farms LLC GKN54080

64827G

27JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On June 26, 2019, at 1108, I, 

, observed less than good

commercial practices in the picking room.  During

the performance of a routine Good Commercial

Practice check (GCP), I observed one live bird

whose throat had not been cut about to enter

scalder number one.  Additionally, the bird

exhibited labored respiration and open eyes.   I

was standing at the west (entrance) end of scalder

number one where the establishment has

installed a stop button for occurrences such as

this.  Per establishment’s written permission, I

immediately stopped the picking line to prevent

the bird from entering the scald vat and

drowning.  

 arrived quickly and removed the

bird from the line prior to restarting the picking

line. This bird had passed all the establishment’s

intervention steps and the entrance into

the scalder was imminent when the line stopped. 

 Hence, it is reasonable to conclude that without

intervention and the utilization of the emergency

stop button, the bird would have entered the

scalder alive.  I immediately performed an

additional 1,000 bird check and did not observe

any improperly slaughtered carcasses.  I then

proceeded to the kill room to verify the function

of the stunner and kill machine.  During my

observation period I noted that the backup killer

had to slit the neck on more than 20 birds in less

than 3 minutes and approximately 50 percent of

these birds were not properly stunned.  I

instructed the backup killer to blow his horn for

maintenance assistance. After removal of the live

bird and examination of the kill process, the

establishment determined that due to bird size

variations the stunner and the kill blade needed to

be raised.  After adjusting the equipment,

verification checks performed by the QA humane

handling technician were found to be acceptable

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 36

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and within the parameters of their poultry welfare

and handling program. 

 was notified that GCP MOI

documentation would be forthcoming.    A copy

of this Memorandum of Interview will be

forwarded to appropriate personnel in the

Jackson District Office. Respectfully,   

 Cc: Dr. Gregory

Brookhouser, DDM, Jackson DO                              

                                                                                

                                                

                                                                                     

                                                   

                                                                                     

                  

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

(b) (6)(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 37

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Code TaskName Status MOI Agenda

50 P1241 Tyson Foods, Inc. MGJ44160

42719G

19APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Establishment 1241-P, Tyson Foods, Inc. April 19,

2019, 9:00 pm.  In attendance: 

Nathan Henry, Plant Manager; 

 At approximately 3:25 pm while

performing a Poultry Good Commercial Practices

task at a point just before where the chickens

enter the scalding tank, I observed a live chicken

enter the scalding tank while still breathing.  The

chicken had no visible knife cut on its neck and

was exhibiting voluntary movement of the head

and neck as it entered the scalding tank.  I

immediately proceeded to the point on the kill

line directly after the last picking machine and

waited for the chicken carcass in question to pass

by me.  When the carcass appeared, I removed it

from the kill line and examined it.  The carcass

was small, red in color, and had no knife cut on

the neck.  I immediately showed the chicken

carcass to 

, and informed him of the impending

MOI.  At approximately 3:45 pm, I resumed the

performance of my Poultry Good Commercial

Practices task at the same point of the process as

described above.  After observing the process for

approximately 2 minutes, I again observed a live

chicken enter the scalding tank while still

breathing.  This chicken also had no visible knife

cut on its neck and was exhibiting voluntary

movement of the head and neck as it entered the

scalding tank.  I immediately proceeded to the

point on the kill line directly after the last picking

machine and waited for the chicken carcass in

question to pass by me.  When the carcass

appeared, I removed it from the kill line and

examined it.  The carcass was small, red in color,

and had no knife cut on the neck.  I immediately

showed the chicken carcass to and

informed him that this incident would also be

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 38

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added to the MOI.  After finding this 2nd incident

of a live chicken entering the scalding tank, I then

observed the process at a point near the

employee who was working as the back up killer. 

I noted that several of the chickens coming down

the line were very small, were missing the water

bath in the stunner, were not being properly

stunned, and were therefore not being cut by the

kill machine.  As a result, the employee working

as the back up killer was having trouble keeping

up with the process. At approximately 9:00 pm, I

met with Nathan Henry and the other members of

establishment management listed above to

discuss my findings and the corrective actions that

were taken by establishment management. 

Nathan Henry stated that the Live Hang

supervisor immediately assumed the role of back

up killer for the remainder of the shift, members

of the maintenance team looked at the stunner

and made some adjustments to it, all

establishment employees who work in the back

up killer position were reminded to stop the kill

line whenever they are unable to keep up with the

process, and the grow out team members were

informed to work with the growers to ensure a

more uniform bird size for incoming flocks.   

, Est.

1241-P Corydon, IN

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 39

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Code TaskName Status MOI Agenda

85 P1284 Pilgrim's GDA38010

52115G

15MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. 01284-P, Pilgrim’s, May 14, 2019, 2120

hours. In attendance: 

. 

On May 14, 2019, approximately 2115 hours,

while inspecting the MSC/DOA offal trailer, I

observed a live chicken. The chicken was on the

floor of the trailer resting on its breast and

covered in red dye denaturant. I estimated around

150 dead chickens were in the trailer, and all

chickens I could easily observe still had their

heads attached. I immediately notified 

. He and 

inspected the offal trailer with me. 

stated he had not dumped any DOA’s into the

trailer since live hanging had started for the shift. I

observed the denaturant on the carcasses and live

chicken had stained the chickens but was dry

 retrieved the live chicken which was alert

and active when picked up. He humanely

euthanized the animal by rapid decapitation. A

Poultry Good Commercial Practices MOI was

documented on 11/19/2015 for finding a live

chicken in the offal trailer. The preventative

measure documented by plant management to

prevent recurrence, was “a documented check

will be performed at the beginning and end of

each shift. The check will be to inspect the

MSC/DOA offal trailer for any live chickens.

Documentation of this check can be found on the

Daily Animal Welfare Audit.” I reviewed the Daily

Animal Welfare Audit form from day shift

operations on 5/14/19, and an inspection of the

MCC/DOA offal trailer for live chickens was

completed at 1520 hours and found to be

acceptable, no live chickens in the MSC/DOA offal

trailer at the end of the shift. I reminded 

 that the regulations require that poultry

be slaughtered according to Good Commercial

Practices. This includes employing humane (b) (6)

(b) (6)

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

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 40

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methods of handling that prevents needless injury

and suffering. No immediate planned actions

were provided by the establishment at this time,

however, an investigation would be conducted,

and a response would be provided by plant

management. was informed that

this mistreatment MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in the event additional

follow-up is recommended. Respectfully

 01284-P Pilgrim’s

90 P1307 Mar-Jac Poultry-AL KIL030205

2108G

08MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0125 while performing

Ante-Mortem and an Animal Welfare check at line

1 live bird cage dump, I observed an

Establishment employee throw a live chicken

approximately 3 feet diagonally across from a

lower set of cages to the top of another set of

cages.  As the chicken skidded across the top of

the cage approximately 2 feet, it vocalized and

flayed its wings.  The employee's actions caused

the bird undue distress and excitement.  I notified

 of my observations. A copy of this

Memorandum of Interview (MOI) will be

forwarded to the appropriate District Office

personnel. Respectfully submitted on May 8,

2019, Cc: Dr. Gregory

Brookhouser, DDM 

(b) (6)

(b) (6)

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 41

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Code TaskName Status MOI Agenda

35 P13369 George's Processing, Inc. ZUD41100

60426G

26JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized FSIS Personnel: Plant

Personnel: 

Location: FSIS Supervisor’s Office Meeting

conducted by: On 6/25/2019 at 1435

hours, met with 

 to discuss the humane handling

issue observed by as described below. 

On 6/21/19 at approximately 1715 hours while

performing a Good Commercial Practice

Verification Task in the dumper area of Live

Receiving, I observed the feet of what appeared to

be 2 birds visible behind the gear/sprocket cover

on the south end of the upper line 3 dumper belt

of the line. The lower 2 1⁄2 to 3 inches of 3 paws

were visible in a standing configuration. I was

unable to determine if the birds were alive at this

time. I immediately informed Receiving and

, who stopped the

dumping process and removed 3 uninjured live

birds and 1 macerated dead bird from this area.

All birds were significantly undersized. The cover

was in place to prevent live birds from being

injured or killed in the gears/sprocket of the upper

belt. called maintenance to evaluate the

situation.  It was determined that, under certain

conditions, the lower portion left space for the

very small birds to get trapped inside and possibly

contact the gears. The cover was removed, the

area was monitored with the intention of

redesigning the cover. 

 and I discussed the observation and he

confirmed the corrective measures that were to

be taken. Monday at approximately 0830 hours I

was told by 

 that the redesign had taken place and I

verified the cover was in place and functioning as

intended.   It is your responsibility to design and

monitor the live bird handling equipment and

practices in a manner which prevents birds from

being mishandled or dying by means other than

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

(b) (6)

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

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 42

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Code TaskName Status MOI Agenda

slaughter. Your ongoing monitoring of areas

where issues have historically occurred or are at

increased risk for such problems is critical in

properly implementing good commercial

practices. This MOI includes all information

discussed during the meeting 

 6/25/2019

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 43

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Task

Code TaskName Status MOI Agenda

90 P164 Tyson Foods Inc IJM212306

2410G

10JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized To: Mr. Steve Langford, Plant Manager Tyson

Foods, P-164 Forest, MS At approximately 0404

hours, while performing a portion of the Good

Commercial Practice task as I was observing the

conditions in the Picking room area in the

Establishment’s Evisceration department. 

 observed a deep red live bird

entering the scalding tank for Picking Line #1, the

live bird was small and no cut was evident on the

bird’s neck area. The bird was alert at this time. I

proceeded to watch the bird until it could be

safely removed from the picking line. Upon closer

examination, the bird in question was still intact

with no cut to the neck area or anywhere else on

the bird. I informed  of this

finding.  immediately notified GPM

Prentiss Bruce as well as  

 Mr. Bruce and 

 observed the bird. A second small red

bird was observed with a bad cut along the neck

area for Picking Line #3. However, I did not

observe the second bird going into the scalding

tank. I reminded 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 recommend that

Mr. Bruce 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.  I notified

 that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.  ____________________                

                  _____________________ 

                                        

(b) (6)

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

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

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 44

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40 P165H OK Foods, Inc. DAF52010

42201G

01APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2035 hours, while performing

part of the Good Commercial Practice task in the

picking room, I observed a sensible bird (eyes

open, head tucked) come by me with its throat

not cut and still breathing on Kill Line 2. I then

observed the bird enter the scald tank. I did not

see the Supervisor in the area, so I proceeded to

the end of the picking line to wait for the bird to

emerge from the pickers. When I got to the end of

the picking line, I located 

just moments before the bird emerged from the

pickers. I showed the bird and he

removed it from the line. and I

observed that there was no cut on the throat but

there was a small superficial cut on the back of

the head. This bird was average size for the birds

within the flock. I performed a recheck shortly

after and observed zero sensible birds prior to the

scald tanks. and

 met with me in the

Evisceration office to discuss the issue. 

 informed me that the backup killer

would be disciplined according to company

policy. He also stated that the employees that

backup the backup killer are contract employees.

He informed me that he had notified their

employer of the incident. Similar findings of a

sensible bird observed prior to the scald tanks

were observed on 11-29-18, 10-30-18, 9-6-18,

8-6-18, and 6-29-18. Previous measures to

prevent this from reoccurring have either been

ineffective or were not implemented.

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 45

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40 P165H OK Foods, Inc. DAF49120

44116G

16APR2019 04C05 Poultry Good

Commercial

Practices

Finalized On 4-15-19 the plant ended slaughter operations

early at approximately 1235 in the live hang area. 

Birds from Evergreen Farm and Vira Farm had

already been caught and brought to the plant or

were in route before the plant ceased slaughter

operations.  The earliest birds from Evergreen

Farm arrived at 0834 on 4-15-19 and the last

trailer from Vira Farm arrived at 1248 on 4-15-19. 

Slaughter operations did not resume until

approximately 0930 on 4-16-19 leaving these

birds without food or water for an extended

period of time (up to 25 hours).  The

establishment’s Animal Welfare Plan contains the

National Chicken Council Animal Welfare

Guidelines and Audit Checklist for Broilers.  Page

11 of the plan states 

  Page 14 of

the plan states

.  Both of

these timeframes were exceeded.  On the

afternoon of 4-16-19, I met with Mr. J.P. Koch,

Plant Manager and 

 and discussed my concerns over the

length of time these birds were kept on-site

without food or water.  Both men appeared to

understand my concerns.  They expressed that

they were forced into holding these birds while

they waited on decisions concerning a large

quantity of product that was on hold at the

establishment.  The establishment delayed

running the birds from Evergreen and Vira Farms

to prevent any potential mixing of product from

those farms with the product that was on hold.

(b) (4)

(b) (4)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 46

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Task

Code TaskName Status MOI Agenda

40 P165H OK Foods, Inc. DAF53040

55821G

21MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0109, I went to live hang to

perform part of the GCP task and immediately

observed 3 live birds caught in the transfer belt

gears. The belt was no longer covering the gears,

which allowed live birds to get caught in them.

The gears were ripping into their abdomens and

crushing their rib cages. The live birds were unable

to escape from the moving gears. One employee

was trying to pull a live bird out from the gears

while the gears were still moving. As I entered the

live hang room, a maintenance employee exited

the room through the back-dock door. There were

2 employees with white shovels pushing the live

birds that were on the dumping belt over to the

opposite side to avoid the moving gears. The live

hangers were sorting through the injured birds on

their belt and hanging the uninjured birds. At no

time did any employee stop the line to prevent

any further birds from being injured. I

immediately took regulatory control and had the

belts stopped. I placed US Reject Tag No.

B-45141447 to the emergency stop lines. I asked

a maintenance employee that had just walked out

the back door to radio 

 I showed the birds

that were caught in the gears. Two of these birds

were still alive and one had just succumbed to his

injuries. There were approximately 3-4 dead birds

mangled within the  gears also. Upon further

inspection of the birds that were on the hanging

belt, approximately 15 birds were found dead.

Some of these had been eviscerated while they

were alive. There were another 4-5 live birds with

severe injuries such as partially amputated legs

and crushed rib cages with deep lacerations to the

abdomens. These birds had shallow breathing, not

moving and their eyes were closed, which

indicates they were in a state of moribund. The

birds were removed and immediately euthanized (b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 47

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via decapitation. During the time that I was in

live hang, I discovered that the live hang transfer

belt that covers the gears had come off its track

earlier in the evening. At that time, Maintenance

repaired the belt and had to remove a link in the

belt during the repair. 

informed me that this had occurred and that they

thought the problem had been fixed. I asked 

 if anyone monitored this belt to ensure that

it stayed on track. He told me that he did not

believe anyone stayed to monitor the belt during

operation. At approximately 0200 hours, 

 informed me that he had held a training

session with all the live hang employees and

leads. The training covered the topic of

immediately stopping the line when a piece of

equipment malfunctioned and notifying the lead

or supervisor. informed me that 

 was going to hold the same training

for the maintenance employees as well. 

 also stated that a maintenance employee

would be placed in live hang for the rest of this

shift to ensure that the belt stayed on its’ tracks.

Regulatory control was relinquished at

approximately 0236 hours after I monitored the

equipment to ensure that it was functioning

appropriately. I reviewed the establishment’s

Animal Welfare Program, last updated 2-17-19.

There are no written procedures that describe

what an employee should do when a piece of

equipment breaks and begins injuring the birds.

