CASE NUMBER PAGE

OF

ESTABLISHMENT NAME

15. NARRATIVE REPORT- See attached. (include the categories listed below in the indicated order. Note: the heading for each category should be entered on a separate

 line above the narrative section for each category ):

 Correlated with:

 Summary of Data Assessment prior to Visit:

 Systematic Approach Comments

 Summary of Reason(s) for Recommendation:

 Findings/Narrative Report

(b) (6) (b) (6) (b) (6) (b) (6) (b) (4) (b) (4) (b) (4) 05-17-GCP002 2 2

Squab Producers of California
Food Safety and 

Inspection 

Service

1400 

Independence 

Avenue, SW. 

Washington, 

D.C. 20250

From:

Date: 4/25/2017

Subject: Increased Incidence of Cadavers - Line 1, Plant 1 PM shift

Meeting Date: 4/24/2017

Meeting Time: 1:30 PM

Establishment: M6137+P6137 - Foster Farms

Reason Code:

Other Reason 

Code:

Comments:

This MOI is intended to document the Poultry Good Commercial Practices incident that 

occurred on Monday, April 24th, 2017.

On Monday, April 24th, 2017, between the hours of 0800 hours and 1300hours, all four line 

inspectors on Line 1, Plant 1 dayshift, recognized, retained and had recorded on their 

respective Tally sheets a significantly increased number of cadaver carcasses. The total 

number tallied in plant 1 for this shift was cadavers; the average daily number of cadavers 

has been per shift (for dates of 3/17/2017 - 4/21/2017) in plant 1 on the dayshift. In 

addition to the above observations, the CSI monitoring Good Commercial Practices observed 

a live bird enter the scald tank at 1306 hours and was described as breathing, lifting its neck 

and visibly blinking. At 1312, both myself and the CSI observed that same bird exit the 

pickers exhibiting the classic appearance of a cadaver with cherry red neck and head and 

overall erythematous appearance. There also did not appear to be a neck cut. Most of the 

cadavers observed by inspection personnel had a generalized red appearance whereas a few 

appeared to be red only in the neck and lower regions of the carcass suggestive of an 

incomplete bleed. 

I immediately addressed and showed these findings to who 

attempted to address the situation with the back-up slaughter personnel. I reminded 

 that poultry are to be handled in a manner that prevents needless injury and 

suffering and in a manner that is consistent with Good Commercial Practices. Compliance 

with these requirements helps ensure that poultry are treated humanely and increases the 

likelihood of producing unadulterated product.

I recommended that the establishment review Federal Register Notice Vol. 70, No. 187, 

published September 2005 [Docket No. ϬκʹϬϯϳN] for FSIS recommendations concerning 

treatment of live poultry before slaughter. Furthermore, 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, 

, Est. P-6137, Foster Farms

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

(4)

(b) 

(4)
1 

MOI for Poultry GCP: 

Est. P6137A, Foster Farms Cherry Plant, April 18, 2017, 0215 hours: 

I was called at 2230 hours and again at 2335 hours the night of 4/17/17 to make dispositions on 

suspected carcasses at stations #1 and #3, Line B, and Line A, station #3 to observe hang 

back carcasses. I found bruises of varying degrees, mostly on the left side of the carcasses. I 

immediately notified and . 

And I went out to the Live Hang area with and found one DOA that was badly 

bruised on the left side with a broken wing. I immediately instructed all USDA online inspectors 

to hang back such carcasses. 

Again I was called at 0200 hours the morning of 4/18/17 to make dispositions on 

hang back carcasses. I observed blood clots when I peeled back the skin where they were badly 

bruised, mostly in the breast and left wing areas. Also, I observed broken articulation of the 

scapula in most of these carcasses. Some had broken left legs, and very few had bruises on the 

right side. It is worth noting that all the bruises did not look recent. was present 

when I carried out the inspection and I notified him of the forthcoming MOI. In addition, I 

notified plant management by email of the MOI for this event. 

Respectfully, 

Night Shift IIC, Foster Farms, Cherry Plant P6137A. 

(b) (4) (b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Food Safety and 

Inspection 

Service

1400 

Independence 

Avenue, SW. 

Washington, 

D.C. 20250

From:

Date: 5/9/2017

Subject: Live sensible Turkey entering scald tank

Meeting Date: 5/9/2017

Meeting Time: 1:00 AM

Establishment: M27389+P27389+V27389 - Pitman Farms

Reason Code:

Other Reason 

Code:

Comments:

On May 7, 2017 at approximately 22:11 hours Performing 

Good Commercial Practice (GCP) task in the live hang area observed the 

following; observed while plant employee located before the 

scald tank removed a sensible turkey from a shackle and placed it inside the 

blood tank. I then informed ) of my 

observation. informed me that he will have an employee 

assisting the employee removing live sensible birds from the shackles before 

entering the scald tank. While I stood back and observed the employee 

removing turkeys from the line and handing the turkey to the other employee 

assisting. The assisting employee walked away and another turkey was 

already being removed from the line by the attendant located before the 

scald tank while he is holding the turkey waiting for the assisting person to 

return another live sensible turkey had gone past the attendant as the 

attendant still has a turkey in his hands. I immediately informed employees 

located at the bleeding station to stop the line. By this time the sensible bird 

had already entered the scald tank. I informed what I had 

witness and notified that I would be documenting an MOI. And 

asked what corrective action would be taken to prevent live 

sensible birds from entering the scald tank. Since the adding an assistant was 

not sufficient to prevent live sensible Turkeys from entering the scald tank I 

then informed that before the line could be released back to 

production an effective corrective action needed to be present that would 

prevent live sensible birds from entering the scald tank. 

informed me that the line speed would be reduced in order to give sufficient 

time for the turkeys to bleed out. At approximately 22:16 hours live hang line 

was released to

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 1

EstNbr EstName Task_Code MOI# Date Description

M1886

6

Jennie-O Turkey

Store Sales, LLC

. WJL33120

44705G

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

Store        , p551, Jennie-O Turkey

Store             This Memorandum of Interview will discuss the

finding of multiple cadavers at establishment p551, Jennie-O

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

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

above average and there are some shifts with numerous,

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

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

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

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

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

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

            The noticeable increase in cadavers has been discussed

many times with plant management, both in weekly meetings

and in individual meetings with establishment supervisors. 

            Cadavers were discussed in the following weekly

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

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

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

offered by the establishment management and observations

and potential causes proffered by FSIS. As taken from the

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

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

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

needs to be accurate to ensure complete bleed out. The

establishment adjusted the auto-knife up which resolved the

issue.”                         , Weekly Meeting MOI

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

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

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

across the beak, some toms were cut too shallow.  

discussed this with and .  Some of the

miscuts occurred when the backup killer employee was the

regular person and when it was another employee.  Some of

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

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

inadequate depth.”                         , Weekly

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

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

cut.  has discussed this with the various 

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 2

EstNbr EstName Task_Code MOI# Date Description

including , and . 

This has also been discussed in previous weekly meetings.  The

various causes as told to me by the supervisors include the

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

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

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

killer blade was not the usual back up person.  

mentioned that there was a supervisor change in hang and kill

around the beginning of March.  The supervisor who was in

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

            stressed this needs to be corrected

also said he would be discussing this with next

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

MOI dated 4/5/17             Discussions have occurred with

individual supervisors as well, including 

, and .  Various causes as offered by

establishment management include: the automatic killer blade

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

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

there but rather someone with less experience.  There were 7

cadavers on 4/4/17.  Discussions occurred with 

 and on 4/4/17.  

indicated that he learned today there are additional

adjustments to the automatic killer blade that he was not

previously aware of.  He as been adjusting the automatic killer

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

also be adjusted horizontally (make the cut deeper or

shallower).  told me today that 

and until about one month ago, will

review the set up of the automatic killer tomorrow morning. 

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

instead of the usual one person.  and 

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

 informed that he had met with 

, on the morning of

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

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

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

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

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

only partially cut.