The establishment’s program has procedures for

instructing employees how to hang birds, carry

birds, stun birds, and euthanize birds but it does

not instruct them on how to stop a line to prevent

birds from becoming injured. USDAs concerns are

that there were approximately 15 employees in

the live hang room, and no one was willing to

stop the line to prevent the birds from enduring

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

(b) (6)

(b) (6) (b) (6)
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the injuries or agonizing death that they had to

endure. USDA encourages the establishment  to

respond to this MOI.

40 P165H OK Foods, Inc. DAF31090

65910G

10JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On 06-09-19 at approximately 2126 while

performing a good commercial practices check, I

 observed two live birds in the DOA

dumpster outside the live hanging room.  It was

early in the shift, so the birds were towards the

bottom of the dumpster.  I observed a rhythmic in

and out of the bird’s abdomen as it breathed.  I

immediately notified

 who happened to be

in the area at the time of my observation.  A plant

employee removed the live bird from the

dumpster at which time I observed a second live

bird that had been underneath it.  During the

removal process both birds had their eyes open

and began moving around.  Past practice at this

facility is for all birds to receive cervical

disarticulation prior to being placed in the DOA

dumpster.  The establishment’s Animal Welfare

Program states 

 explained that the

employee responsible would receive additional

animal welfare training.

(b) (6)

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

(b) (6)
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35 P165S OK Foods, Inc. LWA30200

45109G

09APR2019 04C05 Poultry Good

Commercial

Practices

Open At 1735 on 4/9/19 shortly after the 1700 break, I

was informed that the plant was having a large

DOA issue at Live-hang. At 1739 I arrived at

Live-hang and observed a pile of deceased birds

approximately 3’ in diameter and 2’ tall at the end

of the Live-hang belt. Plant workers were taking

DOAs off the pile, decapitating them, and placing

them into condemn containers. I observed that

the Live-hang belt, which was currently running,

was mostly full of more deceased birds and few

live ones. I asked 

, about the situation. He stated they

had already quit loading cages and were clearing

out the pile of deceased birds. I walked through

the yard and observed that there were several

cages up on the rollers, including at least two still

in the LAPS tunnel. The LAPS tunnel is enclosed on

two sides, has the afternoon sun shining on one

entrance, and does not have fans inside it. I

informed that they should move

those cages out of the tunnel if they are going to

be down for any length of time so as to not cause

further DOA birds, which he did. The remaining

cages further down the rollers were left on the

rollers under fans, though the misters were not

on. A sign on the Live-hang supervisor’s office

door stated that 

 The

temperature reached 85 degrees today.  I

observed significant amounts DOAs (>5 per row

per cage) within the cages on the rollers. I

observed 7 trailers of birds out in the open on the

yard. There was a misting fan trailer near the

middle of the column, but it did not appear to be

on. A forklift was carrying a single diesel-powered

fan around two of the trailers, but the other five

were not getting any air. All the observed birds

were panting heavily, though I did not see very

many DOA birds in those cages. The Live-haul

shed was completely full of trailers with the fans

(b) (6)

(b) (6)

(b) (4)
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on but not the misters. The birds there appeared

calm and not in distress. I asked 

where the cages with all the DOA birds came

from, the yard or from the shed. He stated they

had come from the yard. I informed him that the

misters on the rollers, on the yard, and in the shed

did not appear to be on or functioning. He stated

he would call the Live-haul crew about it.

Maintenance at Live-haul stated the misters were

not working due to the hoses being broken. At

1815 I returned to Live-hang and observed

another, though smaller, pile of DOA birds at the

end of the conveyor. I informed that they

were still going too fast and were causing pile ups

on the floor and at the end of the belt, and that

they need to slow their cage dumping so as not to

cause pile ups. The plant brought out a pressure

washer and was using it to spray down cages that

were on trailers on the yard. The fan in the

dumper was plugged in and turned on at this time

also. By around 1840 the DOA numbers had

drastically declined and appeared to be at normal

amounts. I talked to Ross Greenwood, Plant

manager, about the issues and informed him that

a MOI would be documented. The plant had

brought more trailers of birds than their Live-Haul

shed could contain and so put several trailers

outside in the direct sunlight. They did not have

adequate fans or working misters to care for all

the birds on the company grounds. The

establishment was running cages faster than their

employees could process the DOA which caused

pile ups of dead birds on the Live-hang belt and

floor.   During the weekly establishment meeting

on 3/28/19 I had discussed the increasing

weather temperatures and how the establishment

would need to handle their birds with respect to

the increased temperatures. See MOI #:

LWA4913031528G for further information.

(b) (6) (b) (6)
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35 P165S OK Foods, Inc. LWA41120

65714G

14JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized This MOI is to document my conversation with

. While performing a GCP task in the

Live Hang area, I heard loud offensive music being

played on a speaker device and being sang loudly

by the employees. The lyrics contained vulgar

content and foul language. stated that

he did not take the issue lightly and would

directly take care of it. Also, while performing a

GCP task, I observed a live bird on the line #1 Kill

line enter the scalders. The neck of the bird had

not been cut. The eyes of the bird were opened

and moving. While and I were present,

the cadaver carcass was sorted properly at the

line #1 rehang table by being removed and placed

into the marked “Condemned” barrel.

(b) (6)

(b) (6) (b) (6)
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90 P17766 Southern Hens, Inc SSN091604

0105G

05APR2019 04C05 Poultry Good

Commercial

Practices

Open Ms. Tia Horton Plant Manager Southern Hens,

Inc 329 Moselle-Seminary Rd Moselle, Ms 39459

Ms. Horton, On April 5, 2019 at approximately

0915 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. In the

hallway, concerning one of the drains, there were

3(three) birds located in that common drainage

exit leading to the offal drainage system. The birds

were soaked from the incoming water, 1(one) of

birds was struggling to stay afloat with failed

attempts as it tried to prevent its self from going

further into the offal drainage system. Had I not

been there to inform plant employees of the

situation, more than likely those birds would have

eventually been swept into the offal drainage

system, as this area is not normally monitored

throughout the day. 

 was

informed of the incidents and the GCPIP MOI to

follow. I explained to that

allowing live bird(s) to enter the drains alive

would lead to entrapment, drowning 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. 

 discussed briefly the less than GCPIP

incident at back dock area at approximately

0918 hours. No response to the less than GCPIP

incident was given at this time and a investigation

was pending.  was advised a GCPIP

(b) (6)

(b) (6)

(b) (6)

(b) (6)
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Memorandum of Interview would be issued to

management pending review by 

. Respectfully,  

 cc. Dr Larry Davis, DM Dr. David

Thompson, DDM Dr. Gregory Brookhouser, DDM 

(b) (6) (b) (6) (b) (6)
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90 P18557 Sanderson Farms, Inc. QNA14080

55806G

06MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized On May 6, 2019 at approximately 05:40 

, observed less than Good

Commercial Practices while performing an

Ante-Mortem Inspection and Good Commercial

Practices check at 18557 P in Summit, MS. While

observing the kill machine of each picking line for

proper function, I did not observe any

abnormality in the equipment's operation. I did

observe that a new employee was backing the kill

machine on line #2. I walked to the end of the

blood trough to observe for any live birds entering

the scalder. I observed a single, live bird at 05:40

CDT enter the scalder on picking line #2. The bird

was hanging on the shackle with its eyes open,

blinking, head retracted and showing voluntary

head movement.  I did not observe a cut on its

neck. This bird entered the scalder alive and still

breathing. I observed the head grossly swollen

and hemorrhagic after the bird exited the scalder

and before it went through the deheader.  I did

not take any regulatory action with this

single-bird incident, since no evidence of a system

failure existed. I notified 

, of the observed

nonconformance, during a brief meeting held in

rehang at approximately 05:47 CDT.  I presented

the cadaver to him, explained my observation,

informed him that a Memorandum of Information

(MOI) was going to be documented, and

relinquished the carcass into his control. A copy

of this Memorandum of Information will be

forwarded to the appropriate personnel in the

Jackson District Office. Respectfully, 

and Mr. 

Gregory Brookhouser, Jackson DDM.

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

(b) (6)
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90 P19112 Perdue Foods LLC OXA44220

41803G

03APR2019 04C05 Poultry Good

Commercial

Practices

Finalized On April 1, 2019 I, observed

less than Good Commercial Practices (GCP) while

performing a Poultry Good Commercial Practices

verification task at Perdue Foods, LLC #19112-P. 

The following contains my findings and the

content of an interview conducted at 03:45 by me

with . 

Upon entering the DOA area at 23:55, I noted that

the DOA dumpster was approximately two thirds

full and a chicken was on its back in the dumpster

vigorously paddling.  No plant personnel were

present in the room.  I immediately summoned

 and we identified and removed

five live birds from the top layer of birds in the

dumpster.  I instructed to remove all the

birds from the dumpster checking for more live

birds.  Two additional live birds were found buried

under several layers of dead birds. is

aware that a copy of this MOI will be forwarded

to appropriate personnel in the Jackson District

Office.  The interview concluded. CC: 

        

        

            

        File

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

(b) (6)
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90 P192 Pilgrims Pride Corporation OOB30090

44923G

23APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At 0452 while was performing

Antemortem inspection the following failure to

observe Good Commercial Practices was

observed. A trailer with live birds from Lot 2

Harriad Farm contained a cage in which the floor

bottom divider had fallen down on top of several

birds, which had to bear the weight of the divider

and layer of birds atop it, and forcibly pinning one

bird against the cage bars. The bird was alive, but

its breathing appeared stressed. The inspector

immediately notified 

 to address the animal welfare

concern. Cage conditions were recently

discussed in weekly meeting with management

held on 4/18/19, to confirm cages in poor

condition were culled during slaughter renovation

downtime 3/25- 3/29/19.  Previous issued MOI

OOB171212931I on 12/31/18 was for cage

conditions affecting live birds.

(b) (6)

(b) (6)
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15 P20251 Tecumseh Poultry, LLC PBM00090

62110G

10JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On 06/10/19, at approximately 0809 hours, while

performing a routine Poultry Good Commercial

Practice Verification task, I, 

, observed one instance of bird

mistreatment on an NAE (No Antibiotic Ever)

trailer, numbered T323, in the loafing shed. The

bottom module had a compartment with a stuck

bird. The bird’s two middle toes (second and third

digits) of the left paw were trapped between the

spring wire and the door. The toes were squeezed

flat by the spring door contraption causing the

toe’s segment at the distal phalange to turn

slightly blue/purple, which may have indicated

ischemia. The bird at this time was not moving or

attempting to move. The bird had its eyes closed

and was not fully alert/responsive to

manipulation. The left leg of this bird was laid out,

if not stretched out, horizontally behind it. I met

with to show him

the situation. He slowly opened the door and

released the toes. The bird remained recumbent

with the leg staying in the same position.  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)

(b) (6) (b) (6)
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15 P20251 Tecumseh Poultry, LLC PBM57120

61413G

13JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On 06/13/2019, at approximately 1150 hours,

while performing a routine Poultry Good

Commercial Practice Verification task, I, 

, observed three instances of bird

mistreatment on two NAE (No Antibiotic Ever)

trailers in the loafing shed. On trailer number 32,

one bird had its wing tip squeezed between a

metal board and the floor board of the

compartment above. The bird had enough wing

length to still be able to lay down. However, its

wing was raised above its back. At this time, I

released its wing by propping the top floor board

from the metal bar. Due to the feathers, I was not

able to see if there was damage to the wing tip.

Then, on trailer number T786, on the very top tier

of the stacked modules, one bird had its “shank”

stuck between the floor board and the metal bar.

This bird made multiple attempts of withdrawing

this foot and as it did, blood was actively dripping

from the area that was being scraped by the floor

board. There was evidence of bleeding before I

arrived to see this mistreatment. Small amount of

blood could be seen on some of the metal bars of

the lower part of the module and on the ground

below the injured shank. On the same trailer, the

module below the module with the bleeding bird

had another bird with its left hock stuck between

the floor board and the metal bar. The bird was

not able to retract this leg against the floor board.

The result was heavy bruising and scrapes on the

medial aspect of the hock and distal thigh. This

bird was not dripping with blood, but the floor

board edge had a bloody color that was 4-5

inches in length. At approximately 1200 hours, I

met with

 to show and explain to them what I

saw. A scale house personnel was assisting the

bleeding bird to retract its leg and was successful

so that it was no longer stuck. The bird did not

flex its hock back to a normal position after its

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 59

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shank was released. The establishment was not

able to release the bird with the stuck hock due to

the location of the bird in the module, so the QA

Supervisor had this trailer pulled up to be

slaughtered next.  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). The establishment is

encouraged to maintain the standards of GCP

through a systematic approach that focuses on

treating poultry in such a manner as to minimize

excitement, discomfort, and accidental injury the

entire time that live poultry is held in connection

with slaughter. Establishment management may

review Federal Register notice “Treatment of Live

Poultry before Slaughter”, 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)
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40 P206 Pilgrim's Pride Corporation KCC482006

4618G

18JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On June 17, 2019 at approximately 1955 hours

while performing a routine PHIS Poultry Good

Commercial Practices task 

observed the following noncompliance. At the

entrance of the stunning equipment there was a

dead bird lying on the ground just below the east

picking line with both of its legs ripped off. I

immediately informed 

, to stop hanging birds so as to prevent

anymore birds from dying before slaughter and

call management to the area. 

 was notified and

observed the mutilated bird along with the

remnants from where the bird was ripped apart.

As I was examining the birds entering the

stunners, one bird came down the west picking

line hung by only one leg and the birds were

being smushed up against one another

inappropriately as the equipment was elevated

too high. instructed maintenance to

adjust the stunning equipment and new shielding

was installed to the east line to protect the birds

from being pulled apart.   A similar occurrence

took place on March 15, 2019 for birds dying in

this same way, with their legs ripped off by

equipment. Failure to implement procedures for

preventing accidental injury and/or death

inconsistent with 9CFR 381.65(b) in regard to

birds presented for slaughter, resulted in a GCP

failure, and a bird died by means other than

slaughter. FSIS encourages establishments to

develop and implement a systematic approach to

ensure poultry presented for slaughter are treated

in a manner that minimizes excitement,

discomfort, and accidental injury.  The initial

component of the approach is to assess the areas

where problems may occur.  The second

component asks that establishments determine if

their facilities are designed and maintained to

prevent excitement, discomfort, and accidental

(b) (6)

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

(b) (6)
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injury to poultry the entire time that live poultry

are held in connection with slaughter.  Finally,

establishments should periodically evaluate their

handling methods to ensure that their employees

are treating animals in a manner that minimizes

injury, excitement and discomfort prior to

slaughter and that their methods ensure all

poultry are slaughtered in accordance with 9 CFR

381.65 (b). The establishment was notified that

the 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

noncompliance will be distributed to the

establishment, inspection file and District

Veterinary Medical Specialist per FSIS Directive

6100.3. The establishment is also reminded that

NRs and MOIs documented for GCP issues can be

FOIA requested and made available for viewing by

FSIS. Documented by 

(b) (6)
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35 P208 George's Processing, Inc. XIC111306

2604G

04JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On Tuesday, June 04, 2019, at approximately

11:45 hours, 

, met with 

.  The following is a synopsis of the events

and discussion regarding possibly suffocated birds

due to belt malfunction. At approximately 10:45

hours while performing Good Commercial

practice verification, I observed that the Line 1

back-up killer was performing an abnormally high

number of kill cuts (approximately 18 over one

minute with the normal observations being six per

minute), I immediately informed 

. While discussing with

him, the belt for the Line 1 live hang conveyor

system malfunctioned. Since this area was next on

my area to evaluate and due to previous history, I

elected to observe the establishment

implementing their procedures. As I observed the

belt, I observed that birds were 3-4 layers deep

with birds on top of each other on the conveyor

from the wall until first live hang personnel

position. As I continued watching, there was one

(and at times a second person) that was pushing

or lightly tossing birds further down the belt to

allow the personnel to hang the birds on the line.