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

(b) (6)

(b) (6)

(b) (6)

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

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 3

EstNbr EstName Task_Code MOI# Date Description

M3213

0

Dakota

Provisions LLC

. JEB270905

2011G

2017-05-11 Est. 32130, Dakota Provisions, 05/11/17, 0835 hours.  Meeting

Attendance:  and 

 On 05/11/17 at 0810 hours, while

performing ante-mortem inspection, and I

observed a turkey with his wing caught between the framework

and the fiberglass floor above him.  The bird was discovered in

trailer #10, front cage, bottom tier under the trailer shed

outside.  The cages are designed with 3 compartments/levels

per coop and the floors are comprised of green fiberglass

material held to the cage framework with rivets.  I immediately

notified , and 

of my observations and concern of the

welfare of the bird.  tried to free the wing from the

floor above but the weight of the birds above made it

impossible to free the wing without harm.  The establishment

then brought out a bar to leverage between the floor and

framework which took pressure off the wing and allowed the

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

the wing was broken or dislocated from the entrapment.  I

placed US Reject Tag No. B42252120 on the cage so it could be

evaluated later today. A discussion was held with 

 of my observations and concern for

animal welfare at 0835 hours.  The establishment must

employ humane methods of handling and slaughtering

consistent with Good Commercial Practices in a way that

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

manner that prevents needless injury and suffering.  Employing

humane methods of handling and slaughtering that are

consistent with good commercial practices increase the

likelihood of producing unadulterated product.

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

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 4

EstNbr EstName Task_Code MOI# Date Description

M3213

0

Dakota

Provisions LLC

. JEB230705

5916G

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

Attendance:  and 

 On 05/16/17 at 0647 hours, while

performing ante-mortem inspection, I observed a turkey with

his right wing caught between the framework and the fiberglass

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

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

designed with 3 compartments/levels per coop and the floors

are comprised of green fiberglass material held to the cage

framework with rivets.  I immediately notified 

 of my observations and concern of the

welfare of the bird.  was also

notified.  used a bar to leverage between the floor and

framework which took pressure off the wing and allowed the

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

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

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

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

inadequately riveted in place which allowed the wing to become

trapped.  This was previously discussed and documented in MOI

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

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

was held with of my

observations and concern for animal welfare at 0710 hours.  

The establishment must employ humane methods of handling

and slaughtering consistent with Good Commercial Practices in

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

handled in a manner that prevents needless injury and

suffering.  Employing humane methods of handling and

slaughtering that are consistent with good commercial practices

increase the likelihood of producing unadulterated product.

(b) (6)

(b) (6) (b) (6)(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 5

EstNbr EstName Task_Code MOI# Date Description

M3213

0

Dakota

Provisions LLC

. JEB510905

2418G

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

Attendance: 

 and On 05/18/17 at

approximately 0500 hours, while performing ante-mortem

inspection, I observed 

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

between the framework and the fiberglass floor above him.  The

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

the trailer shed outside.  The cages are designed with 3

compartments/levels per coop and the floors are comprised of

green fiberglass material held to the cage framework with

rivets.  used a bar to leverage between the floor and

framework which took pressure off the wing and allowed the

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

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

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

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

the establishment had to free another bird with his wing

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

laceration and was bleeding, but the wing did not appear

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

follow up with the cage repair.  The fiberglass floors are

inadequately riveted in place which allowed the wings to

become trapped.  This was previously discussed in two other

instances which were documented in MOI JEB0206055711I

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

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

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

, of my observations and concern for animal

welfare at approximately 0530 hours.  instructed Quality

Control personnel in the live hang department to look at all

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

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

must employ humane methods of handling and slaughtering

consistent with Good Commercial Practices in a way that

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

manner that prevents needless injury and suffering.  Employing

humane methods of handling and slaughtering that are

consistent with good commercial practices increase the

likelihood of producing unadulterated product.

(b) (6)

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

(b) (6)

(b) 

(6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 7

EstNbr EstName Task_Code MOI# Date Description

picking room space, one cadaver carcass with a head attached

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

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

covering both production lines.  Birds appeared unresponsive

between the stunner and back-up stunner system.  The

machine/manual cutter appeared to be performing on a

majority of carcasses through the line.  One bird missed the

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

Good Commercial Practices (GCP) verification performed at

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

stunner to rehang table.   GCP of the slaughter process right

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

verified.         While walking back to the evisceration

department space, a second condemned barrel was observed

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

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

carcasses with the head attached with the aforemented dark

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

One carcass was observed to be headless.  The multiple

locations of these cadaver carcass findings along the slaughter

process demonstrate loss of process control. No corrections

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

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

documentation was cited for the est. personnel involved. USDA

personnel discussed with establishment management (Mr.

Marty Moser, Mr. Marv Mueller) when sporadic uncut cadaver

events occurred during slaughter production the 20th and 22nd

of June 2017.  Cadavers observed during production were

discussed during the 13th of June 2017 (MOI

CNC3110062314G), 11th of April 2017 (MOI

CNC0816044212G), and 14th of March 2017 (MOI

CNC1818033414G) weekly meeting.
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 8

EstNbr EstName Task_Code MOI# Date Description

M56 PILGRIMS PRIDE

CORPORATION

. MBJ09090

51224G

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

hang performing Good Commercial Practices. I noticed there to

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

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

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

and, wedged between 2 DOAs and a wall of chicken

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

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

way of falling DOAs when 

appeared. I informed him of my findings and

brought his attention to the live bird. said he would

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

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

I informed management of my findings. I explained that warmer

temperatures meant that DOAs would be presenting more

frequently and that the establishment was responsible for

making the necessary provisions to keep up with the increase.

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

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

Good Commercial Practices. Measures should always be taken

to ensure that poultry are handled and kept in conditions that

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

“employing humane methods of handling and slaughtering that

are consistent with good commercial practices increases the

likelihood of producing unadulterated product”. Establishment

P56 is hereby advised to address the above observations and

take preventative measures to reduce the likelihood of

occurrence. Cc’d 

(b) (6)

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 9

EstNbr EstName Task_Code MOI# Date Description

M56 PILGRIMS PRIDE

CORPORATION

. MBJ10090

63002G

2017-06-02 On 5/31/2017 

) conducted a Good Commercial Practice

Correlation Visit at Est. P-56. At approximately 12:54 PM she

and , were in the pinning

room observing the birds prior to entering the scalder. 

 saw a live conscious bird about to go into the

scalder. She informed who was able to remove the

bird from the shackle before the bird could enter the scalder. 

My above findings are noncompliant with 9 CFR 381.65(b):

"Poultry must be slaughtered in accordance with good

commercial practices in a manner that will result in thorough

bleeding of the carcasses and ensure that breathing has stopped

prior to scalding. Any deviation from Good Commercial

Practices is unacceptable. Since this is an isolated incident, it

will not be registered as a noncompliance record because the

establishment’s process appears to be in control, and no further

birds were observed entering the scalder.This MOI serves as a

written notice that future deviations may result in the taking of

additional administrative actions. Please submit documentation

of corrective and preventive measures to prevent a recurrence. 

 at Est. P-56 cc: 

Raleigh District ,

Raleigh District Dr. Roger Murphy, DDM, Raleigh District 

 Harrisonburg Circuit 

 Est. P-56

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

(b) (6) (b

) 

(6)

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

(b) (6)

(b) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 10

EstNbr EstName Task_Code MOI# Date Description

M5842 Tyson Foods,

Inc.

. NPF41060

42603G

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

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

Commercial Practices on the 3rd of April, 2017. 

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

breaks on the evisceration lines at approximately 0600

hours,  and 

 observed in the area between the backup venter station

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

yellow condemned barrel having no apparent  cut and the head

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

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

normal slaughter process.  This was shown to 

 at the time of the observation by 

.   The carcass was taken by to show to the

responsible parties to insure no further issues would arise and

then condemned by . 

informed   of the issues and informed him that IPP

would be documenting an MOI.  performed follow

up observations of the killing process and no further issues were

observed and it was assumed by that it was an

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

issue was conveyed to at

approximately 0700 hours on the 3rd of April 2017.  

 Est. 5842P Springdale, AR

(b) (6)

(b) 

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

(6)

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

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 11

EstNbr EstName Task_Code MOI# Date Description

M5842 Tyson Foods,

Inc.

. NPF38000

40208G

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

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

approximately 1605 hours, I observed one of the carcasses

presented for inspection at Post Morten inspection station

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

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

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

means than the normal slaughter process. Also at the same

station three DOA carcasses were presented to me for

inspection, the carcasses were purplish in color the viscera

appeared congested. The carcasses and viscera were exhibit

signs of decomposition (visceral organs, carcass discoloration

and condition odor).  These carcasses were removed from the

evisceration line 2. Another DOA carcass was presented for

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

 All the carcasses were shown to

 and

  After discussing this observation with

management. I and elected to

observed production at rehang area, 5 more DOA carcasses

were observed in the condemned barrels. These carcasses were

also shown to management. was present

went I informed 

that all the DOA carcasses should be condemned at

ante-mortem inspection and not brought into the slaughter

process. He was also informed of my intentions of documenting

an MOI . At 1700 hours, I performed follow up

observations of the killing process and no further issues were

observed.  

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 12

EstNbr EstName Task_Code MOI# Date Description

M751 Norbest, LLC

(Moroni)

. MMK0409

040306G

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

attendance:

 and

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

, while performing the good commercial

practices task, observed the following incident. I observed 5

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

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

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

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

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

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

not observe anyone monitoring the area so that this would not

occur. I told and that the PPIA and Agency

regulations reguire poultry be handled in a manner that is

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

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

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

issues and possible repercussions if there is continued

recurrence of this. I recommended management review the

Federal Register on Treatment of Live Poultry Before Slaughter,

published September 2005, for FSIS recommendations

concerning treatment of live poultry before slaughter. I provided

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

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

Reeder) and the and ) in case

additional follow-up is recommended. stated that he

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

be instructed to observe and prevent escaped turkeys from

being run over by the transport vehicle. Respectfully 

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

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 13

EstNbr EstName Task_Code MOI# Date Description

M7559 David Elliot

Poultry Farm

Inc.

. SNA08070

61615G

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

management; Mr. Moshe Fink, Mr. Yehudah Fink, 

 and The purpose of this meeting was

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

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

There were approximately 1,337 DOA carcasses out of the

 broiler chickens intended for slaughter on this day.

During the meeting management discussed the factors they

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

but not limited to- the high temperature and humidity

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

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

intends to take additional planned corrective measures,

including proactively coordinating with the hauler that

transports the birds when warmer outside temperatures are

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

each crate and thereby increasing air flow/cooling.

Management also discussed the possibility of changing the

location of the trucks after they arrive at the establishment from

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

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

reminded management of their responsibility to ensure that live

poultry are handled in a manner consistent with good

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

causes other than slaughter per Agency regulations and the

Poultry Products Inspection Action (PPIA). Management was

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

previously discussed, lack of adherence to GCPs could

potentially result in a noncompliance record (NR). Management

was notified that this MOI will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case any additional follow-up is recommended.

(b

) 

(6)

(b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 14

EstNbr EstName Task_Code MOI# Date Description

M9977 Tyson Foods Inc. . YBL131604

4501G

2017-04-01 On 3/30/17 at approximately 1351 hours, while conducting a

routine Poultry Good Commercial Practice Task in live receiving,

the following was observed.  I was standing on the dumper

stand next to the dumper-operator while he was actively

operating the dumper.  When the dumper-operator

mechanically removed a cage away from the dumper to be

taken away to the transportation trucks, I observed that one

half of the cage doors (the entire left half of the cage doors

when observing the cage with the cage doors facing the

observer) had not opened at all and that this half of the cage

was still full of live chickens.  The dumper-operator mechanically

opened the doors.  He then mechanically moved the cage with

the doors still open against the dumper, which did not align

properly against the dumper.  Immediately, the

dumper-operator mechanically moved the cage away from the

dumper again with the cage doors still open.  I observed several

live chickens standing at the edge of cage at the location of the

hinge where the cage edge and door edge connect, as well as on

the inside aspect of the cage doors.  At this point, the

dumper-operator closed the doors on the live chickens, resulting

in several body parts of live chickens being stuck between the

edge of the cage doors and the cage itself.  I observed

approximately two live chickens with their necks stuck between

a door edge and the cage, approximately one live chicken with

its neck and its wing stuck between a door edge and the cage,

and approximately one live chicken with its wing stuck between

a door edge and the cage.  

and were immediately notified of the

situation.  assumed control of operations,

mechanically opened the cage doors, manually released the

stuck chickens back into their cages, and dumped the cage onto

the conveyer belt.  I informed him that the District Office would

be made aware of the situation informed me that the

dumper-operator should have gently pushed the live chickens

completely back into the cage before closing the doors.  He also

informed me that the dumper-operator had been taken to

Human Resources.  Live bird body parts getting stuck in

equipment from operator error is not consistent with good

commercial practices.  Under the Poultry Products Inspection

Act (PPIA) and Agency requirements, live poultry must be

handled in a manner that is consistent with good commercial

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 16

EstNbr EstName Task_Code MOI# Date Description

M9977 Tyson Foods Inc. . YBL061605

2826G

2017-05-26 On 5/26/17 at approximately 1441 hours while performing a

routine Good Commercial Practices Verification task, I was

watching establishment employees shackling live poultry in the

live hang area when I observed an establishment employee

retrieve a live, loose chicken located in a metal offal bin

positioned to the left of the end of the conveyer belt, outside of

the fenced in area.  I informed 

of my observation. Instances of live, loose chickens in the live

hang area have been previously observed, discussed, and

documented in Memorandum of Interviews (MOIs) from routine

weekly meetings with establishment management: From MOI

YBL0920055317G On 5/10/17 at approximately 1339 hours

while conducting antemortem/GCP in the live hang area two

live chickens fell from the conveyer belt onto the floor within

one minute of each other.  I informed 

that process control needed to be maintained at all

times. On 5/12/17 at approximately 1351 hours in the live

hang area I noticed two instances of live birds at the end of the

conveyer belt, where the hanger controls the belt speed with a

knee pedal, jump over the metal barrier and into the offal bin. 

 and 

 were informed. From MOI YBL2716054324G 

On 5/18/17 at approximately 1342 hours while performing

antemortem and good commercial practices in the live hang

area I noticed one live bird jump from the moving conveyer belt

at the left most end in front of the conveyer belt operator/live

hanger over the left metal barrier and land under the Dead

Upon Arrival (DOA) table (where moribund birds and DOAs are

placed before being humanely euthanized and placed in the

DOA bin) OUTSIDE of the fenced in area.  No management was

present and the hanger buzzed.  When arrived I

informed him of the situation.  Less than one minute later one

live bird landed from the conveyer onto the floor within the

fenced in area and was promptly retrieved.  notified

afterward.  Loose live birds also noted within live hang area on

5/10/17 and 5/12/17. On 5/19/17 at approximately 1340

hours while performing a routine antemortem/GCP task in live

hang I noticed one live bird jump from the conveyer belt onto

the floor within the fenced in area and was promptly retrieved. 

 notified.  Loose live birds also noted in live hang area on

5/18/17, 5/12/17, and 5/10/17. To be documented in the next

(b) (6)

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

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 17

EstNbr EstName Task_Code MOI# Date Description

weekly meeting with establishment management MOI: On

5/25/17 at approximately 1424 hours in live hang area during

antemortem/good commercial practice inspection I observed

 pick up a live, loose bird outside of the fenced in area to

the left of the left-most hanger.  Loose live birds also noted in

live hang area on 5/19/17, 5/18/17, 5/12/17, and 5/10/17. 

 notified. Repeatedly allowing live chickens to fall

and/or jump from the waist-level conveyer belt onto the floor

and floor-level areas in the live hang area can result in injury to

live chickens and is not consistent with good commercial

practices.  Previous corrective actions were either not

implemented or ineffective at preventing recurrence.  Under the

Poultry Products Inspection Act (PPIA) and Agency

requirements, live poultry must be handled in a manner that is

consistent with good commercial practices, which means they

should be treated humanely.  Respectfully, 

P1009 Wayne Farms

LLC

. DSM57210

44603G

2017-04-03 At approximately 1500 hours while assisting 

 with an annual GCP audit, a cadaver was noted exiting

the last picking machine.  The head was intact, engorged and

red/purple in color, edematous, and no neck cut was present.  I

followed the carcass into the evisceration department.  The

head was removed by the head puller after the rehang table.  I

followed the carcass to inspection station 2 to ensure it was

condemned.  The inspector at station 2 condemned the carcass

and instructed the trimmer to document it on the

condemnation lot sheet as a cadaver at approximately 1508

hours.  At approximately 1545 hours, informed plant

management that an MOI would be issued.  9 CFR 381.65(b)

states that "Poultry must be slaughtered in accordance with

good commercial practices in a manner that will result in

thorough bleeding of the carcasses and ensure that breathing

has stopped prior to scalding.