One of the people that was pushing the birds

further down the belt would stop every few

minutes to retrieve birds that were no longer

breathing. Another person positioned on the

opposite was sporadically relocating birds further

on down the belt.  As I continued watching, I

observed that numerous birds of the top layer

were lifting their wings, beaks open, and their

respiratory rate appeared faster than normal. It is

important to note that while observing the

condition of the birds in the trailers as well as the

modules (outside), I only observed one or two

birds with their beaks open and what appeared to

be an increased respiratory rate. I also observed (b) (6)

(b) (6) (b) (6)
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that birds on the lower layers appeared to be

repositioning to get out from other birds. In

addition, I observed one bird that was sitting on

top of two birds that was trapped on its back by

two other birds. It was flapping its wings,

attempting to roll, open beak, respiratory rate

was fast, and the bird appeared to have increased

respiratory effort. Before the establishment could

remove the birds sitting on it, the bird stopped

breathing. After about 20 minutes, the

establishment was able to get the belt clear. As I

watched the live hangers, I observed two birds

that were not moving, no obvious breathing, and

that were not responsive to stimuli that were

hung on the line.  During the 20-minute period of

the belt being malfunctioning, I observed

approximately 30-40 dead birds that had been

removed from the belt by employees or fallen on

to the floor at the end of the belt. Now that the

belt was clear, I immediately informed 

of my observations and that the malfunction of a

belt resulting in the suffocation of at least one

bird (and possibly as many as 40) was not

consistent with good commercial practices. I also

informed him that at least two dead birds had

been hung on the lines. I informed that

this was not consistent with the establishment’s

sorting procedures which indicates that the live

hang will not hang dead birds on the line. Then,

we proceeded to the kill line between the end of

the pickers and the post pick dip to retrieve any

carcasses that died by methods other than

slaughter. As we watched the line looking for

cadavers, 

, approached and I informed him of my

observations, concerns, and that the malfunction

of the belt resulting in at least one bird

suffocating was not consistent with good

commercial practices. After the conversation

ended, removed a single carcass that

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

(b) (6)

(b) (6)
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appeared to be a cadaver with red to purple

discoloration of the neck and body. The meeting

was adjourned at approximately 11:50 hours. On

June 5, 2019, at approximately 10:30 hours,

met with in the

USDA office. explained his observations

and concerns from the belt malfunction from

yesterday. explained that these birds

were not slaughtered in accordance with Good

Commercial Practices. informed

establishment management that he wanted to

provide the establishment with an opportunity to

respond with a plan in action to prevent future

occurrence. continued that memoranda

of interviews (as well as noncompliance records)

are not punishments and are an opportunity for

FSIS to present concerns in writing to the

establishment to provide them with due process.

 further summarized 9 CFR 381.65 and

explained that this is the regulatory requirement

for Good Commercial Practices. informed

establishment management that based on

conversations yesterday that the establishment

was going to modify their preventative

maintenance schedule for the live hang belt

replacement. inquired if there were any

additional steps that production could take to

help alleviate the possibility of birds dying by

methods other slaughter. informed 

 that the establishment’s goal (when the belt

malfunctions) is to attempt to get the birds off the

belt as soon as possible (to prevent any dying by

methods other than slaughter). 

informed that the belt malfunction or

the steps to correct was not intended to harm any

chickens. Discussion involved potential steps to

(b) (6)

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

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 65

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rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

improve efficiency of transporting the chickens

from the dumper to the live hang personnel when

the belt malfunctions. Establishment

management also informed that the

establishment will evaluate whether improving

ventilation from the dumper to the live hang

personnel would help minimize the number of

birds in respiratory distress. The meeting was

adjourned at approximately 10:40 hours.

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 66

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Task

Code TaskName Status MOI Agenda

40 P325 Tyson Foods, Inc. YDM07230

60705G

05JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On June 5, 2019 at approximately 1650 while

conducting a GCP task 

observed the following conditions in the Live Hang

department.  There were two condemn barrels at

the end of the DOA bin.  noticed the

birds in one barrel were moving up and down

signifying the possibility of a live bird underneath. 

Upon further investigation, she removed

approximately 3 layers of birds and found a live

bird breathing.  took regulatory control

action and stopped live hang from hanging any

birds until the barrel was cleared of any further

live birds mixed with the DOA birds.  I notified

 of the concern with live bird

humane handling.    

stated that the team member had just been up to

HR due to some concern over pay that was owed

to him. The concern was when 

 arrived, there was no one attending to the

carcasses in the condemn barrels. The mixing of

live birds with dead birds in the condemn barrels

can suffocate the live, weak birds and is not

consistent with the Agency expectations for

handling of live poultry. The establishment is

asked to ensure establishment employees

handling live animals are aware of company

policies regarding live bird handling. 

Employing humane methods of handling

consistent with Good Commercial Practices can

help produce an unadulterated product.  Copies

of this Memorandum of interview will be

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.

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

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 67

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Task

Code TaskName Status MOI Agenda

40 P325 Tyson Foods, Inc. YDM23230

63306G

06JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On June 6, 2019 at approximately 1545 while

conducting a GCP task 

observed the following conditions in the Live

Receiving Area.  She was performing ante-mortem

examination on the trailer that had just been

placed in live receiving.  There was one cage

approximately midway on the trailer that had

three doors open.  noticed the birds

sitting on the doors and not in cages.  Upon

further investigation, she noticed a total of 5-6

birds outside of a bottom cage on three different

levels (or sections).  They were sitting on the cage

doors and trailer bed.  One bird had one of its legs

stuck between the door and an adjacent cage. 

 immediately notified 

 of the concern with live

bird humane handling and transport.  

 came out to

the trailer and began removing the birds that

were sitting on the cage doors they could reach. 

They instructed the fork lift driver to remove the

cage on top of the one with the open doors to get

to the birds and close the cage doors.  While

removing the top cage adjacent damaged cage,

the fork lift driver manipulated both the top and

bottom cage onto the bird’s leg that had been

pinned.  immediately instructed them

to stop.  A team member came over to release the

bird’s leg and remove it from the cage door.  The

establishment  removed the adjacent cage and

the remaining birds before closing the cage doors.

At the time of the observation described above,

there were no establishment employees attending

to the open cage or attempting to remove the

birds who had come out of the cage onto the

doors. Allowing birds to be outside cages and be

pinned between cages is inconsistent with the

Agency’s expectations of Good Commercial

Practices. The establishment is asked to ensure

establishment employees moving live animals are

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

(b) (6)(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 68

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Task

Code TaskName Status MOI Agenda

aware of company policies regarding live bird

handling.  Employing humane methods of

handling consistent with Good Commercial

Practices can help produce an unadulterated

product.  Copies of this Memorandum of

interview will be 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.
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 69

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Task

Code TaskName Status MOI Agenda

40 P325 Tyson Foods, Inc. YDM28210

60713G

13JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On June 13, 2019 at approximately 1530 while

conducting a GCP task observed

the following conditions in the Live Hang

department.  Approximately five DOA birds were

on the floor to the side of the metal DOA bin and

approximately 10 live birds on the floor in the

hanging pen throughout the floor.  The metal DOA

bin at the end of the live hang belt was three birds

deep and no one was removing the birds from the

bin.  asked the live hang supervisor to

remove the birds from the bin.  Upon closer

inspection there were a total of two live birds

mixed in with the DOAs in the bin.  Those birds

were underneath the layer of dead birds. I notified

 of the concern with live

bird humane handling.  

informed that the normal team

member that picks up live birds and removes

DOAs from the bin was not present this evening

and the establishment was using someone new in

that position.     While continued her

GCP task at 1545, a live bird was found under the

stunner that was soaked and huddled up.  No one

was attending to or removing the bird.  

took regulatory control action and stopped the

live hang lines.  was notified of

the bird under the stunner.  He removed the bird

from under the stunner and released

regulatory control back to the plant. The mixing

of live birds with dead birds in the DOA bin can

suffocate the live, weak birds and is not consistent

with the Agency expectations for handling of live

poultry. Allowing the DOA bin to fill two three

layers of birds deep with overflow onto the floor is

indicative of a loss of process control and is not

acceptable.  The establishment is asked to ensure

establishment employees handling live animals

are aware of company policies regarding live bird

handling.  Employing humane methods of

handling consistent with Good Commercial

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 70

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Code TaskName Status MOI Agenda

Practices can help produce an unadulterated

product.  Copies of this Memorandum of

interview will be 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.

40 P325 Tyson Foods, Inc. YDM29230

64921G

21JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized While performing presentation checks at about

1640 there were 2 cadavers hung back for

veterinary disposition. Upon further investigation,

there were no cuts on the necks of either bird. 

Exiting the picking room an additional cadaver

was observed without a neck cut. 

 was notified of the

cadavers. The presence of birds that are not

thoroughly bled out and cadavers that would have

entered the scald tank while still breathing

constitute a concern with 381.65(b) and good

commercial practices. (

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 71

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Task

Code TaskName Status MOI Agenda

80 P445 Wayne Farms, LLC FKA501405

1328G

28MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1600, as I went to the live

receiving department to perform my good

commercial practices task, I observed an

unusually large number of Dead on Arrival birds

(DOA's).   The DOA vat was full to overflowing, if

you tried to place another bird to the vat, that

bird would fall to the floor.  Additionally, there

was a pile of DOA's next to the DOA vat that was

approximately 8 feet long, 3 feet wide and 2 feet

deep.  Also, there was a plant employee

continuously throwing DOA's from the hanging

area through the plastic strips onto the pile.  I

found , in the

evisceration department, and notified her of my

findings.  She went out to live receiving to gain

control of the operation.  had a plant

employee empty the DOA vat and dispose of the

rest of the DOA's.  She was also monitoring the

belts bringing the live birds to the people hanging

the birds on the shackles, since this is where she

found the cause of the increased DOA's to be

coming from.  This seemed reasonable because

the cages of live birds did not have many visible

DOA's in them, maybe one DOA per 10 cages. 

, was present and he

started dousing the birds in cages on the trucks

with water (in addition to the fans and water

mist) in an effort to keep them cool.

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 72

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Task

Code TaskName Status MOI Agenda

50 P45819 King & Sons Poultry Services, Inc. IUY121104

1102G

02APR2019 04C05 Poultry Good

Commercial

Practices

Open At approximately 0725 hours while evaluating

birds on the production line heading to the scald

tank as part of a GCP audit, 

, observed a conscious, alert bird that had

not been cut.  immediately notified the

stunning operator, who then promptly removed

the bird from the shackle and rehung it in the

shacking area upstream from where it had been. 

The bird was then stunned and cut.  No other

issues with mis-cuts or birds breathing as they

entered the scald tank were noted during the

observation period.  discussed the

incident with .

35 P45912 Midwest Poultry Processing LLC GLL080904

1409G

09APR2019 04C05 Poultry Good

Commercial

Practices

Finalized April 8, 2019, approximately 1030 hours; outside

temperature approximately 70 degrees F.  While

performing ante-mortem inspection on the

loading dock, I observed approximately 200 DOA

carcasses in the top layer of crates that had been

covered with a black tarp during transport on a

flatbed trailer.  The tarp was removed just prior to

antemortem; it appeared the birds died from heat

exhaustion during their extended time under the

tarp.  I addressed live bird handling and good

commercial practice procedures, particularly

regarding the increasing outside temperatures

with Irvin Martin, owner of Midwest Poultry, and

provided Mr. Martin with a copy of Good

Commercial Practices (GCP) Humane Handling

Poultry for additional guidance.  Mr. Martin had

employees remove all condemned DOA carcasses

before the start of slaughter. Mr. Martin said he is

aware of the expectations discussed.

(b) (6)

(b) (6)(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 73

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Task

Code TaskName Status MOI Agenda

50 P45939 Petersburg Poultry Processing CZJ320905

4623G

23MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized Upon arrival at Petersburg Poultry Processing for

slaughter processing on May 22, 2019 while

performing the antemortem check on the

chickens to be slaughtered the 

observed multiple deceased chickens in the crates

which, after confirming with establishment

employees, were left uncovered in the rain

overnight from the previous day , they were the

remaining chickens that were not slaughtered

from the day before. After the slaughter was

finished the establishment counted 83 DOA

chickens that had passed as a result of being left

unprotected from the inclement weather.

80 P4602A NEW MARKET POULTRY, LLC YCG191406

0121G

21JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On 6/21/2019 at approximately 1005 hours,

 while performing the Good Commercial

Practices verification task noticed a live hung hen

pass the area on the kill line where the backup

killer was stationed lift its head, look left and

right, and blink.  I took regulatory control action

by stopping the hanging area line.  I informed the

lead supervisor of the issue and we both observed

the backup kill find and slaughter the chicken

with a knife cut across the throat area.  The lead

continued to monitor the backup killer until he

was satisfied that no more birds were passing the

final checkpoint uncut.  I then informed 

 of my

observations.  Later, during the weekly meeting,

establishment management mentioned adding an

emergency stop button to the backup killer's side

of the line so that he could more quickly stop the

line if signaled. Had I not stopped the line, it is

likely the live chicken would have entered the

scalder water while alive and breathing producing

a true cadaver [381.65(b)].  Such a cadaver was

previously on May 6, 2019.  Evidence of a

developing trend of loss of process control such

that true cadavers are produced may result in a

NR for 381.65(b).

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 74

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Task

Code TaskName Status MOI Agenda

40 P46374 Sanderson Farms, Inc. Tyler Processing

Division

AQI361204

3509G

09APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Poultry Mistreatment Meeting at Est. P-46374,

Sanderson Farms - Tyler in April 9, 2019 at

approximately 1100 hours. In attendance

 At approximately

1046 hours, on 9th of April 2019, while

performing Poultry Good Commercial Practices

task, observed the live chicken

dumper free one young chicken stuck on the cage

and threw it 7 feet across towards the unloading

belt, hitting the bar with its flapping wings. I

notified the accordingly. Ten

minutes later, observed the same

chicken dumper dumped a new batch of young

chickens on top of the remaining 6 young

chickens on the unloading belt.  I notified

 accordingly. I recommended to

 to review the Federal Register Notice

Vol. 70, No. 187, published September 2005

(Docket No. 04-037N) and sent him a copy. I also

notified that this

Memorandum of Interview (MOI) will be written

which will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow up is recommended. 

Respectfully, of Est.