(b) (6)

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 18

EstNbr EstName Task_Code MOI# Date Description

P1201 Pilgrims Pride

Corporation

. JAB011106

1310G

2017-06-10 At 1144 hours, while performing a GCP task on Saturday, I 

 observed the plant employee

make an attempt to retrieve a live bird from a cage rack. The

employee was standing at the DOA observation station when I

noticed him go with urgency to automatic loading area for the

cage wash. He was unable to stop the cage from entering

washer or retrieve the live bird. The live bird was retrieved from

the cage after passing through the washer (water temperature

unknown) and placed on the CO2 conveyer chamber for

slaughter. I discussed this occurrence with 

 and assured me the

incident will be addressed. On Monday (6/12/2017) at 0605

hours, informed me of documentation the

employee was retrained and how to proceed if a bird is

observed in cage rack entering the washer. A copy of this MOI

and your response will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended.

(b

) 

(6)

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 19

EstNbr EstName Task_Code MOI# Date Description

P1235 Wayne Farms

LLC

. GKN16120

41507G

2017-04-07 On April 7, 2017, at 0843, I, 

observed less than Good Commercial Practices. While

performing a routine Ante-Mortem Inspection and Good

Commercial Practice check (GCP), I observed one live bird whose

throat had not been cut about to enter scalder number one. The

bird had open, blinking eyes and was lifting its head in an

attempt to right itself. I was standing at the west (entrance) end

of scalder number one where the establishment has installed a

stop button for occurrences such as this. Therefore, I

immediately stopped the picking line, per establishment’s

written permission, to prevent the bird from entering the scald

vat and 

 arrived quickly and 

removed the bird from the line prior to restarting the picking

line. I immediately performed an additional 1,000 bird check

and did not observe any improperly slaughtered carcasses. I

then proceeded to the kill room to verify the function of the

stunner and kill machine. During my observation period all

except 3 small birds were stunned and killed. The 3 small birds

were then missed by the kill blade but were properly cut by the

back up killer. The aforementioned bird had passed all plant

intervention steps and the entrance into the scalder was

imminent when the line stopped. Hence, it is reasonable to

conclude that without intervention and the utilization of the

emergency stop button, the bird would have entered the scalder

alive. After removal of the live bird and examination of the kill

process, the establishment determined that due to bird size

variations the stunner needed to be raised. After adjusting

equipment, verification checks performed by QA humane

handling technician indicated that additional adjustments were

needed. These adjustments were made and verification checks

were found to be acceptable. At approximately 0900, I notified

Plant Manager Heath Loyd that GCP MOI documentation would

be forthcoming.  A copy of this Memorandum of Interview will

be forwarded to appropriate personnel in the Jackson District

Office. Respectfully, Cc:

Dr. David Thompson, DDM, Jackson

DO                                                                                                        

                          

(b) (6)

(b) (6)

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 20

EstNbr EstName Task_Code MOI# Date Description

P1250 Fieldale Farms

Corporation

. OAA34090

42511G

2017-04-11 124 birds were accidently suffocated on the hanging belt in the

live hang room at P-1250 on the morning of April 10 between

0700 and 0800 hrs. due to a malfunction of the hanging belt

causing the cogs to run but the belt to slip.  Consequently birds

from the dumping belt dropped on top of the birds on the

hanging belt below and suffocated the birds on the hanging

belt.   I observed many of the dead birds while performing

the Good Commercial Practices task.  I met with 

 and 

 later the same morning at approximately 0945

hrs. They gave me the above explanation, also adding that the

dumping belt automatically continues to operate as long as the

cogs on the hanging belt are turning and cannot recognize when

the hanging belt is slipping, i.e. the dumping belt keeps

running.  They said that when the malfunction was recognized

by establishment personnel, no new cages of birds were

dumped on the dumping belt. They didn’t see how the incident

could have been avoided and said that it doesn't happen very

often.

P1272 Pilgrim's Pride

Corporation

. CCA220704

5425G

2017-04-25 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Monday, April 24,

2017 at approximately 0605 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the pre-evisceration area. I observed one live bird

enter the scald vat on line number two alive. The bird was

observed alive and blinking its eyes prior to entry into the scald

vat. I immediately notified . We

both observed the cadaver upon exit from scald vat number 2

and scald vat number 3. stated he would replace the

current backup killer on line two with another backup killer. No

other live birds were observed entering the scald vat alive. This

issue will be discussed with management at the next USDA

weekly meeting on April 25, 2017. There was no immediate

response given by establishment management. Respectfully, 

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

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 21

EstNbr EstName Task_Code MOI# Date Description

P1272 Pilgrim's Pride

Corporation

. CCA340306

0014G

2017-06-14 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Friday, June 9, 2017

at approximately 0834 hours while performing a Good

Commercial Practices Task at P-1272 I, 

observed an issue with the implementation of Good Commercial

Practices in the evisceration area. I observed and pulled from

the line one cadaver bird during inspection on line number one

at station number three. The cadaver was observed with an

engorged head intact with the neck to which there was no cut

visible. I immediately notified 

 and . I held the cadaver at the PHV hold

rack at the station to show both supervisors. stated

he would place a second person to assist the current backup

killer on line one. During verification of this corrective action, it

was later observed that instead switched backup

killers instead of placing two people at this position. No other

live birds were observed entering the scald vat alive. This issue

will be discussed with management at the next USDA weekly

meeting on June 15, 2017. There was no immediate response

given by establishment management. Respectfully, 

(b) (6)

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 22

EstNbr EstName Task_Code MOI# Date Description

P1272 Pilgrim's Pride

Corporation

. CCA420606

3216G

2017-06-16 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Wednesday, June 14,

2017 at approximately 0840 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the evisceration area. I observed and pulled from

the processing line one cadaver bird on line number two at the

rehang table. The cadaver was observed with an engorged head

intact with the neck to which there was no cut visible. I

immediately notified ,

who observed the bird shortly after the occurrence. Plant

Manager, Mark Dean was notified and observed the bird shortly

thereafter. At approximately 0842 hours while still performing

a Good Commercial Practices Task in the pre-evisceration area, I

again observed a live bird enter the first scald vat on line

number two. I immediately notified 

. The bird was removed from the line after

exiting scald vat number two. We both observed an engorged

head and that there was no cut to the neck of the bird. 

and were also notified shortly thereafter. 

For both instances, stated that two employees will

be placed at the position of backup killer on line two for the

remainder of the shift. No other live birds were observed

entering the scald vat alive. This issue will be discussed with

management at the next USDA weekly meeting on June 15,

2017. There was no immediate response given by establishment

management. Respectfully, 

(b) (6)

(b) (6) (b) 

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 23

EstNbr EstName Task_Code MOI# Date Description

P1272 Pilgrim's Pride

Corporation

. CCA220606

4320G

2017-06-20 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Friday, June 16, 2017

at approximately 1105 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the pre-evisceration area. I observed one live bird

enter the scald vat on line number two alive. The bird was

observed alive and blinking its eyes prior to entry into the scald

vat. I immediately notified 

 We both observed the cadaver upon exit from scald vat

number two. removed the bird at this point before

entering scald vat number three. The cadaver was observed with

an engorged head intact with the neck to which there was no

cut visible. First shift plant manager, Demaricus Green was

notified and shown the cadaver shortly thereafter. Mr. Green

stated he would replace the current backup killer on line two to

allow for further re-training of the employee and if placed back

in the position of backup killer there would always be a second

person with him. No other live birds were observed entering the

scald vat alive. This is the fourth bird in one week to be

observed entering a scald vat alive at this establishment. Those

corrective actions which have been stated and used  thus far

may not be sufficient to prevent reoccurrences of this nature.

This issue will be discussed with management at the next USDA

weekly meeting on June 20, 2017. There was no immediate

response given by establishment management. Respectfully, 

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 24

EstNbr EstName Task_Code MOI# Date Description

P1272 Pilgrim's Pride

Corporation

. CCA420606

4620G

2017-06-20 Mark Dean, Plant Manager Pilgrim's Pride Corporation P-1272 

113 McNeal Drive Douglas, GA 31533 On Monday, June 19,

2017 at approximately 1042 hours while performing a Good

Commercial Practices Task at P-1272 I, ,

observed an issue with the implementation of Good Commercial

Practices in the pre-evisceration area. I observed one live bird

enter the scald vat on line number two alive. The bird was

observed alive and blinking its eyes prior to entry into the scald

vat. I immediately notified 

and . We all observed

the cadaver upon exit from scald vat number two. 

removed the bird at this point before entering scald vat number

three. The cadaver was observed with an engorged head intact

with the neck to which there was no cut visible. 

stated he would add another backup killer on line two for the

remainder of the shift. No other live birds were observed

entering the scald vat alive. This is the fifth bird in

approximately one week to be observed entering a scald vat

alive at this establishment. Those corrective actions which have

been stated and used thus far may not be sufficient to prevent

reoccurrences of this nature. This issue will be discussed with

management at the next USDA weekly meeting on June 20,

2017. There was no immediate response given by establishment

management. Respectfully, 

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

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 25

EstNbr EstName Task_Code MOI# Date Description

P1309 House of

Raeford Farms

Inc.

. JLA152305

4612G

2017-05-12 At approximately 1135 hours, during the performance of a Good

Commercial Practices task, I inspected the cages on truck

#2837, which had been pulled from the truck sheds and was

being prepared for unloading.  I noted that one cage had three

birds that appeared to be sitting on top of one another.  Upon

closer inspection, I observed that the top two floors of the cage

were broken in one corner.  This damage allowed a bird in the

top section to fall through on top of two birds in the second

section.  These two birds had fallen partially through the floor of

their section and were stuck between the second and third

sections of the cage.  One of these birds had a small amount of

blood and an abrasion on the tail.  I immediately notified 

 of the damaged cage.  I

requested that the affected cage be removed from the truck,

and the birds in the affected sections were removed by hand to

prevent any further injury.  The birds were then placed on the

live hang conveyor belt for slaughter.  The remaining birds in the

cage were run through the cage dump, and tagged the

cage for repair.  Third Shift Manager Joe Bunch also observed

the damaged cage and indicated he would have the problem

addressed.  As I observed the unloading of other cages from

truck #2837, I noted that some were missing one or more of

their metal loading doors.  The establishment most recently

was notified of an issue with cage conditions by 

 via MOI #JLA3712031830G issued on

03/30/2017.  This MOI noted a number of cage issues, including

broken cage bottoms, missing cage doors, and damaged metal

parts and framing, during the week of March 27, 2017.  A

number of cages still appear to be in poor condition with the

same issues noted above.  The establishment has the

responsibility to ensure the safe handling of all birds on its

premises, which includes ensuring acceptable cage conditions,

since significant cage damage may lead to injury or death of the

birds.

(b) (6)

(b) (6) (b

) 

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 26

EstNbr EstName Task_Code MOI# Date Description

P1317 Wayne Farms

LLC

. QUI111004

3118G

2017-04-18 On Monday April 17, 2017 at approximately 0817 hour while

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed a weak bird on its back under the

dump cages in a puddle of water, with weak respirations,

soaking wet and unable to right itself.  In addition its right wing

was contorted in an abnormal angle in the mid humeral region

appearing fractured.  I immediately went to ask the dump cage

operator if he had a radio to call for a supervisor, he asked if it

was for the loose bird, I replied yes.  He told me that he did not

and that I needed to go around front to the office to find

someone.  I went towards the front of the building, at which

time I found a maintenance worker with a radio and asked him

to call for a supervisor to meet me at the dump cages as quickly

as possible.  At approximately 0819 a supervisor came to the

dump cages, got the bird and took it back into production.  At

0822 a meeting was held with supervisors explaining that it is

imperative that birds be handled/treated humanely prior to

slaughter and do not die by means other than slaughter.  This

bird was in imminent danger of dying by drowning.  At this time

I was told that the bird had fallen out of a hole in the bottom of

a cage to the area under the dump cages, which has a large

amount of water at all times.  The bird had not been retrieved in

a timely manner allowing it to become injured and at risk of

drowning.  Management was informed of the resulting MOI

from this incident. As per Federal Register Notice Docket No.

04-037N dated September 28, 2005, Treatment of Live Poultry

before Slaughter, the Food Safety Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines. My observations are consistent with less

than good commercial practices. A copy of this Memorandum

of Interview will be forwarded to appropriate personnel in the

District Office. Respectfully submitted on April 17, 2017. 

 Cc: DDM DVMS FLS

(b

) 

(6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 27

EstNbr EstName Task_Code MOI# Date Description

P1317 Wayne Farms

LLC

. QUI151104

0919G

2017-04-19 On Wednesday April 19, 2017 at approximately 0647 hour

while performing an Ante Mortem inspection and a Good

Commercial Practice Check, I observed a weak, moribund bird

on its back with shallow respirations on the ground in live hang

at the end of the live hang belt under a pile of four other dead

birds.  This bird was in imminent danger of becoming crushed

and dying by means other than slaughter.  There was not a

supervisor in the area, nor was one close by.  No one was

monitoring the birds at the end of the belt.  I asked one of the

live hang employees if anyone in the area had a radio to call a

supervisor and was told no; that in order to get a supervisor I

would have to go through the building and find the offices to

locate someone.  Due to the immediate risk of

death/suffocation to the weak bird and the length of time it

would take to get a supervisor, I first pulled the bird off to the

side out from under the pile of already dead birds in order to

prevent it from dying until I could locate a supervisor.  An

employee with a radio was found in the building.  I asked her to

please call a supervisor to meet me in live hang.  Approximately

5 minutes from finding the bird, 

arrived and I showed her the bird and told her that

it had been under the pile of the dead birds that were now

beside it.  She had gotten an employee to get the bird and put it

back on the belt and into production and also instructed the

employee to stay at the end of the belt to monitor the area. 

 informed me that the supervisors had been in a

meeting discussing the similar event that occurred yesterday

and previous GCP MOI issued earlier this week. Yesterday,

Tuesday April 18, 2017 at approximately 0827 while doing the

Ante Mortem and Good Commercial Practice Check for that day,

I observed a similar incident.  In the live hang room at the end of

the live hang belt on the ground there were a total of 8 birds, 7

of them were dead and one was live.  The live bird was

moribund and very weak.  I asked an employee to get a

supervisor and it took approximately 6 minutes for a supervisor

to arrive.  By the time the supervisor had gotten to the area the

bird had expired.  I asked for the supervisor to radio 

, to discuss the incident.  Good

Commercial Practices were discussed in depth at that time and

 assured me that the situation would be rectified, as

this had never been an issue at this establishment before and it

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 28

EstNbr EstName Task_Code MOI# Date Description

would be prevented from happening again in the future.  I

explained to him that this was very serious and the agency takes

treatment of birds prior to slaughter very serious as well as birds

dying by means other than slaughter.  I also informed him that I

would be doing additional GCP checks to verify that this did not

occur again.  Live birds should not comingle with the DOA birds

as this puts them at risk for suffocation / becoming crushed.  

Once the incident occurred today was informed that

an MOI would result from these issues. As per Federal Register

Notice Docket No. 04-037N dated September 28, 2005,

Treatment of Live Poultry before Slaughter, the Food Safety

Inspection Service (FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good Commercial Practices

(GCPs) as described by industry guidelines. My observations

are consistent with less than good commercial practices. A

copy of this Memorandum of Interview will be forwarded to

appropriate personnel in the District Office. Respectfully

submitted on April 19, 2017. Cc: Dr.