P46374 - Sanderson Farms at Tyler

(b) (6)

(b) (6)(b) (6) (b) (6) (b) (6) (b) (6)(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 75

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Task

Code TaskName Status MOI Agenda

40 P46374 Sanderson Farms, Inc. Tyler Processing

Division

AQI400804

5124G

24APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P46374, Sanderson Farms Tyler Processing,

April 23, 2019, 1337 hours. In attendance

is also present. At approximately 0545

hours, 23rd of April 2019, while performing

Poultry Good Commercial Practices verification

task, I observed at pre-scald two young chickens

still breathing. who is right

behind me immediately stopped the line when I

said “still breathing”. instructed

the plant neck cutter to make a cut on the neck of

the two young chickens still breathing which

apparently have cut on their necks already. Then,

 adjusted the blades of the kill

machine accordingly. told the

plant neck cutter to be more alert to ensure that

all the necks of the young chickens are properly

cut. The plant neck cutter is a back up to the kill

machine. asked if what I saw is

not a reflex reaction of the bird who may already

be dead.  said the two

aforementioned birds open their beaks gasping

for breath with eyes wide open and the other one

flapping its wings. requested if

MOI may not be issued as due process with the

consideration that the plant has not found

cadaver on the line except for 3 birds on the 3rd

week of operation. replied that IPP

would give the opportunity for the

establishment's system to work before making a

compliance determination however, the

establishment does not have GCP monitoring or

procedures at pre-scalder which consequently

cannot prevent these birds from entering the

scalder while still breathing.  also said

that under NPIS, FSIS is not monitoring the cause

of condemnations. added that based

on FSIS Directive 6110.1, the aforementioned

(b) (6)

(b) (6)(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 76

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Task

Code TaskName Status MOI Agenda

incident has to be documented in an MOI.  I

reminded 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 

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. I also recommended that

 review FSIS Directive 6110.1 which is

Verification of Poultry Good Commercial

Practices.  I notified that this MOI will

be forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

 Respectfully, 

P46374 Sanderson Farms Tyler Processing.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 77

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Task

Code TaskName Status MOI Agenda

40 P46374 Sanderson Farms, Inc. Tyler Processing

Division

AQI330604

0426G

26APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Poultry Mistreatment Meeting at Est. P-46374,

Sanderson Farms - Tyler in April 16, 2019 at

approximately 1000 hours. In attendanc

 At approximately

0900 hours, on 15th of April 2019, while

performing Poultry Good Commercial Practices

task on Lot 2, I, sensed the live

chicken dumper dump a new batch of young

chickens sooner than usual.  I was beside the wall

looking through the opening and observing few

young chickens left behind in the cage.  So, I did

not have a visual on what actually happened. 

Then, I positioned myself strategically and

watched carefully the next dump and I confirmed

that the dumper is dumping young chickens over

other young chickens on the first belt. I notified

 accordingly. When I went

outside to check on few young chickens left over

in the cage, the dumper motioned on me to climb

up the control stand and he showed me that the

first belt is a lot slower than the second belt.  He

explained that it is the reason why approximately

25% of the dumped young chickens are able to

walk back to the first belt.  I said, it is not a reason

to dump new batch of young chickens on other

young chickens.  later told me

that the maintenance crew is adjusting the speed

of the belt. I recommended to to

review the Federal Register Notice Vol. 70, No.

187, published September 2005 (Docket No.

04-037N). I also notified 

 that this Memorandum of Interview (MOI)

will be written which will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow up is

recommended. Respectfully, of

Est. P46374 ????Sanderson Farms at Tyler

(b) (6)

(b) (6)

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

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 78

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Task

Code TaskName Status MOI Agenda

40 P46374 Sanderson Farms, Inc. Tyler Processing

Division

AQI041305

0931G

31MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1325 hours on 30th of May

2019, while performing Poultry Good Commercial

Practices task, I, observed the

following:  One young chicken still breathing at

pre-scalder for Lines 1 and 2 which I pointed to

. He had the line  stopped and

pulled out the breathing young chicken off the

shackle.  Closer examination revealed uncut

trachea, esophagus and right jugular vein and

right carotid artery. The vent and thoracic cage is

rhythmically moving.  After few minutes, one

young chicken still breathing is also observed at

pre-scalder for Lines 3 & 4.  had

the line stopped but the breathing young chicken

is unreachable on the second shackle next to the

scalder.  It went to the scalder flailing. One day

before, 29th of May 2019, at approximately 0900

hours, while performing Poultry Good Commercial

Practices task, I, observed the

following:  One young chicken still breathing at

pre-scalder.  This time, there is no supervisor that

magically appears behind to pull out the

breathing young chicken before it goes to the

scalder.  The back up neck cutter stopped the line

and promptly cut the head off of the breathing

young chicken. Few days before, 25th of May

2019, at approximately 0840 hours, while

performing Poultry Good Commercial Practices

task, I, observed the

following:  One young chicken still breathing at

pre-scalder.  appeared from

behind and pulled out a different bird  from the

shackle.  Turned out, the one he pulled out is also

breathing –  flailing, vent and rib cage moving

rhythmically for at about 2 minutes and

eventually stopped moving. The breathing young

chicken I saw entered the scalder flailing. The

aforementioned incidents are evidences of

isolated instances in which a bird was still

breathing when it entered the scalder or about to

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 79

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Task

Code TaskName Status MOI Agenda

enter the scalder,  but the system is otherwise in

control.  At approximately 1245 hours, 31st of

May 2019, I summoned 

 to notify him of these findings. I

reminded 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 to die from causes

other than slaughter. I recommended that 

 review Federal Register Notice Vol. 70, No.

187, published September 2005 [Docket No.

04–037N] for FSIS recommendations concerning

treatment of live poultry before slaughter and

provided him a copy of this document. I notified

 that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. Respectfully, 

 P46374 Sanderson Farms Tyler

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 80

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Task

Code TaskName Status MOI Agenda

35 P468 Peco Foods, Inc. JVD420606

1804G

04JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On June 3, 2019 at approximately 0950 hours, I

 observed a trailer containing

live chickens underneath one of the

establishment’s live haul sheds that had ten open

cage doors. The opening of each of these cages

was located between each stack of cages.

Numerous birds were sitting on the open cage

doors, outside of the cages. Additionally, three

live birds had their heads caught in the cage

doors, presumably after the cage door opened

and then closed back. I notified 

 of the situation. 

immediately attended to the hung birds by

placing them back in the cages. He then had the

trailer moved to where the birds are unloaded via

forklift and transported to the dumping area. The

damaged cages were then carefully lowered by

forklift from the trailer and the birds were placed

back in the cages and the cage doors closed. Upon

lowering one cage that had three separate open

doors, one chicken did fall to the ground upon the

cage being lowered by the forklift. The bird did

not appear harmed and was placed back in the

cage by an establishment employee. All cages on

this trailer were transported to the cage dump

area. informed me that

this was likely caused by the driver of the trailer

slamming on the brakes en route to the

establishment. then ensured that the

driver retraced his route to make sure there were

no live chickens left along the driving path. He

also discussed the situation with the live haul

crew. I informed that I would discuss

this situation with my supervisor and that this

does not follow Good Commercial Practices for

poultry and may result in a memorandum of

interview. 

(b) (6)

(b) (6)

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 81

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Task

Code TaskName Status MOI Agenda

85 P476 Pilgrim's Pride ODA27230

52022G

22MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized Daniel Shaw, Plant Manager Pilgrim's Pride

Corporation P-0476 616 Kingsbridge Rd.

Carrollton, GA 30117 On Wednesday, May 22,

2019 at approximately 1850 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 department. I

observed approximately thirty-five cadaver birds

both on evisceration line number one and

removed from the line inside a condemn barrel

within the evisceration department. I immediately

notified 

 of

this issue. I notified 

 shortly thereafter by phone.

 Both and observed the

cadavers on the line in my presence. I was notified

by that there

was no water in the stunner and the backup killer

was trying to kill each bird by hand, which lead to

the large number of cadavers seen on the

evisceration line. stated water was

replaced in the stunner on picking line number

one and the problem was corrected. Once all

cadavers were removed by UDSA inspection and

notated on the lot tally sheets, no other cadaver

birds were observed. The topic will also be

discussed again at the next UDSA weekly meeting

on May 27, 2019 at 2330 hours and the minutes

will be documented in the corresponding MOI. 

Respectfully, 

(b) (6)

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 82

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Task

Code TaskName Status MOI Agenda

35 P481 Tyson Foods, Inc. VHF49040

55308G

08MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized On May 6, 2019 at approximately 2200 hours the

, observed the

following good commercial practice failure. While

conducting a routine antemortem 

 was walking on the pathway parallel to

the loading dock when she noted the seventh

cage from the rear of trailer 228 had been pushed

off the truck, lodging it between the vehicle and a

metal wall. The cage was positioned such that it

was partially rotated with the bottom corner

positioned on the ground and the top corner still

supported by the truck. Due to this all the birds

were condensed into the lowest point of the cage,

causing them to pile on top of each other. Wings

and feet of multiple chickens could be seen

pushed out of the bars of the cage, and loud

vocalization could be discerned from the affected

birds. It was noted that none of the cage doors

opened during the fall so all the birds were

contained. notified 

, and Andrew Adams, Plant

Superintendent, of the situation. In response

maintenance was called to the loading dock to

assist in the retrieval of the cage.  Once the

situation was properly assessed chains were

connected from the fallen cage to the forklift. The

cage was then lifted via said chains and slid back

into position on the trailer with minimal

disturbance to the chickens contained within.

After the chains were detached the cage was

removed from the trailer and presented to the

SPHV for further inspection at 2216. The birds in

the affected cage were found to be restless, but

vocalizations had subsided, and they had spread

out across the module’s floor. The majority of

visualized chickens appeared unharmed by the

drop and pressure of the animals on top of them,

likely due to their small size. One bird appeared

reluctant to stand, but it was unclear if it had

been injured during or prior to the drop. Visual

(b) (6)

(b) (6)

(b) (6)(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 83

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inspection revealed no frank blood, nor any

obviously broken limbs. The plant was given

permission to run the birds once the cage was

sound enough to be put through the dumper. A

broken and bent support bar of the cage was then

affixed back into place, with care taken to prevent

any sparks from hitting the birds. The chickens

proceeded through the slaughter system as

normal with no increase in broken limbs or

bruises noted by inspection personnel. When

the forklift driver was interviewed about the

incident by plant supervision it was determined

that the issue occurred secondary to live haul

cage mishandling. When the prongs of the forklift

entered the bottom track of the cage the driver

found that he could not progress further. When

he tried to remove the prongs, they were found to

be stuck on detritus lodged inside the tracks

during the catching process. The driver attempted

to push forward to free his forklift, but

unintentionally pushed the cage off the trailer in

the process. Upon inspection of the cage it was

found that the track along the bottom of the cage

used for unloading birds were bent. It was also

noted that multiple cages on the same truck had

litter and debris filling the entirety of the forklift

tracks due to the catch crews pushing cages

through the litter in the houses. Plant

management observed the issue and stated they

would be discussing proper cage handling with

the live haul supervision. Please note it is not

within the standards of good commercial practice

to cause birds undue stress or injury during the

slaughter process. Repeated incidences, such as

this, can result in further action being taken by

FSIS personnel.
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 84

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Task

Code TaskName Status MOI Agenda

90 P509 Koch Foods LLC IPG540304

2512G

12APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P-509, Koch Foods, April 11, 2019, 2330

hours. In attendance: 

 At approximately 11:00 pm on April 10,

2019, was observing conditions

on the slaughter-picking line when he noticed five

live chickens with uncut necks moving toward the

scalder and one of the five live chickens entering

the scalder. stopped the line to prevent

the remaining four live chickens from entering the

scalder. One of the remaining four live chickens

had its neck cut by the plant employee assigned

as the back-up cutter and the other  three

live chickens were returned to live hang.

 was summoned and he

assumed the duties of the backup cutter. At the

weekly meeting with the plant establishment on

April 11, 2019, said that a trained and

qualified person would be assigned to provide

breaks for the regular backup cutter instead of the

person providing the break during the incident of

April 10th.  I notified that this MOI

would be forwarded to the District Office and the

District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended. 

Respectfully, P-509,

Koch Foods.

(b) (6)

(b) (6)(b) (6) (b) (6) (b) (6)(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 85

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Code TaskName Status MOI Agenda

80 P510 House Of Raeford Farms RHB12010

43802G

02APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Ms. Nicole Reynolds, Plant Manager 

Establishment P510 House of Raeford Farm, Inc. 

Rose Hill, NC 28458 Ms. Reynolds, On

4/1/2019, at approximately 2219 hours, while

performing a Good Commercial Practices task in

the Live Hang Room, I noted a live bird about to

enter the scalder.  At the time of my observations,

the bird had normal rhythmic breathing, eyes

open and blinking with the head elevated.  No

team member was in the area, so I stopped the

line and called a team member to remove the bird

from the line.     On further observation, the bird

had an incomplete cut on the neck which did not

allow it to bleed out completely before entering

the scalder.  The bird was placed back on the line

to go through the proper slaughter process

 was

shown my findings and informed that there was

an increase in incompletely stunned birds

, to the area

 increased the voltage on the stunner

and verified that the stunner was working

appropriately.  Following this conversation, I

repeated my Good Commercial Practices task and

verified that the number of stunned birds was

appropriate. These findings were also reported to

.  He was notified that a GCP MOI would

be written as a result.  Previous memoranda

have been written on 3/4/19 and 3/28/19 for

similar findings.  In the memorandum dated on

3/4/19 (MOI# RHB1412035404I), a live bird was

found at the scalder entrance without a cut on the

neck.  The incident was attributed to variation in

bird size and the preventive measure cited was to

have the back-up cutter pay more attention to the

smaller birds as they pass the kill blade.  In the

memorandum dated on 3/28/19 (MOI#

RHB1605034728I), 3 live birds were noted at the

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 86

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Code TaskName Status MOI Agenda

scalder entrance without a cut on the neck and 2

live birds had incomplete cuts.  This incident was

attributed to the trainer of a new back up killer

stepping away from the platform.     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,   

-Tyson Foods, Inc., Monroe

(b) (6) (b) (6)
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Code TaskName Status MOI Agenda

90 P517 Mar-Jac Poultry-MS QOO23010

40302G

02APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Joe Colee Complex Manager Mar-Jac Poultry,

MS 1301 James Street Hattiesburg, MS 39401 

Mr. Colee, At approximately 2050 hours on April

1, 2019, the following less than Good Commercial

Practices (GCP) incident was observed at Mar-Jac

Poultry in Hattiesburg, MS. One (1) live young

chicken with 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 corresponding

cadaver was observed in the condemned barrel at

the rehang table for evisceration line #1

approximately 5 minutes later. 

were verbally notified of the incident at

approximately 2110 and 2100 hours respectively. 

A second verification check of an approximate

500 bird random subgroup sample on the north

picking line at approximately 2200 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 GCP and causes

needless suffering and death and results 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. 

 were advised a GCP

Memorandum of Interview would be issued to

management pending review by 

. Respectfully, . 

_______________________________________ Dr.

, Hattiesburg, MS

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 88

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39401 cc: 

90 P517 Mar-Jac Poultry-MS QOO46230

40016G

16APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Joe Colee Complex Manager Mar-Jac

Poultry, MS 1301 James Street Hattiesburg, MS

39401 Mr. Colee, At approximately 0500 hours

on April 16, 2019, the following less than Good

Commercial Practices (GCP) incident was observed

at Mar-Jac Poultry in Hattiesburg, MS. One (1)

alert live young chicken with no cut to its neck

and it's head raised from an approximate 500 bird

random subgroup sample entered the scald tank

on the north picking line which feeds evisceration

line #1.

 were verbally notified of the incident at

approximately 0500 and 0515 hours respectively. 