David Thompson, DDM 

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

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 29

EstNbr EstName Task_Code MOI# Date Description

P1362 Tyson Foods,

Inc.

. LPC160906

2809G

2017-06-09 On June 8, 2017, at approximately 09:20 hours, 

 and 

, met with .

The following is a synopsis of the events and discussion

regarding GCP related issues.  I  began that while verifying that

poultry was slaughtered in accordance with good commercial

practice, I observed approximately 25 carcasses on the floor

behind Line 1  live hang that were dead on arrival. I observed

live hangers discarding several carcasses from the Line 1 live

hang belt to the floor. I  continued my GCP verification. While

observing the poultry in the receiving shed, I observed several

modules on several trailers in which the green plastic liner on

the bottom layer of the module was displaced upwards limiting

the space in which the birds could move freely. Some of these

liners were displaced upwards in which there was only about 4

inches between the bottom of the next module and the liner of

the lower module. I also observed a module in which there was

a hole approximately 6-8 inches long and 4 inches tall in which

birds could easily fall out or escape. Lastly, I observed a cage

with a 4 inch piece of the module had been dislodged and was

bent inside the cage where it could easily impale the bird. At

approximately, 09:20 hours while returning from the receiving

shed, I located and and

informed them of his observations. I  inquired about the cause

of the large number of DOAs. informed me that

these were due to holdovers from nightshift. I inquired about

whether the establishment scheduled these holdovers to be

slaughtered first. informed me that they did. I

 inquired about if the holdovers should be finished by this point

and thought they were after consulting with 

 It should be noted that NR number

LPC1219064002N dated June 1st was issued due to DOA at the

inspection station. Furthermore, DOAs presenting at inspection

stations have been a developing trend discussed in the weekly

meeting. In addition, cages being in disrepair were also most

recently noted in the weekly meetings April 13th.  There was no

response by the establishment. MOI LPC1809025307G was

issued on February 7th for similar instances of cages in disrepair.

The meeting was adjourned at approximately 09:30 hours.

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

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

(b) 

(6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 30

EstNbr EstName Task_Code MOI# Date Description

P146 Tyson Foods,

Inc,

. EJJ531004

3926G

2017-04-26 P 146 Tyson Poultry On April 25, 2017 at approximately 0515

while performing ante-mortem and Good Commercial Practice I

observed while walking through the live hang area there were a

large number of dead chickens on the DOA belt. This seems to

be a constant finding when there are chickens left over from the

night shift that did not get slaughtered. In checking I found

there were chickens that were held over from the

previous night. While continuing to perform ante-mortem and

Good Commercial Practice on the live chickens on the trailers in

the shed, I observed the chickens in the cages to be very

depressed and cold looking. I could see there were some that

had also died. These were also part of the numbers that were

left from the previous night.I Inquired if there had been any

equipment failure or a mechanical issue that caused this

number of chickens not to be slaughtered and there was none.

This seems to be a continual issue of too many chickens

delivered to be slaughtered within the shift. The weather during

the night was rainy and there was a cold damp air. The shed is

open without any protection from the weather allowing these

chickens to endure the elements of the weather. The chickens

are held off feed prior to being caught and loaded into the cages

on the trailers and have not had any water after they were

loaded. Therefore these chickens had no food or water for

approximately 12 to 24 hours.I have observed prior that when

chickens are carried over from the previous day to bear the

elements of the weather whether it is very cold or very hot there

is an increase in the number of DOA’s during my ante-mortem

and GMP

checks.

                                                                                                             

                                                                 Therefore my observation

is that all this these chickens evidently died due by means other

than the normal slaughter process.This issue had been discussed

at the last weekly meeting and evidently no corrective measures

have been taken to correct the issue.

(b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 31

EstNbr EstName Task_Code MOI# Date Description

P165H OK

FoodsProcessing

Plant

. DAF29140

44417G

2017-04-17 At approximately 1225 on 4/17/17 while performing a good

commercial practice check in the back dock area, I observed the

following poor live bird handling techniques.  A live bird holding

cage was resting on the concrete with all the doors open and

approximately 300 live chickens huddled in the area.  It

appeared that the cage had fallen from a forklift and spilled the

birds out.  I observed the cage boomer correctly lifting birds,

one at a time and placing them into the cage.  As I monitored

the situation, I observed two live hang employees come to the

assistance of the boomer.  However, one of these employees

was scooping up multiple chickens (3) at a time, resulting in

birds being carried by a wing or leg.  These chickens were then

crammed into the cage using more force than necessary.  At this

point, I walked to the cage and asked the live hang employee to

stop catching birds.  Both live hang employees immediately

stopped catching birds and returned to the live hang room.  I

then began looking around the area for someone with a radio to

contact plant management.  I observed one of the live hang

leads watching from under the cage dumping area and asked

him to radio .  

 arrived a short time later.  I immediately informed him

of my observations.  I stayed in the area until all the live birds

were caught and returned to the cage using proper live bird

handling techniques commented that he would

discuss my observations with the back dock lead in an attempt

to determine who the live hang employee was.  Later, 

 reported that the live hang employee denied catching

birds by the wing or leg.  On the morning of 4/18/17, 

met with to further

discuss this incident.  asked what caused the cage to

fall from the live haul truck and what steps the establishment

was taking to prevent this from happening in the future.  

 later explained that the forklift driver had not raised the

top cage high enough prior to backing up the lift.  The top cage

caught on the lip of the cage below, pulling it off the forks of the

lift, causing it to fall to the concrete.  also commented

that the establishment plans to retrain the forklift driver to

prevent future incidents

(b) (6)(b) 

(6) (b) (6)

(b) 

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

(b) 

(6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 32

EstNbr EstName Task_Code MOI# Date Description

P165H OK

FoodsProcessing

Plant

. DAF13140

65203G

2017-06-03 6-3-17 OK Foods, Inc. PO Box 158 1000 Old Pike Road 

Heavener, OK 74937 At approximately 0659 on 6/3/17, while

observing cages being dumped as part of a good commercial

practice task, I observed a chicken resting between the incoming

track and the exit track of the cage dumper.  The employee

operating the cage dumper continued to dump chickens as the

bird squatted between the tracks.  Incoming cages passed the

chicken on one side and outgoing cages passed the chicken on

the other side.  The chicken became excited as the doors of an

exiting cage were closed and the chicken moved onto the track

in front of the cage.  The chicken was then pushed along in front

of the cage until the point that it became crushed between the

cage and the end stop plate at the exit end of the cage dumper

track.  I immediately notified 

 of my observation and discussed the incident at

approximately 0850 with 

.  Later in the shift I discussed the incident again

with .  She informed me that the employee operating

the cage dumper was unaware that a chicken was on the

equipment because he was unable to see it from his vantage

point.  I explained that the establishment may need to consider

placing a mirror on the cage dumper so the employee can

visualize this area.

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 33

EstNbr EstName Task_Code MOI# Date Description

P165S OK Foods, Inc. . LWA22190

64121G

2017-06-21 On 6/21/2017 at about 1645 hours I had gone out to the

hanging dock to complete a GCP task. I saw cages of birds on

the line ready to go to the dumper. There were two cages in the

hypobaric chamber and two cages sitting on the end of the line

sitting in the sun. At about 1715 hours I noticed that birds

were being dumped into the hopper ready to go into the live

hang area. Two cages of birds were dumped into the hopper and

another was ready to be dumped on top of those. The birds

were stacked two deep in the hopper causing them to stand on

top of each other. The misters were not on and the birds were

noticeably in distress. I called up to the top of

the stairs so that he could see what was happening. I told him

that the birds were stacked two deep in the hopper and there

were no misters on. He told me that he would get maintenance

to get a hose and fix the misters. The birds were in the hopper

five minutes before hanging started. When I went inside the

hanging room I saw that there were several DOAs being thrown

away from the birds that had been sitting in the hopper. I

counted about 30 DOAs. I told about what I had seen

before start up and informed him that the birds could not be

piled so high in the hopper. He said that he would take care of

the situation. I also told of my concerns about the

birds in the cages sitting on the line in the sun during break.