A second verification check of an approximate

500 bird random subgroup sample on the north

picking line at approximately 0530 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 GCP and causes

needless suffering and death and results 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. 

 was advised a GCP Memorandum of

Interview would be issued to management

pending review by . 

Respectfully, . 

_______________________________________ 

, Hattiesburg,

MS 39401 cc: 

(b) (6)

(b) (6)

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

(b) (6)
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90 P517 Mar-Jac Poultry-MS QOO39020

45526G

26APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Mr. Joe Colee Complex Manager Mar-Jac

Poultry, MS 1301 James Street Hattiesburg, MS

39401 Mr. Colee, At approximately 2202 hours

on April 25, 2019, the following less than Poultry

Good Commercial Practices (GCP) incident was

observed at P517, Mar-Jac Poultry, Hattiesburg,

MS. The employees had gone to break without

removing DOA birds from the DOA conveyor, nor

the pile on the floor adjacent to the South live

hang conveyor.  observed chest

movement and paw movement in the pile on the

conveyor. It took approximately five minutes after

notification for establishment personnel to begin

attempting resolution of the situation. During

resolution two birds were observed trapped

among DOAs. Comingling live birds and DOAs

can lead to suffocation 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. 

 met with 

 at approximately 2110 hours on the live

hang dock to discuss the less than GCP incident. 

 was advised a GCP Memorandum of

Interview would be issued to management

pending review by . 

Respectfully, cc: 

(b) (6)

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

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 90

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Code TaskName Status MOI Agenda

90 P517 Mar-Jac Poultry-MS QOO40050

52328G

28MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Joe Colee Complex Manager Mar-Jac

Poultry, MS 1301 James Street Hattiesburg, MS

39401 Mr. Colee, At approximately 2050 hours

on May 27, 2019, the following less than Good

Commercial Practices (GCP) incident was observed

at Mar-Jac Poultry in Hattiesburg, MS. One (1)

alert live young chicken with no cut to its neck,

it's head raised, and vocalizing from an

approximate 500 bird random subgroup sample

entered the scald tank on the north picking line

which feeds evisceration line #1. Barry Sparks,

Plant Superintendant, was verbally notified of the

incident at approximately 2055 hours. A second

verification check of an approximate 500 bird

random subgroup sample on the north picking

line 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 GCP

and causes needless suffering and death and

results 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. 

Mr. Sparks was advised a GCP Memorandum of

Interview would be issued to management

pending review by . 

Respectfully, . 

_______________________________________ 

, Hattiesburg,

MS 39401 cc: 

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 91

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Code TaskName Status MOI Agenda

90 P522 Sanderson Farms, Inc. (Processing Div) IKB580504

4326G

26APR2019 04C05 Poultry Good

Commercial

Practices

Finalized On April 26, 2019 at approximately 0456 hours

while conducting a Good Commercial Practice

check in the Picking Room of establishment

P-522, I observed sufficient evidence to support

that the stunner located on the inside picking line

was inoperable and as such approximately 54

conscious birds drowned when the picking line

was stopped. 

 was informed of the forthcoming

GCP MOI documenting this incident.            

Respectively, 

 Dr.

Gregory Brookhouser, DDM

90 P522 Sanderson Farms, Inc. (Processing Div) IKB500605

2320G

20MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized On May 20, 2019 at approximately 0518 hours

while conducting a Good Commercial Practice

check in the Picking Room of establishment

P-522, I observed sufficient evidence to support

that the stunner located on the inside picking line

was inoperable and as such approximately 28

conscious birds drowned when the picking line

was stopped.  Additionally, I observed 8 live birds

enter the scalders on the inside picking line. There

was no blood or cut on the neck of the birds.  The

birds were alert, blinking their eyes and looking

around as they hung on the Picking Line

 and Brandon

Macloud, Plant Manager, were notified of the

pending MOI. Respectively, 

Dr. Gregory Brookhouser, DDM

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

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 92

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Code TaskName Status MOI Agenda

25 P529 Pilgrim's Pride Corporation ODE35100

61226G

26JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0310 on Tuesday June 18, 2019,

I was notified by that an

on-line USDA food inspector had condemned two

cadavers within a five-minute period. I evaluated

the two carcasses hanging behind the inspector's

stand, they appeared bright red to purplish with

no evidence of a cut on their neck. I notified Kill

and of our findings. He

implemented his corrective actions which

consisted of raising both the stunner and the

automatic neck cutter to compensate for the bird

size variation. He also mentioned that if more

cadavers are encountered the back-up cutter

would be substituted. As I walked to the

inspector's stand at around 0330, I noticed two

more cadavers hanging behind one of the

inspector's stands and two more cadavers

recorded on the lot tally sheet of a different

inspector; all on line two. I went out to the live

hang area to evaluate the stunning and cutting

machinery, both of which appeared to be working

properly. Then I stood by at the end of the blood

tunnel to evaluate the birds bleed out and noticed

an uncut bird. Upon further evaluation the neck

was extended downward, and no blood stain or

cut was noticed on the neck region. 

, was immediately

notified of the uncut bird at around 0345 and he 

said that the back-up cutter will be replaced. I

then went to the transfer table to wait  for the

cadaver and condemned the carcass at that

point.         At around 0420, while giving breaks to

on-line inspectors,   approached

me to indicate that there were three more

cadavers identified by three inspectors on line

one. After finishing giving breaks, I went and

looked at the cadavers inside the condemned

barrels and they looked bright red with no

evidence of a cut on their neck. Then I went to Kill

and Pick to notified of the

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

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 93

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Code TaskName Status MOI Agenda

cadavers found on line one. In addition,

mentioned that the week before (Wednesday

June 12, 2019) management was informed of one

inspector finding three cadavers in less than 10

minutes right before lunch. That day there were

12 cadavers in total for the night shift. The next

day (Thursday June 13, 2019) there were 20

cadavers in total for the night shift.    This topic

was discussed at the weekly establishment

meeting Thursday June 13, 2019 at 0545. The

establishment's corrective action was to re-train

the back-up cutter and talk about humane

handling and animal welfare.
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 94

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Task

Code TaskName Status MOI Agenda

60 P533 Hain Pure Protein Corporation - FreeBird

East

AKB270304

3116G

16APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0400 hours I was in the live

receiving department on the catwalk standing

next to the establishment employee operating the

hydraulic controls to dump the birds onto the live

hang conveyor belt. The belt was clear in the area

where the birds being dumped from the cages go.

The plant employee retracted the cage box from

the dumper and noticed that the bottom section

of birds had not emptied onto the belt from the

previous time that the cage was dumped. The

plant employee then dumped the bottom section

of birds (approximately 20 birds) from the cage

onto the empty belt. The employee then

immediately dumped a completely full cage box

on top of the approximately 20 birds that were

still on the belt. The 20 birds that were on the belt

previously were buried under the new birds that

were dumped. The 20 birds could be seen visibly

struggling underneath the birds on top of them. I

immediately informed 

 of what I had observed. He informed

me that he was going to speak with the employee

in question immediately to prevent a

reoccurrence of the situation. I then found 

, in the

establishment office and explained to him what

had occurred. He expressed that he would also

look into the situation.

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 95

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Code TaskName Status MOI Agenda

60 P533 Hain Pure Protein Corporation - FreeBird

East

AKB002104

3525G

25APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2020 hours while performing a

walkthrough of the live receiving area my 

, and I observed a live bird in the DOA

auger which at this point was still off and not

running. The bird was upside down with its head

in the auger and struggling to breath when we

saw it. We informed 

, immediately and he removed the bird

which started vocalizing and flapping its wings as

soon as it was removed from being lodged head

first into the auger. Also, one of the bird's wings

had been badly broken and mutilated and overall

the bird appeared to be in intense pain. I saw

them place the bird back over in the live hang

area to be properly slaughtered. After speaking

with he immediately started

instructing the plant employees on the

importance of making sure that the birds are

definitely deceased before they are placed in the

DOA auger. After speaking with 

, I was informed that he

would speaking with about the

situation to resolve the issue further and verify

that this will not occur again in the future. In the

past USDA was told that if a bird appeared that it

might still be alive that it would be properly and

humanely euthanized by a trained supervisor or

department lead employee before being placed in

the DOA auger.

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

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 96

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Task

Code TaskName Status MOI Agenda

25 P544 Jennie-O Turkey Store IYW450504

3216G

16APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Poultry Handling at Loading MOI for

P544/Jennie-O Turkey Store, Melrose, MN 8th

April 2019 During ante-mortem inspection of

trailers at approximately 12:40pm before harvest

operations on the 2nd shift, the following

observations were made: Four trailers (1911,

1926, 1924, 1932) contained light hens observed

sitting two to four layers on top of each other. 

Heads were observed stuck between bodies on

the bottom, necks were twisted back, and live

birds with heads above were open mouth

breathing.  Single layer live birds in other trailers

did not observe to have open mouth breathing. 

One trailer (1911) contained an increased

observance of bloody ledges, blood splattered

birds, and due to the stacking, it was difficult to

identify what kinds of injuries all contributed to

the blood.  On the driver side of the second tower,

one live bird was observed to have its leg

amputated, missing the left pad and toes.  One

bird was observed open mouth gasping with its

neck approximately 9inches out of the trailer cage

and positioned under at least 2 live birds.  Birds

were observed double to quadruple stacked on

each other. One trailer (1926) was observed to

have three and four layers of stacked birds on the

passenger side of the trailer, with the driver side

with open space.  A number of the birds on the

bottom of the stacked layers were dead on arrival.

The observations regarding the trailers were

brought to the attention of 

 at 12:55pm. Review of the DOA

numbers for trailer 1911 (64) contributed to

65.3% of the DOAs for that lot 9347/Hiltner. 

Trailer 1926 had 13 DOAs. Corrective measures

communicated from live haul supervision via 

was loader-operating retraining. 

This corrective measure was also cited during a

previous documentation of overloading and

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 97

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Task

Code TaskName Status MOI Agenda

increased DOA observations observed the 14th of

March and documented as part of weekly

meeting discussions the 21st of March (MOI

IWY3712030721), 28th of March (MOI

IYW50080303291) and the 4th of April (MOI

IYW43080430041).
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 98

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25 P579 Jennie-O Turkey Store Sales, Inc. UIO100405

4616G

16MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized I, was notified by 

 at approximately

5:00 am this morning that the spotter dumped a

truck containing a load of birds in the yard. When

I arrived on the scene shortly after, I saw one of

the trailers containing a full load of Turkeys

(trailer # 1007) was tipped over and on its right

side with the tractor up in the air (tires off the

ground) about 6' in the air. I observed

approximately 30-40 turkeys on the ground that

had experienced injuries when the roof panels

gave way from the top of the truck. I observed

both injured and non-injured turkeys on the

ground around the truck. Some turkeys were

walking around as if nothing happened while

others had varying degrees of injuries with some

dead birds observed as well from the accident.  

 and stated that because of the way the

tractor and trailer were positioned that they

deemed the area too dangerous for employees to

enter and address or unload the birds as the

tractor trailer could shift at anytime and

potentially injure someone. The establishment

taped off the area to prevent establishment

employees and other personnel from entering

until the area could be made safe for employees

to enter and deal with the birds and clean-up the

scene. I observed 

at the site monitoring employee safety.  I was

informed by that establishment employees

were not trained to deal with situations like this,

so, the loading crew and a tow truck company

were called to come-in and deal with the

situation. The loading crew was called at

approximately 5:10 AM.  The tow trucks didn't

show until approximately 6:30 am.  I observed

the loading crew personnel start remove some of

the birds that spilled out from the top row of the

truck onto the ground after the tow trucks

arrived. They also cut the front panels and cut the

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
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roof panels and extracted the birds from the top

row of the truck. Many of the ones that had fallen

to the bottom had suffocated and were dead at

time of removal. They were able to save some of

the birds, but, most observed had died from

suffocation. At approximately 08:35 AM, I

observed that the tow trucks had righted the

truck. I observed loading crew personnel cutting

coop doors in order to gain access to the birds.

Many of the birds on the down side of the truck

had died due to suffocation by birds above. The

loading crew along with the assistance of plant

personnel removed all dead birds, which were

condemned and denatured as required. Any birds

that were alive were diverted for slaughter.  At

approximately 9:05 AM the loading crew was still

working to sort birds (live birds from dead birds). 

The loading crew Supervisor informed me that

they felt they would be able to transfer the live

birds using the same trailer involved in the

accident and would be placing the side panels

back on the truck to contain the birds, since, the

coop doors had been cut and removed; to prevent

further injury to any of the birds during

movement to the live hang area for slaughter.  

The establishment had addressed all the birds

involved in the accident and cleaned-up the area

by the end of 1 shift EVIS operations (12:45 pm).  

I reviewed the establishments GCP paperwork on

05/15/19 at approximately 12:00 pm and did not

see any reference or documentation by the

establishment surrounding the incident.  The

plant had listed 567 birds as plant

rejects/condemns from the affected lot with most

if not all presumed to be coming from the trailer

of birds involved in this incident. The birds

involved were Fay 3, Flock # 200696, Lot # 479,

5,616 birds/Lot. A typical truck holds

approximately 850 to 880 turkeys. Based on this

information USDA estimates that the
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 100

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Task

Code TaskName Status MOI Agenda

establishment lost a little over 60 % of the birds

from the trailer due to suffocation or other

traumatic injuries, with, most of the loss due to

suffocation.
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 101

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Task

Code TaskName Status MOI Agenda

80 P622 Tyson Foods NLB252006

2403G

03JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Ira Phillips, Plant Manager Establishment

P622 Tyson Foods, Inc. Monroe, NC 28110 Mr.

Phillips, On 6/3/2019, at approximately 1737

hours, while performing a Good Commercial

Practices task in the Kill Room, I noted a bird pass

by the back-up killer uncut.  At the time of my

observations, the bird had normal rhythmic

breathing, eyes open and blinking with the head

elevated.  No team member in the area had

noticed that this bird passed uncut, so I had the

line stopped and called a team member to

remove the bird from the line.     On further

observation of the bird, I confirmed that there was

no evidence of a cut on the neck to allow it to

bleed out completely before entering the scalder. 

The bird was placed back on the line to go

through the proper slaughter process.  

 and 

 was

shown my findings.  and 

confirmed that a new back up killer was being

trained and that they would ensure that the

experienced back up killer was paying close

attention to prevent recurrence.  Following this

conversation, I repeated my Good Commercial

Practices task and verified that the number of

stunned birds and manually killed birds was

appropriate.  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). If you have

any questions or concerns regarding this MOI,

please feel free to contact myself or 

. Respectfully, 

-Tyson Foods,

Inc., Monroe

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

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

(b) (6)

(b) (6)
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Code TaskName Status MOI Agenda

80 P622 Tyson Foods NLB331306

2505G

05JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Ira Phillips, Plant Manager Establishment

P622 Tyson Foods, Inc. Monroe, NC 28110 Mr.

Phillips, On 06/04/2019, at approximately

01645 hours, while walking into the plant I noted

that both evisceration and picking lines were not

running.  As I proceeded through the Picking

Room towards the Live Hang Room, I noted there

were no birds on either picking line prior to the

scalders.  In the Live Hang Room, I observed that

both Live Hanging Belts, which conveys live birds

from the Dumper to the Hanging Station, were full

of birds. Each belt contained large numbers of

birds such that there was little room for individual

movement and the high density of birds was

observed to extend back to the Dumping Station

for both lines.  At the time of my observations, I

observed that birds on each belt had open mouth

breathing and there were no team members in

the area.  At the Dumping Station, there were 3

cages in queue for each line on the platform.     I

returned to the Upper Evisceration area and 

, confirmed that both lines had been

stopped for 28 minutes.  I informed him of my

observations in Live Hang, as well as the failure to

follow the plant’s written Action Plan in the event

a picking line is shut down for an extended period

of time.  The Action Plan outlines the steps to be

taken in the event of an extended shut down (i.e.

longer than 10 minutes); including the 

. 

immediately directed that the live birds be

removed from the Live Hanging Belt and return of

the queued cages to the trailers over his radio. 

When I returned to the Live Hang Area, I observed

large numbers of dead birds on the floor behind (b) (6)

(b) (4)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 103

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Code TaskName Status MOI Agenda

both hanging lines and two racks of dead birds

being pushed out to the dumpster.  These dead

birds were being removed from the Live Hanging

Belt as the live birds were being returned to

cages.  At 1740 hours, Mr. Ira Phillips, Plant

Manager, and

came to the Live Hang Area and

I informed them of my observations and the

failure of team members to follow the plant’s

written Action Plan.  In all there were 245

carcasses that had been removed by the time Live

Hang was returned to process control at 1750

hours.  It is likely that the large number of dead

birds on the Live Hanging Belt was due to

smothering.     Operations resumed once process

control was returned in the area and Mr. Phillips

and were made aware of my findings

and was notified that a GCP MOI would be written

as a result.  Mr. Phillips stated that he would

address the situation to prevent this from

occurring in the future.  It is important that the

plant’s preventative measures be proactive and

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 Dr

. Respectfully, 

-Tyson Foods, Inc.,

Monroe

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 104

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Task

Code TaskName Status MOI Agenda

80 P622 Tyson Foods NLB151606

3310G

10JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Ira Phillips, Plant Manager Establishment

P622 Tyson Foods, Inc. Monroe, NC 28110 Mr.

Phillips, On 6/10/2019, at approximately 1635

hours, while performing a Good Commercial

Practices task at the head puller for Line 2, I noted

a live bird about to enter the scalder.  At the time

of my observations, the bird had its eyes open and

blinking with the head elevated above the head

puller.  No team member was in the area and I

could not stop the line before the live bird entered

the scalder.       I waited for the bird to exit the

scalder on Line 2 and upon exiting the scalder I

confirmed that there was no evidence of a cut on

the neck to allow it to bleed out completely

before entering the scalder.  The bird’s head, neck

and breast were bright reddish purple in color.  I

followed the carcass through the rest of the

Picking Room and caught the head at the head

puller after the pickers.  At the transfer belt in the

Evisceration Department, where the birds are

transferred to the Evisceration Line, I observed a

team member taking the bird off the line and put

it into a USDA yellow condemn barrel.   I called

, to

the area and showed him my findings in upper

evisceration.  went to the kill room and

found that the number of manually killed birds

exceeded the plant’s plan.  He made an

adjustment on the automatic kill blade and I

verified that the number of stunned birds and

manually killed birds was appropriate. 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).   If you have any questions or

concerns regarding this MOI, please feel free to

contact myself or 

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 105

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Task

Code TaskName Status MOI Agenda

 Respectfully,   

-Tyson Foods, Inc., Monroe

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 106

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Code TaskName Status MOI Agenda

90 P6504 Peco Foods, Inc. CHK21020

40917G

17APR2019 04C05 Poultry Good

Commercial

Practices

Finalized P-6504, Peco Foods Inc., Tuscaloosa AL 16 April

0245 hours Meeting Participants:  

                                     

 At

approximately 0245 hours on 16 April 2019 in the

live hang area of P-6504, I witnessed that there

were approximately 10 or more birds piled on top

of each other at the end of the live hang belt. 

Some were partially stuck under the roller at the

end of the belt by wings and feet.  The lead live

hang person then used his arms to sweep the

birds that were piled up at the end of the belt to

force them back on top of the incoming birds

from belt away from the roller.  This sweeping

action resulted in birds being thrown a short

distance, landing on top of those birds coming

down the belt and possibly smothering those

birds underneath them.  Further investigation

revealed that the bird density on the incoming

feed belt was very high -- too high in my opinion

for the hangers to effectively handle the birds as

observed by the back-up of birds waiting to be

hung on the kill line leading to the mistreatment

of the birds at the end of the line as described

above.  was

informed of the birds piling up and the overload

on the incoming belt.  supervised

the pile-up at the end of the belt and gave

direction to the lead hanger to correct the issue. 

A discussion between myself and 

 ensued to inform the

establishment that they were not treating birds in

a manner consistent with good commercial

practices.  Video surveillance should be available

to justify my claims.  went to check

the videotape.  I am unaware of any further

actions that were taken.  Later in the shift I

checked the hanging procedure in live hang and

the incoming belt for bird density and was

satisfied that the birds, at that time, were being (b) (6)

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

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 107

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Code TaskName Status MOI Agenda

handled appropriately, hopefully as a result of

actions taken by plant management.

90 P6504 Peco Foods, Inc. CHK41220

54012G

12MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized P-6504 Peco Foods, Inc. Tuscaloosa, AL 

Meeting Date:  8 May 2019       Meeting Time: 

0400 hours Meeting Participants:    

                                     

                                    

                                    

                                    

 

                                    

             On May 2, May 5, and May 8

2019 on the transfer belt conveying live birds

from the dumper into live hang 

 witnessed, at approximately 0200

hours on each morning, the piling of live birds on

top of one another.  The handling of live birds in

this manner is inconsistent with industry

standards for good commercial practices.

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 108

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Task

Code TaskName Status MOI Agenda

90 P6504 Peco Foods, Inc. CHK15040

52324G

24MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized P-6504 Peco Foods Inc. Tuscaloosa, AL 

Meeting Date:   22 May 2019 Meeting Time: 

2215 hours Meeting Participants:   

        

             On 22 May 2019

while doing a Good Commercial Practices task at

P-6504 located just before bird entry into the

scalder tank at 2210 hours 

 witnessed a bird with a small cut in the

neck, head attached, eyes open, and making

conscious movements with its wings and legs go

into the scalder tank.  Because this bird was alive

and the head pullers before entry into the scalder

tank were not adjusted properly as had

informed the establishment previously the bird

missed the head pullers and proceeded into the

scalding tank before death.  The handling of live

birds in this manner is inconsistent with industry

standards for good commercial practices.

90 P6504 Peco Foods, Inc. CHK35020

53630G

30MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized P-6504 Peco Foods, Inc. Tuscaloosa, AL 

Meeting Date:  30 May 2019      Meeting Time: 

0055 hours Meeting Participants:    Sylvia

                                    

             On

30 May 2019 SPHV witnessed

the piling of live birds on top of one another at

approximately 0055 hours on the belt conveying

live birds from the dumper belt into live hang. The

handling of live birds in this manner is

inconsistent with industry standards for good

commercial practices.  

was apprised of the situation at the time it was

discovered on the back dock of P-6504.

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 109

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Task

Code TaskName Status MOI Agenda

85 P6519B Coastal Processing, LLC AGJ430906

4113G

13JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized To: Coastal Processing LLC, P6519B 1670

Forstman Rd. Louisville, GA 30434 On

Thursday, June 13, 2019 at approximately 0800

hours while observing operations in the live

hang/receiving area, I, , observed

an issue with the implementation of Good

Commercial Practices. While observing birds that

had passed the back-up killer’s position just prior

to entering the scalding tank, I observed an uncut

bird (i.e. live bird) enter the scalder. I followed the

bird down the line and instructed a plant

employee stationed after the pickers to remove

the bird from the line for my inspection. I quickly

found , in

live hang and showed him the bird. There was no

visible cut on the neck and the head and neck

were swollen and red/dark purple in color. I

informed that I would be issuing a

MOI for this occurrence. He called 

, who also came to look at the bird in

question. It was agreed that this bird was a

cadaver and it was condemned. Both 

and went directly to observe operations

at the back-up killer to ensure proper cuts were

being administered by the automatic blade and

after finding no issue with this, counseled the

back-up killer on his job performance. No other

live birds were observed entering the scalder at

the time of this occurrence.  After I returned to

the USDA office, came to speak with me

further regarding this issue. He stated he would be

writing an official response for this incident

documenting the establishment’s planned

corrective actions and preventative measures.  

This MOI serves as a reminder that the PPIA and

Agency regulations require that live poultry be

handled in a manner that is consistent with good

commercial practices (GCPs). Poultry are to be

slaughtered in a manner that ensures that

breathing has stopped before scalding, so that

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

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 110

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Code TaskName Status MOI Agenda

birds do not drown and that slaughter results in

thorough bleeding of the poultry carcass. Poultry

carcasses that show evidence of having died from

other means other than slaughter are considered

adulterated and must be condemned. Compliance

with these regulations helps ensure poultry are

treated humanely.  Respectfully,  

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 111

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Task

Code TaskName Status MOI Agenda

85 P713 Gentry's Poultry Co., Inc. HDA36150

43424G

24APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At 1505 on April 24th, 2019, I went into the

scald/picking room to monitor chickens entering

the scald tank and ensure that no birds were

entering the scald tank alive. Within a few

minutes of arrival, a chicken that was not stunned

(head was pulled up) and without any obvious

neck cut was seen to enter the scald tank. Unable

to remove the live bird or to stop the line, I

followed the line around and removed the chicken

from the line before the hock cutter. The body

was red with blood suffused in the neck and head.

No neck cut of any kind was evident. I walked

back to the scald tank to determine if this was an

isolated incident or not. I immediately saw two

chickens without any neck cuts enter into the

scald tank. I followed the line around and

removed both of these chickens off the line with

similar findings to the first - the bodies were red

with swollen heads and no neck cuts were

evident. I immediately took all three carcasses

and showed them to 

, at 1514. I told him that it was

unacceptable to have live birds entering into the

scald tank. Looking back at post-mortem

condemned records over the last two weeks,

there have been cadavers reported on 8 of the last

11 days. One of the days, April 11th, there were

22 carcasses condemned by inspection as

cadavers. This indicates a possible problem with

the establishment's overall system of ensuring

chickens are not entering into the scald tank alive.

Live chickens entering into the scald tank and

dying by means other than slaughter is not

following PPIA and Agency regulations requiring

that live poultry be handled in a manner

consistent with good commercial practices. This

MOI has been forwarded to 

and

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 112

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Task

Code TaskName Status MOI Agenda

85 P713 Gentry's Poultry Co., Inc. HDA20080

51307G

07MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At 1445 on May 6th, 2019, I went into the

scald/picking room to monitor chickens entering

the scald tank and ensure that no birds were

entering the scald tank alive. Within one minute

of arrival, a chicken that was not stunned (head

was pulled up) and without any obvious neck cut

was seen to enter the scald tank. Within 30

seconds, a second conscious chicken without a

neck cut entered the scald tank. Unable to remove

either bird due to the height of the line or to stop

the line, I followed the line around and removed

both chickens from the line before the hock

cutter. Both bodies were red with blood suffused

in the neck and head. No neck cut of any kind was

evident on either chicken. I immediately took the

two carcasses and showed them to 

, at 1500. I told him that it

was unacceptable to have live birds entering into

the scald tank. This is a repetitive issue that the

establishment has been notified about on

multiple occasions. Corrective actions have failed

to be effective in preventing live chickens from

entering into the scald tank. A MOI was

documented on April 24th, 2019 for the same

finding (HDA3615043424G). This issue has been

brought up at USDA/establishment meetings,

including 4-2-19 (HDA1513045902E) and 5-2-19

(HDA0207050103E). The establishment has been

unable to prevent live chickens from entering into

the scald tank. Live chickens entering into the

scald tank and dying by means other than

slaughter is not following PPIA and Agency

regulations requiring that live poultry be handled

in a manner consistent with good commercial

practices. This MOI has been forwarded to 

 and 

.

(b) (6)(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 113

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Task

Code TaskName Status MOI Agenda

35 P72 Tyson Foods, Inc JPJ231205

1707G

07MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At 0500 Hrs on 5/06/2019 while performing Ante

Mortem inspection prior to First shift beginning

and 3rd shift ending, I stepped up on the platform

cage dumping area platform. I observed a chicken

that appeared not to be breathing with its head

caught between the live hang conveyor belt and

the plastic flap attached to the right side metal

frame.  

was entering the area and I showed

 the condition of the bird.  When the belt was

started the chicken carcass came out from

underneath the plastic flap and conveyed up the

belt.  It was evident the bird was deceased. 

condemned the bird in the Live hang area.  

According to the establishment Good Commercial

Procedure plan 

  Dumping area team member is

responsible to check live bird infeed belt for any

caught up birds”.  This created a concern that the

equipment caused the injury and death of a bird

and I expressed my concerns of why this was not

addressed when it occurred. 

 and was to

investigate the reason by reviewing footage from

the camera system.  Later in the afternoon, 

 stated the area could not be viewed from

this angle on the camera footage.  Additional

investigation will be performed and repairs if

needed. Repairs were made to the equipment to

prevent the ability of chickens to get caught up in

the area and was verified on 5/7/2019.

(b) (6)

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

(b) (4)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 114

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Task

Code TaskName Status MOI Agenda

90 P7342 Wayne Farms LLC SCJ461306

5307G

07JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On 06/07/2019, at approximately 1310 while

performing my Good Commercial Practices at the

entrance of the scalder on Line 2 (New

Kill/Picking/Evisceration Line), I

observed two uncut, live birds pass by at

approximately 1311 and 1312. I noted that the

birds were breathing and alert to their

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 birds as they entered and exited the head

puller (prior to the entrance of the scalder) and

into the scalder where both entered still

breathing. I completed my check and went to the

exit of the picking system where I observed four

cadaver birds (two that had previously passed

prior to my GCP check and two mentioned

above), head attached and bright red in color, exit

the picking system at the rehang table.

Establishment personnel promptly removed all

four cadaver birds and threw them into the drain.

I also observed during this time another bird with

the same appearance had been taken off the line

and placed next to the main drainage area exiting

the evisceration department. I immediately

notified 

of my observations. After notifying , I

returned to the stunning, cutting/kill, and back-up

cutting/kill area where I observed approximately

every 7th-8th bird missing the kill blade. The

back-up killer (establishment personnel with

knife) was able to effectively keep up with the

missed birds during my observations

(approximately 5-10 minutes).  stated

that once notified he also immediately observed

back-up killer personnel and did not note any

deficiencies. Equipment effectiveness was also

evaluated and no obvious issues were noted. He

stated that retraining would be implemented, as

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 115

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Task

Code TaskName Status MOI Agenda

well as, additional documented checks. At

approximately 1330, I again performed another

GCP check on this line and observed no birds

entering the scalder alive. No other vulnerabilities

were noted during today's production.
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 116

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Task

Code TaskName Status MOI Agenda

80 P764 Perdue Foods, LLC CUA41090

51620G

20MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview 

                                                                                     

                                                                           May

20, 2019 

                                                                                     

                                                                          

Perdue Foods, LLC 

                                                                                     

                                                                           P-764

                                                                                     

                                                                          

Salisbury, MD Attendees:                 

,

Perdue Foods, LLC                

 USDA, P-764 A meeting was held at

approximately 0840 hours in the office of the 1st

Processing Business Unit Leader, P-764, Perdue

Foods, LLC in Salisbury, Maryland between 

 and me.  I identified myself as

  He acknowledged that

he understood my official capacity through the

conversation. The purpose of the meeting was to

discuss the poultry good commercial

practices / poultry welfare concern that I had

observed at 0704 this morning.  At 0704 while

performing the good commercial practices check

in the picking / dressing room, I observed a

cadaver (a bird with bright red skin color all over)

on kill line 2 as it moved through the post-pick

PAA dip tank.  As it exited the dip tank, I could see

that the head was still attached and that it had no

kill cut (or other cut) on its neck or throat.  I

removed it from the line before it went to the

hock cutters.  I notified

 at that time and

had call over to the area. 