They do not have misters nor fans and the sun it shining directly

on the cages. He said that from now on he would make sure the

lines are clear when they go to break so that birds are not left in

the sun. 

P17340 Pilgrim's . UQB25030

52029G

2017-05-29 At approximately 2:45am, on 5-28-2017, while performing the

Poultry Good Commercial Practices task, I found one live bird in

the DOA dumpster on the "old side".  The bird was resting

between birds that had been sprayed with denaturant but did

not have denaturant on it. I notified 

 retrieved the bird.  I then informed

 the .The

establishment's program failed to segregate a live bird from the

dead birds.  Without USDA-FSIS intervention, the

establishment's plan would have failed to prevent a bird from

dying by means other than slaughter.

(b) (6)

(b) (6)

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 35

EstNbr EstName Task_Code MOI# Date Description

conveyor belt and onto the live hang conveyor belt are being

funneled into a narrow area (choke point) resulting in

congestion and heaping of birds on the belt to the extent that

birds on the incline line are dragging across the top of them.

Upon further observation and I also noted

that the feet of birds were being caught between the divider and

the live hang conveyor belt, and that one bird was entrapped in

the aforementioned equipment by its wing. 

subsequently freed the bird from its entrapment. 

, was verbally notified of

the aforementioned. Federal Register Notice Docket No.

#04-037N dated September 28, 2005, "Treatment of Live

Poultry Before Slaughter," encourages those involved in the

slaughter of poultry to abide by Good Commercial Practices.  A

copy of this MOI will be forwarded to the District Office and to

the District Veterinary Medical Specialist in case additional

follow-up is recommended.  Respectfully, 

P17766 Southern Hens,

Inc

. SSN341304

5311G

2017-04-11 Good Commercial Practices MOI: On April 11,

2017 @ approximately 0905 hours, I observed a less than good

commercial practice while performing Ante-mortem

inspection and a Good Commercial Practices check at

Establishment P-17766. While performing a 500 bird count, I

saw a live, non-stunned and uncut bird enter the scalder.  This

was the result of two birds having been hung together in one

shackle. The other bird in the shackle was dead from a proper

cut to the neck before entering the scalder.  

and 

 were immediately notified of this finding.  In

accordance with FSIS Docket No. 04-037N, Treatment of Live

Poultry before Slaughter, live poultry must be handled in a

manner that is consistent with good commercial practices. In

order for this to occur, poultry must be treated in a manner that

will minimize excitement, discomfort and accidental injury

throughout processing.  A copy of this Memorandum of

Interview will be sent to the Jackson District Office for further

review.  Thanks for your attention to this matter. Respectfully, 

(b) 

(6)

(b) (6)

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 36

EstNbr EstName Task_Code MOI# Date Description

P17766 Southern Hens,

Inc

. SSN081304

5524G

2017-04-24 Good Commercial Practices MOI: On April 24,

2017 @ approximately 0838 hours, I observed a less than good

commercial practice while performing Ante-mortem

inspection and a Good Commercial Practices check at

Establishment P-17766. While performing a 500 bird count, I

saw a live, non-stunned bird enter the scalder.  The bird was

flapping and attempting to right itself.  As it entered and

traveled half the length of the first scalder, the bird jerked

violently, while lifting itself until it was no longer in my

immediate sight.  

was immediately notified of this finding.  In accordance with

FSIS Docket No. 04-037N, Treatment of Live Poultry before

Slaughter, live poultry must be handled in a manner that is

consistent with good commercial practices. In order for this to

occur, poultry must be treated in a manner that will minimize

excitement, discomfort and accidental injury throughout

processing.  A copy of this Memorandum of Interview will be

sent to the Jackson District Office for further review.  Thanks for

your attention to this matter. Respectfully, 

P18414 MB Consultants

LTD

. JYI5211045

513G

2017-04-13 On 4/11/2017 I observed in the area before the plucker 24

broken wings out of 500 total birds that passed by. On

4/12/2017 when I asked for the animal welfare guidelines they

stated they didn’t have one.  I discussed with the plant that

broken wings are considered mistreatment and are more likely

to result in the birds being adulterated during processing, which

is not following good commercial practices.  Following animal

welfare guidelines would be more likely to result in good

commercial practices than not having any guidelines at all. 

Mishandling birds and creating 24 broken wings on 500 birds is

not good commercial practice.  Failure to follow good

commercial practices could result in further regulatory action

being taken

(b) (6)

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 38

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

. QNA18110

53715G

2017-05-15 On May 15, 2017 at approximately 1045, 

, observed less than Good Commercial Practices while

performing an Ante-Mortem Inspection and Good Commercial

Practices check at 18557 P in Summit, MS. While observing the

kill machine of each picking line for proper function, I did not

observe any abnormality in the equipment's operation. I did

observe that a new employee was backing the kill machine on

line #2.  I walked to the end of the blood trough to observe for

any live birds entering the scalder. I observed a single, live  bird

at 1045 enter the scalder on picking line #2. The bird was

hanging on the shackle with its eyes open, still breathing, and

without a cut on its neck. This bird entered the scalder alive and

still breathing.  I did not take any regulatory action with this

single-bird incident, since no evidence of a system failure

existed. I notified , of

the observed nonconformance, during a brief meeting held

in his office at approximately 1050. I presented the cadaver to

him, explained my observation, informed him that a

Memorandum of Information (MOI) was going to be

documented, and relinquished the carcass into his control. FSIS

Docket No. 04-037N, Treatment of Live Poultry before

Slaughter, states that under the Poultry Products Inspection Act

(PPIA) and Agency regulations, live poultry must be handled in a

manner that is consistent with good commercial practices. In

order to ensure that poultry is handled and slaughtered in a

manner that is consistent with good commercial practices,

poultry should be treated in such a manner as to minimize

excitement, discomfort, and accidental injury throughout

processing.A copy of this Memorandum of Information will be

forwarded to the appropriate personnel in the Jackson District

Office. Respectfully, cc:

 and

Mr. Don Coley, Jackson DDM.

(b) (6)

(b) (6)

(b) (6)(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 39

EstNbr EstName Task_Code MOI# Date Description

P18557 Sanderson

Farms, Inc.

. QNA02110

64712G

2017-06-12 On June 12, 2017 at approximately 1049 while performing a

GCP task in the and 

 observed less than Good Commercial Practices.  A

weak, moribund bird was observed lying in the vat of DOA birds

located in the live receiving/cage dumper area.  The bird had a

very shallow and labored  respiratory movement.  Two

employees were in the act of throwing more DOAs into the vat. 

This action would have certainly smothered the debilitated bird

with the additional weight, since the bird could not right itself

and escape.  A new employee in the Management Trainee

Program was informed of our observation. He removed the live

bird, before any more DOAs were deposited into the vat, and

replaced it on the hanging belt. We discussed the incident with

, at about 1055.  He

immediately communicated with 

  in an effort to prevent future incidents.  As per

Federal Register Notice Docket No. 04-037N Treatment of Live

Poultry before Slaughter, states that under the Poultry Products

Inspection Act (PPIA) and Agency regulations, live poultry must

be handled in a manner that is consistent with good commercial

practices.  In order to ensure that poultry is handled and

slaughtered in a manner that is consistent with good

commercial practices, poultry should be treated in such a

manner as to minimize excitement, discomfort, and accidental

injury throughout processing.  A copy of this Memorandum of

Information will be forwarded to the appropriate personnel in

the Jackson District Office. Respectfully, 

cc: 

and Mr. Don Coley, Jackson DDM

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

(b) (6)

(b) (6)

(b) (6)

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 41

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

. PBM05150

40127G

2017-04-27 Good Commercial Practice Mistreatment MOI at Est. 20251P 

 and met with

 at 0815 hours on April 27, 2017

to discuss the mistreatment of young chickens described below:

On April 26, 2017, at approximately 0520 hours, while

performing ante-mortem inspection of birds on Organic trailer

T-15, I, , observed several dead and dying

young chickens.  The young chickens were wet and the outside

temperature was 38 degrees Fahrenheit with an 18 mile per

hour wind speed.  I contacted the 

and requested more information on the trailer. Via

E-mail, informed me that the trailer of birds was

from Iowa.  The trailer arrived to the establishment covered. 