When arrived at 0712 hours, I showed

him the cadaver bird.  While waiting for 

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
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Code TaskName Status MOI Agenda

 to arrive, I continued to observe the birds

on kill line 2 and saw no further cadavers.  I went

into the kill room and observed the stunning and

slaughter process and could not see any problems

there.  The slaughter process appeared to be

under control. I reminded that the

Poultry Products Inspection Act and Agency

regulations require that live poultry be handled in

a manner consistent with good commercial

practices and that they not die from causes other

than by slaughter.  I told that this

memorandum of interview will be forwarded to

the district office and the District Veterinary

Medical Specialist (DVMS) in case additional

follow-up is recommended.  told me

that he had spoken with the associate in the

position of the back-up killer for kill line 2.  The

back-up killer said that excessively small birds

were being hung on the line, leading them to miss

the kill blade.  said he coached him

about stopping the line if such a problem was

identified, to bring it to their attention (as

excessively small birds were not supposed to be

hung by the live hang associates). I attest that

this memorandum includes all the information

discussed during the meeting to the best of my

knowledge.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 118

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Task

Code TaskName Status MOI Agenda

80 P764 Perdue Foods, LLC CUA23080

61314G

14JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview 

                                                                                     

                                                                 June 14,

2019 

                                                                                     

                                                                 Perdue

Foods, LLC 

                                                                                     

                                                                 P-764 

                                                                                     

                                                                 Salisbury,

MD Attendees:                Mr. Kevin Dennis,

Director of Operations, Perdue Foods, LLC 

              

, USDA, P-764      

                     A meeting was held at 0744 hours in

 office at P-764, Perdue Foods, LLC in

Salisbury, Maryland between establishment

management and me.  I identified myself as 

.  The

establishment management acknowledged they

understood my official capacity through the

conversation. The meeting was held to discuss a

poultry good commercial practices (GCP) incident

that I observed while performing a routine poultry

welfare GCP check in the receiving department at

0736 hours.  At the dead on arrival (DOA) area of

the receiving department, I was checking the DOA

tank and DOA sorting table/tank.  The sorting

tank is where some birds go immediately from the

live hang department to be sorted: well birds,

unwell birds (to be euthanized), and dead birds

(DOA to go into the DOA dumpster).  Here at the

sorting tank, I observed a large quantity

(approximately 400-500) of small birds.  There

(b) (6)

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were so many birds that live birds were piling on

top of dead and non-ambulatory disabled birds. 

There were 4 to 5 layers of birds in some areas of

the table.  I notified , receiving

supervisor, immediately of my concerns.  Birds

kept coming from the live hang conveyors, so I

took regulatory control of the live hang

department by tagging the room with U.S.

Rejected tag number B-45337992 after informing

 that I was doing so and the reason. I

informed the establishment management that

this was a poultry welfare concern because birds

could suffocate due to being piled so high upon

each other.  The process was out of control during

this incident and was not acceptable.  The

establishment management concurred and said

they would reduce the kill line speed, to decrease

the rate which the birds were arriving to the DOA

sorting area.  I reminded the management that

the PPIA and Agency regulations require that live

poultry be handled in a manner consistent with

good commercial practices and that they not die

from causes other than by slaughter.  I notified

establishment management that this MOI would

be forwarded to the district veterinary medical

specialist (DVMS) and district office in case

follow-up is recommended. Regulatory control

was relinquished at 0820 hours upon verification

of acceptable conditions at the DOA sorting tank. 

I attest that this memorandum includes all the

information discussed during the meeting to the

best of my knowledge.

(b) (6) (b) (6)
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25 P7669 Turkey Valley Farms LLC RZB080705

1322G

22MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. 7669p Turkey Valley Farms, May 22nd, 2019 

At approximately 0630 hours, while performing a

Good Commercial Practices verification task, I

observed 1 out of 100 carcasses showing signs of

consciousness (blinking eyes, open mouth

breathing, raised head, and wing movement)

proceed into the scalder. The establishment had a

back-up killer located approximately 10 feet prior

to the final stunner which is just prior to the

scalder. The bird had it's head raised with no cut

present. The back-up killer did make a cut on the

neck.However, the final stunner was not

positioned high enough to make contact with all

of the birds. 

, was notified immediately. He notified me

that they were training new employees and then

he made adjustments to the stunner. An

additional 100 bird check was conducted at this

time and no further issues were observed.

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25 P7669 Turkey Valley Farms LLC RZB001105

4330G

30MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. 7669p Turkey Valley Farms, May 30th, 2019 

At approximately 0910 hours, while performing a

Good Commercial Practices verification task, I

observed two cherry-red carcasses on the

transfer/rehang table. I did not observe a cut

present on the neck. While examining these two

carcasses, an additional carcass was thrown onto

the table that also did not have a cut present on

the neck. I then proceeded into the picking room

to observe birds prior to the scalder. While

observing birds prior to the scalder, I observed 2

out of 50 carcasses showing signs of

consciousness (blinking eyes, open mouth

breathing, raised head, and active wing

movement) proceed into the scalder. No cut was

present on the neck. 

, was notified immediately. At this

time, and I observed 1 out of 100

carcasses showing signs of consciousness proceed

into the scalder. stated that the two

back-up killers were inexperienced and he placed

a trained employee into the back-up killer

position. At approximately 0920 hours, an

additional 200 bird check was conducted and no

further issues were observed at this time. Again at

approximately 1100 hours an additional 100 bird

check was conducted and no further issues were

observed at this time.  A similar Good

Commercial Practices MOI was documented on

5/22/19, RZB0807051322G, titled Poultry Good

Commercial Practices / RZB0407050122I.

(b) (6)

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25 P7669 Turkey Valley Farms LLC RZB320906

1710G

10JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. 7669p Turkey Valley Farms, June 10th, 2019. 

At approximately 0910 hours, while observing

operations in the Evisceration Department, I

observed 2 cadavers (cherry-red carcasses with

blood pooling at the neck region) at the USDA

inspection stations and 1 cadaver on the floor

near the rehang/transfer table. Upon inspection,

these birds did not have an adequate cut present

on the neck. I then proceeded into the picking

room to observe birds prior to the scalder.

, was present at this

time. While observing birds prior to the scalder, I

observed 1 out of 100 carcasses showing signs of

consciousness (blinking eyes, open mouth

breathing, and raised head) proceed into the

scalder. No cut was present on the neck. 

, was notified immediately. 

stated that he would make adjustments to the kill

machine to ensure the cut would be properly

positioned.   At approximately 0920 hours, an

additional 200 bird check was conducted and no

further issues were observed at this time.At

approximately 0930 hours, I informed Plant

Manager, Shawn Kaas, of my observations and

informed him that this is the third similar incident

since 5/22/19. He stated that he would take care

of the issue. A similar Good Commercial

Practices MOI was documented on 5/22/19,

RZB0807051322G, and

5/30/19, RZB0011054330G.

(b) (6)

(b) (6)

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35 P768 Tyson Foods, Inc. BFC171404

3123G

23APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At 1130 hours, while performing Good

Commercial Practices and observing the stunners,

cutters, and backup cutters, I, 

 observed an almost-decapitated dead bird

hung in shackles on the line closest to me coming

out of the stunner, before the cutter. The bird’s

body was slightly curved, with the head hanging

in the right shackle (to my view). The esophagus

and trachea were all that connected the head to

the body. The bird was covered in bright red

blood. The birds to the left and right of the

almost-decapitated bird were also covered in

bright red blood. I did not observe how the bird

was almost decapitated, but due to the amount

and location of the blood, it likely happened

recently, possibly in live hang. The backup cutter

removed the almost-decapitated bird from the

shackles and placed it on the floor. I informed

 of my observation and

showed him the bird at 1135 hours. I also

observed multiple less-than-perfect conditions in

live hang. I noted a large amount of chicken litter,

chicken heads, and debris dispersed on the floor

of live hang (1132 hours). I counted least ten flies

in three yellow condemn barrels (one full of

decapitated chickens and heads, one 2/3 full of

chicken litter, and one coated in blood) and along

the corner near the white board in live hang at

1137 hours. Three of the yellow condemn barrels

in live hang were thoroughly coated inside with

blood. At about 1139 hours, I observed an

establishment employee transporting live small

birds for decapitation inside a yellow condemn

barrel (the birds were unharmed in the barrel and

were not piled on top of each other). 

Additionally, at 1152 hours, I watched an

establishment employee dump birds from one of

the yellow condemn barrels into the outside

white tote near dumping. The birds in the barrel

had not been decapitated. The employee told me

(b) (6)

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that the birds had been left over from night shift,

and the contents of the barrel smelled rank. 

When I observed live hangers at 1140 hours, I did

not see any mistreatment of birds. When I again

observed the stunners, cutters, backup cutters,

and live hang starting at 1310 hours, I did not see

any major issues (only two flies in a yellow

condemn barrel in live hang). I understand that

live hang has been short staffed. At this time, I do

not see a loss of process control, however I am

concerned that live hang may be working faster

than they can handle. At this time, I am not

considering slowing the line speed, but I will be

monitoring live hang for the remainder of this

shift to make sure these issues do not progress to

loss of process control. At 1337 hours, I informed

Establishment management 

, and of

my observations as described above. They

acknowledged and told me they would investigate

the cause of the almost-decapitated bird. The

meeting concluded at 1344 hours.

(b) (6)

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80 P7903 Perdue Foods, LLC UYN19130

40201G

01APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0600, while performing a

Poultry Good Commercial Practices verification

check in the live hang area, a live bird was heard

chirping in the hopper of the DOA conveyor.  The

hopper was approximately 1/3 of the way full

(approximately 30 – 40 birds) and the live bird

was not able to be seen.  The plant employee that

was present advanced the belt and, again, the live

bird was heard chirping, but unable to be seen. 

The belt was advanced again and the live bird was

uncovered from the other dead birds that were

completely covering it initially. 

arrived at the

hopper and was able to remove the live bird from

the stainless steel enclosure.  All of the carcasses

that were present within the hopper had already

been denatured, including the one bird that was

still very much alive.  I reminded of

the plant’s responsibility and obligation to handle

the live birds in a manner consistent with the

requirements of FSIS Directive 6100.3 and the

Code of Federal Regulations. After leaving the

receiving area, I spoke with and

 about my findings and conversation

with .  indicated that the

Perdue disciplinary process would be utilized to

handle the mismanagement of the live

hanging/sorting process. All the aforementioned

statements are true and correct to the best of my

knowledge, as indicated by my electronic

signature below.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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80 P7903 Perdue Foods, LLC UYN09140

45426G

26APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Today, April 25, 2019 at approximately 2125

hours, while performing a Poultry Good

Commercial Practices verification in the area

where the DOA truck is located I, 

, observed one(1) live bird laying inside of

the truck with several other carcasses that were

present had already been denatured. The plant

employee that was present was verbally notified

and shown the bird in question.

 was also

verbally notified. The plant employee that was

present was able to remove the live bird from the

DOA truck at approximately 2135 hours. I

reminded of the plant’s responsibility

and obligation to handle the live birds in a

manner consistent with the requirements of FSIS

Directive 6100.3 and the Code of Federal

Regulations. All the aforementioned statements

are true and correct to the best of my knowledge,

as indicated by my electronic signature below.

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

(b) (6)
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80 P7903 Perdue Foods, LLC UYN53170

65305G

05JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Today, June 5, 2019 at approximately 1511 hours,

while performing a Poultry Good Commercial

Practices verification in the area where the DOA

truck is located I, ,

observed one(1) live and denatured bird laying

inside of the truck with several other carcasses

that had already been denatured. The plant

employee that was present was verbally notified

and shown the bird in question.

 was also

verbally notified. The plant employee that was

present was able to remove the bird from the

DOA truck and humanely euthanized it at

approximately 1516 hours. I reminded 

of the plant’s responsibility and obligation to

handle the live birds in a manner consistent with

the requirements of FSIS Directive 6100.3 and the

Code of Federal Regulations. All the

aforementioned statements are true and correct

to the best of my knowledge, as indicated by my

electronic signature below.

(b) (6)

(b) (6)

(b) (6)
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80 P806 Tyson Foods, Inc. OGC24210

45811G

11APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P806, Tyson Foods, Inc.   April 11, 2019 2150

hours. In attendance: ;

.

At 2150 hours on April 11, 2019 I met with 

 to

discuss observations that occurred earlier in the

live bird hanging area. At 2052 hours when I

entered the live hang area I observed a large

number of DOA carcasses (approximately 40) in a

pile three and four layers high at the end of the

hanging belt. Buried within this pile I observed

several birds that from the portions of the body

parts that were exposed were observed to be

breathing. I also observed that there were

approximately ten live birds that were loose on

the live hang floor. There was no employee on the

floor in this area at the time. All employees were

actively hanging birds on the kill line and there

was no attempt being made to address this

situation. At this point I took action to stop the

plant from dumping any more cages of live birds

onto the hanging belt. Subsequent to this action

and after all live birds that were currently on the

belt were hung on the kill lines, the employees

then came down from the hanging line to address

this matter. Around the same time, I observed

that the DOA tank was being brought back in to

the live hang area. I observed as the employees

sorted through the pile of DOA carcasses,

segregating out the live birds from the DOA’s and

returning them to the hanging belt and placing

the DOA carcasses into the DOA container. I spoke

with 

 in regard to ensuring that all live birds

remain separate from the DOA carcasses and that

live birds that come off of the hanging belt and

are loose on the floor are addressed promptly and

returned to the hanging belt. After I observed the

employees properly retrieve the loose birds and

return them to the live hang belt, I then allowed

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

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the plant to resume the dumping of live birds

onto the belt and to begin normal hanging

operations.   I discussed with the

requirement that live poultry be handled in a

manner that is consistent with good commercial

practices to minimize any harm or excitement to

the birds and ensure that they do not die from

causes other than slaughter. I referred 

to the Federal Register Notice Vol. 70, No. 187

[Docket No. 04–037N], that presents FSIS

recommendations concerning the treatment of

live poultry before slaughter and offered to

provide a copy of this document. 

proposed actions to be taken to address this

situation in the future to include; maintaining an

individual on the floor to address any live birds

that come off of the hanging belt and are on the

DOA belt or the floor, and to have a backup

container or condemn barrel available for the

disposal of DOA carcasses when the DOA tank

becomes full and is removed from live hang to be

emptied. Upon completion of the meeting I

informed that this MOI will be

forwarded to the District Veterinary Medical

Specialist (DVMS) in the District Office in case

additional follow-up is recommended.   

Respectfully, , Est. P806

Tyson Foods, Inc.

(b) (6)(b) (6) (b) (6) (b) (6) (b) (6)
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80 P843 Pilgrims Pride Corporation PZA451305

4508G

08MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0937 hours, while performing a

Good Commercial Practice task, I, 

, went in the door at the lower end of

Evisceration Department that leads into the

Picking Room. While watching the birds go into

the scalder for approximately one minute and 37

seconds, I observed a live bird go into the scalder.

The chicken’s head was lifted upward and its eyes

were blinking. Upon further investigation, I went

to the Upper End of the Evisceration Department,

where the birds exit out the Picking Room into the

Evisceration Department. I wanted to follow the

bird into the Evisceration Department. While

moving into the area, at approximately 0941

hours, at the Pre-Sorter area, I observed a team

member taking the bird off the line and putting it

into a USDA yellow condemn barrel. I took the

bird out of the USDA yellow condemn barrel for

further observation. The bird’s throat had not

been slit. IPP had to ring bell for

. He agreed with my

observation. 

 and 

 were notified of this serious matter. 

This is a repeat MOI for live birds entering the

scalder. See MOI entitled, “Live birds going into

the scalder”, dated 5/2/2019. The previous

preventive measure was ineffective in preventing

recurrence.

(b) (6)

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

(b) (6)

(b) (6)
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85 P855 Pilgrim's Pride Corporation FDA20140

62507G

07JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P855, Pilgrim’s Pride, June 4, 2019, 1146

hours. In attendance: 

; and 

. I, 

, while conducting post-mortem

inspection at the inspection stations in the

evisceration department on Wednesday, May 29,

2019, observed the following:  At 0920 hours, I

observed a cadaver presented to the inspection

station on Line 4 Station 1.  I immediately

informed of the noncompliance. 

At 0946 and 0950 hours, I observed two cadavers

presented to the inspection stations on Line 3

Station 1 and Line 3 Station 2, respectively.  I

immediately informed of the

noncompliance.  At 1001 hours, I observed a

cadaver presented to the inspection station on

Line 3 Station 3.  I immediately informed 

 of the noncompliance.  Each of the

carcasses had the same presentation as grossly

bright red in color throughout the entire body, the

heads were attached, and the necks were not at

all cut, which indicates that the carcasses entered

the scalders alive and not at all bled out.  Each of

the cadavers were placed on the PHV shackles for

the plant to confirm the findings.  No one from

the plant responded to the observations at the

time of my observations.  The plant response was

received on June 4, 2019 by .  It

stated as follows: “Corrective actions for

cadavers on picking line 1 & 2: On 5/29/19 there

were cadavers found coming off of both picking

lines that made it to the USDA inspector stations. 

After investigation it was found that they were a

result of picking room lead giving breaks and not

catching all uncut birds at kill station.  Employee

was removed from the line and written up by

supervisor. Write up is on file in HR.” Again,

while I was conducting post-mortem inspection at (b) (6)

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

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

(b) (6)

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the inspection stations in the evisceration

department on Monday, June 3, 2019 at 0915

hours, I observed a carcass being presented to the

inspection station on Line 1 Station 1 that was

clearly a cadaver.  The carcass was grossly bright

red in color throughout the entire body, the head

was attached, and the neck was not at all cut,

which indicates that the carcass entered the

scalder alive and not at all bled out.  I

immediately informed the plant 

 of my observation and noncompliance. 

The cadaver was placed on the PHV shackle for

the plant to confirm the findings.  No one from

the plant responded to the observation at the

time of my observation.  The plant response was

received on June 4, 2019 by .  It

stated as follows: “Corrective action for cadavers

on picking line 1: The killer on line 1 was replaced

by a back-up killer with more experience than the

one we had on the line during the week of

6/1/19.  The previous killer was just a fill in used

for breaks and the one she was replaced with on

6/3/19 had performed the job for a longer period

of time in the past while working for the

company.  This employee was a rehire and will be

retrained on the new back up killer SOP along

with anyone who is sent to the kill room in the

future for any length of time.” During a meeting

with management on June 4, 2019, I reminded

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 notified management 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)

(b) (6)

(b) (6)
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90 P890 Peco Foods, Inc. CYD290304

0830G

30APR2019 04C05 Poultry Good

Commercial

Practices

Open At approximately 11:30 pm on the night of

4/24/19 was just finishing

his first set of breaks when he noticed several

members of Plant management and personnel

rushing to the back dock area.He immediately

followed to see what was happening when he

observed a plant’s truck suspended with

front wheels off the ground and its cab pointing

straight up.. The trailer (#57416) which was still

attached to the cab was laying flat on its right

side.Live and dead chickens were seen scattered

around the overturned truck with most chickens

still inside the cages piled on top of each other at

the bottom side (right) of each cage. At that time

 and 

informed Night Plant Manager Franklin Harris and

 that the

birds needed to be removed humanely and that

all live and dead birds should be accounted for.

Because of the way the trailer was positioned and

cages still being attached to the trailer by chains,

each cage had to be removed by forklift one at a

time and some had to be cut loose with a cutting

torch. This took considerable time (approximately

11:40 pm to 5:20 am) to accomplish and

probably allowed for many of the birds trapped

under the piles to suffocate and

 monitored the plant’s removal

and separation of live and dead birds at all times

and made sure that denaturant was applied to the

combos they were placed in. When the process

was completed there were 2 1⁄2 large, 2 medium,

and 5 smaller combos of dead birds totaling 2,969

birds which were killed by means other than

slaughter or an approved euthanasia method. This

GCP-MOI is being issued to the plant to document

basically a process control failure which led to

mistreatment, harm, and deaths of birds on its

regulated premises.                                                  

(b) (6) (b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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80 P9197 Perdue Foods, LLC. UAB25190

62107G

07JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On June 7, 2019 at approximately 1635 a bird

came to Line 3 Station 3 with the head still

attached, and no cut visible on the neck. The head

was engorged with blood, and from the base of

the neck to the head was discolored a dark

purple. The bird was not cut to facilitate bleeding

of the carcass, nor was the head removed by the

head-puller placed prior to the scalder. I notified

, who took the bird to 

, and then disposed of the carcass. This

establishment has a zero tolerance policy for any

live birds entering the scalder according to their

Poultry Care Process. The establishment has a

plan in place for handling animals from the time

they enter the premises. The last MOI written

regarding deviation from Good Commercial

Practices was received by the plant on June 4,

2019 citing that the establishment failed to

slaughter poultry in accordance with Good

Commercial Practices.

(b) (6)

(b) (6)

(b) (6)
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80 P9197 Perdue Foods, LLC. UAB05170

64013G

13JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized About 1730 hours, while giving breaks on Line 2,

 found a bird on the line

with the head still attached and no evidence of a

neck cut.  She showed the bird to 

, and .  When I inspected the

bird it was small for the lot, which is common for

both uncut and still-headed birds, as they miss the

knife machine and the headpullers.  There was

some evidence of a cut to the lower mandible

having removed keratin layers from the beak, but

no sign of any cut to the neck at all.  The head

was swollen and the head and neck both dark

purplish-red in color.  Regulations require that

birds shall have died by bleeding out before

entering the scalder; this was not possible in this

case, since there was no cut from which the bird

could bleed out and the head and neck were

engorged with blood.  It is a failure of Good

Commercial Practices to allow birds to enter the

scalder without being bled out, because such

birds are unsalable, and because of the possibility

of such birds drowning in the scalder, which is

inhumane.   This establishment has a zero

tolerance policy for any live birds entering the

scalder according to their Poultry Care Process.

The establishment has a plan in place for handling

animals from the time they enter the premises. 

The last MOI written regarding deviation from

Good Commercial Practices was received by the

plant on June 7, 2019, citing that the

establishment failed to slaughter poultry in

accordance with Good Commercial Practices.

(b) (6)

(b) (6)

(b) (6)
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80 P935 Allen Harim Foods, LLC. YXA071904

1602G

02APR2019 04C05 Poultry Good

Commercial

Practices

Open At approximately 1622 hours while providing a

break on line 2, station 3 I observed a carcass with

the head intact which was red to purple in color

and had not received a cut to the neck. 

 and

 were notified

of the observation of a bird dying other than by

slaughter. At approximately 1720 hours, after

completing the inspection breaks, 

stated that the cause of the uncut bird was failure

to make adjustments to the kill blade due to small

birds.  I performed Good Commercial Practice

verification by observing 200 carcasses enter the

scalder, and 200 carcasses at the kill blade.  There

were no live birds observed entering the scalder

and the back-up kill performed a cut to the neck

of all birds not cut by the kill blade. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, Allen

Harim Foods, LLC P935 Harbeson, DE. 19951

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

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 137

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA001904

4809G

09APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1650 hours while providing

inspection break on line 3, station 1 I observed a

carcass with the head intact which was red to

purple in color and had not received a cut to the

neck. 

and were

notified of the observation of a bird dying other

than by slaughter. At approximately 1700 hours,

after completing the inspection breaks, I

performed Good Commercial Practice verification

by observing 200 carcasses enter the scalder and

200 carcasses at the kill blade.  There were no live

birds observed entering the scalder and the

back-up kill performed a cut to the neck of all

birds not cut by the kill blade.  

determined the cause to be personnel not

performing job appropriately. It is

recommended that establishment management

review the Federal Register on “Treatment of Live

Poultry before Slaughter”, published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, 

Allen Harim Foods, LLC. P935 Harbeson, DE.

19951

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 138

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA431604

5723G

23APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1648 hours while providing a

break on line 1, station 3 I observed a carcass with

the head intact which was red to purple in color

and had not received a cut to the neck. 

 was notified 

of the observation of a bird dying other than by

slaughter. At approximately 1704 hours, after

completing the inspection breaks, 

 stated that the cause of

the uncut bird was failure to perform duties by

the back-up kill personnel who will received

disciplinary action.  I performed Good Commercial

Practice verification by observing 200 carcasses

enter the scalder and 200 carcasses at the kill

blade.  There were no live birds observed entering

the scalder and the back-up kill performed a cut

to the neck of all birds not cut by the kill blade. It

is recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, Allen

harim Foods, LLC P935 Harbeson, DE. 19951

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

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 139

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA090805

4829G

29MAY2019 04C05 Poultry Good

Commercial

Practices

Open From:                  . 

Date:                   05/29/2019. 

Subject:                             Poultry Good

Commercial Practice/ MOI Meeting Date.  

05/29/22019 Meeting Time    : 8.00 am 

Establishment: P 935 – Allen Harim Foods, LLC 

Comments:        MOI.               To: 

.               CC: .   This

memorandum of interview serves as written

notification of occurrence of one Cadaver found

on USDA line 3 inspection stations 4 today May

29, 2019. At approximately 8.00am a FI’s on line

three station four informed me that she observed

a cadaver carcass on her stations and hanged it

for Veterinary disposition. I observed the cadavers

on the station with head intact and no cut on the

neck. The facial area was cherry red and swollen;

skin around the neck was purple in color while the

rest of the body of the carcass was bright red in

color. A supervisor was present at that

time, . 

notified him and showed him the cadaver birds.

He assured me to take proper measures to

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)

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

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 140

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA171206

1003G

03JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0952 hours while performing

ante-mortem and Good Commercial Practice

verification I observed a damaged cage on trailer

number 71, located in the cooling shed.  The

flooring to the cage had collapsed, birds were

piled on top of one another and the birds on the

bottom were dead. I observed one live bird in a

pile of DOAs covering the approximate 3-foot X

5-foot stainless steel table at the end of the DOA

belt for medium birds.  The pile of DOAs was deep

(approximately 2 feet) enough that the birds on

the top of the pile were touching the DOA belt

blocking DOAs from exiting the belt. 

 and 

 were notified of birds dying

other than by slaughter and being handled in a

way that could result in excitement, discomfort or

injury while being handled in connection with

slaughter. had trailer #71 moved from

the cooling shed to live receiving immediately and

the damaged cage was removed from service after

the affected live birds were placed into

production.  No verbal preventive measure was

provided in response to the live bird being

observed in the DOAs. 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.  was

notified that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. Respectfully,   

 Allen Harim Foods, LLC. P-935 

Harbeson, DE. 19951

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

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

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 141

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA571406

4403G

03JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1504 hours while performing

ante-mortem and Good Commercial Practice

verification I observed the dumper operator move

the cage, that had just dumped, back from the

dumper.  One live bird remained in the area

where the cage had been.  The dumper operator

then walked over to the bird and kicked it, in an

attempt to move the bird onto the conveyor belt

approximately 2 feet below.  The bird remained in

place and the dumper operator kicked the bird a

second time onto the conveyor belt below. 

 was notified of the bird

being handled in a way that could result in

excitement, discomfort or injury in connection

with slaughter.  replaced the dumper

operator with another employee. 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.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, Allen

Harim Foods LLC. P-935 Harbeson, DE. 19951

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 142

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA271606

4305G

05JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1355 hours, I was notified that

the inspector on line 3, station 2 had hung back 1

bird for Veterinarian disposition.  Upon arrival I

observed the bird had head intact which were red

to purple in color and had not received a cut to

the neck.  

was notified of the observation of a bird dying

other than by slaughter.  At approximately 1407

hours I performed Good Commercial Practice

verification by observing 200 carcasses enter the

scalder, and 200 carcasses at the kill blade.  There

were no live birds observed entering the scalder

and the back-up kill performed a cut to the neck

of all birds not cut by the kill blade. 

stated that the responsible establishment

employee would receive disciplinary action. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, 

Allen Harim Foods, LLC. P-935 Harbeson, DE.

19951

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 143

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA050906

2818G

18JUN2019 04C05 Poultry Good

Commercial

Practices

Open From:                  . 

Date:                   06/18/2019. 

Subject:                             Poultry Good

Commercial Practice/ MOI Meeting Date.  

06/18/22019 Meeting Time    : 8.15 am 

Establishment: P 935 – Allen Harim Foods, LLC 

Comments:        MOI.               To: 

.               CC: .   This

memorandum of interview serves as written

notification of occurrence of one Cadaver found

on USDA line 1 inspection stations 4 today June

18, 2019.   At approximately 8.00am a FI’s on

line one station four informed me that she

observed a cadaver carcass on her stations and

hanged it for Veterinary disposition. I observed

the cadavers on the station with head intact and

no cut on the neck. The facial area was cherry red

and swollen; skin around the neck was purple in

color while the rest of the body of the carcass was

bright red in color. 

 was   notified and showed him the

cadaver birds. He observed and  assured me to

take proper measures to 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)

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-419 08:17 Monday, July 29, 2019 144

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA271806

5420G

20JUN2019 04C05 Poultry Good

Commercial

Practices

Open At approximately 1712 hours, I was notified that

the inspector on line 3, station 2 had hung back 1

bird for Veterinarian disposition.  Upon arrival I

observed the bird had head intact which were red

to purple in color and had not received a cut to

the neck.  

was notified of the observation of a bird dying

other than by slaughter.  At approximately 1732

hours I performed Good Commercial Practice

verification by observing 200 carcasses enter the

scalder, and 200 carcasses at the kill blade.  There

were no live birds observed entering the scalder

and the back-up kill performed a cut to the neck

of all birds not cut by the kill blade. 

stated that the responsible establishment

employee would receive disciplinary action. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, Allen

Harim Foods, LLC. P-935 Harbeson, DE. 19951

80 P935 Allen Harim Foods, LLC. YXA281006

3022G

22JUN2019 04C05 Poultry Good

Commercial

Practices

Open Ante-mortem check performed on lot 1at about

5.00am. 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 and Killing was effective, no loose bird in

live hang, live haul and holding sheds.

(b) (6)

(b) (6)

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