There were 112 DOAs and there were birds from two different

lots on the trailer. I explained to that allowing

birds the die by other means than slaughter is not consistent

with GCPs. will look into it and contact

transportation about it. The meeting was adjourned at 0840

hours.

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

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 42

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

. PBM32060

55516G

2017-05-16 On May 12, 2017 at 1215 hours, and

 met with Establishment  P20251 

 and 

 for a weekly meeting and to

discuss Good Commercial Practice observed by stated

below. On May 12, 2017 at 0532 hours while performing

ante-mortem, I, , observed two live young

chickens setting on Trailer T-796.  The module adjacent from the

birds had a broken door, open outwards and penned between

the trailer support post and module, on the third level.  There

were approximately 20 live young chickens in the open

compartment of the module.  I notified the scale house

personnel.  The two loose birds were gently removed from the

trailer and placed into another module.  A wooden board was

placed in front of the opening.  Since the wooden board was not

secured to the module, I asked the scale house personnel how is

the module going to be handled when placed in the facility to

keep the birds from falling out of the opening.  He informed me

that he would notify the unloading personnel of the broken

module and they would monitor it at that time. 

 was notified via Email that an MOI would

be documented and sent to District office for review. At the

meeting, informed USDA that the module was

unloaded first and no issues were reported. And 

will look into options for preventative measures.

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 43

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

. PBM56120

65428G

2017-06-28 On 27 June 2017 at 1315 hours, USDA FSIS 

 met with VP Operations Mr. Erik Monson and

 upon request

from the establishment. The establishment does not believe

that the birds with red skin and red muscle being condemned

are cadavers.  They had a similar issue back in 2013.  By meeting

with the current USDA FSIS inspection team, they hope we can

come to a consensus. The establishment used the description

of a cadaver from the Compliance Guideline for Training

Establishment Carcass Sorters in the New Poultry Inspection

System (NPIS) Food Safety and Inspection Service U.S.

Department of Agriculture, September 2014, which states: “A

cadaver is a generalized condition that causes the carcass and

viscera to be unwholesome and unfit for human food.  Cadavers

are any birds that did not bleed out properly due to a poor or

missed cut of the neck veins before the bird entered the

scalder.  The heat of the scalder causes blood left in the carcass

to expand into the skin blood vessels, giving the skin of the

carcass and neck a cherry red to purple color.  The blood also

accumulates in the dependent (lower) regions, such as the

necks, wings, and upper breast area.  Some cadavers may

appear red all over; others will appear red only in the lower

regions of the carcass.  The blood vessels in the viscera will

appear enlarged and the liver may appear burgundy colored. 

The entire carcass and viscera of cadavers are unwholesome and

must be disposed of properly to ensure that they are not used

as human food.” It also states what the establishment sorter is

to look for: “cherry red to purple color of whole carcass or the

lower regions of the carcass; sometimes, just the neck will

appear cherry red or purple color; may be no cut on the neck,

or may be only partially cut; and blood vessels in the viscera

may appear engorged (filled up with blood)” The establishment

wanted to know if IPP are looking at the livers before

condemning the birds as cadavers.  Unfortunately by the time

the carcasses arrives to the Carcass Inspection Station, there are

no livers to examine and the IPP can only go by the skin, muscle

and what they can see inside the cavity. But, I, , was

able to examine the lot at the Leukosis station and noticed that

a large number of the birds have congested livers and ascites.

 asked if the condition of the birds were due to their

system.  I replied: “No, but the condition of the birds and your

(b) (6) (b) 

(6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 44

EstNbr EstName Task_Code MOI# Date Description

system can cause cadavers. This is why birds need to be placed

on the line in a timely manner so they can go through the kill

machine and bleed out.” The establishment doesn’t

understand why IPP are looking at the breast muscle since they

have no documentation on looking at the breast meat to

disposition a carcass. They request to have some of the birds

submitted for pathology.  They will also share the documents

they have from 2013 to the USDA FSIS.  USDA FSIS agreed to

submit pathology samples from carcasses that are condemned

as cadavers and will review the documents the establishment

has on the matter.  Once all the information is review and

pathology results received, the establishment and USDA FSIS

will meet again on this matter.  The meeting was adjourned.
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 45

EstNbr EstName Task_Code MOI# Date Description

P20251 Tecumseh

Poultry, LLC

. PBM30170

61329G

2017-06-29 On 28 June 2017 at approximately 0815 hours, I, 

 meet with

 to discuss the Good Commercial Practice

mistreatment observed earlier that morning. On 28 June 2017

at 0759 hours while performing ante-mortem inspection in the

South loafing shed, trailer T325 had six loose young chickens on

it.  The top module at the second level from the top had a

broken door which was hanging down and pinned between the

trailer’s support post and the module. The Scale House

employee was notified. And, the birds were caught and placed

into another module without harm or added stress.  The

employee informed me that a plastic door would be placed in

front of the opening to prevent the remaining chickens from

falling out and the trailer would be unloaded first for that lot. 

As I continued ante-mortem inspection on trailer T325, 529 and

T796, I observed a large number of dripping wet young birds. 

During the time the trailers were being transported uncovered

to the establishment, there were thunderstorms in the area. The

small young chickens (under 3 pounds) were dead or very

lethargic and pale in color. The young chickens were from Lot

Number: 4308179, Total Head: Total DOAs: 178 (24, 36

and 9 DOAs were on the three trailers). The Poultry Products

Inspection Act and Agency regulations (9 CFR 381.65(b)) require

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

good commercial practices (GCPs). Compliance with GCPs

increases the likelihood of producing unadulterated product.

Poultry are to be handled in a manner that prevents needless

injury and suffering in order to produce a commercially

marketable product. Establishment management may review

Federal Register notice “Treatment of Live Poultry Before

Slaughter”, 70 Fed. Reg. 56624 (September 28, 2005) for FSIS

recommendations concerning the treatment of live poultry

before slaughter. This MOI will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended. Respectfully, 

 Establishment P20251

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

) 

(6)

(b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 46

EstNbr EstName Task_Code MOI# Date Description

P208 George's

Processing, Inc.

. XIC331905

0322G

2017-05-22 On 5-22-2017 at approximately 1910 hours while walking

through the live hang and receiving areas I noted that the Kill

Line #1 cage dumper was inoperable.  As a result live hang

employees were transferring live birds by hand from the Kill Line

#2 hanging belt to the Kill Line #1 hanging belt, approximately 7

feet away, to be hung on shackles to allow both kill lines to be

utilized for production.  As I observed these activities in the live

hang area I noted that a live hang employee was removing live

birds from the Kill Line #2 hanging belt and throwing them

through the air at a distance of approximately 5 feet to land on

the Kill Line #1 hanging belt.  On two occasions this employee

tossed a live bird far enough to hit live birds that were hung on

the Kill Line #1 shackles and then drop onto the hanging belt

below. I immediately stopped production on Kill Line #1 and

placed U.S. Reject tag #B35619004 on the live hang belt to

denote it as rejected for use.  I contacted N/S Plant Manager

Paul Howell and  informed him that the Kill Line #1 hanging belt

was rejected for use due to improper handling of live birds by

the live hang employee.  After investigating the incident Mr.

Howell and met with me

to discuss corrective actions to prevent improper handling of

live birds by live hang employees.  Mr. Howell held an

immediate meeting with the live hang employees to discuss

proper bird handling.  He also informed me that there would be

a formal training session addressing good commercial practices

and proper bird handling to be held with all live hang personnel

at the end of the night's shift.  He also directed that

a supervisory employee be stationed in the live hang area to

monitor live hang employees until the transfer of live birds

between the two kill lines was discontinued for the night.  At

approximately 1926 hours I removed the U.S. Reject tag and

released the Kill Line #1 live hang belt for use.  The Kill Line #1

cage dumper became operational at approximately 2100 hours

and normal operations for live hang on both kill lines resumed

at that time.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 47

EstNbr EstName Task_Code MOI# Date Description

P2632 Pilgrims Pride

Corporation

. GAA14120

61808G

2017-06-08 P-2632 Pilgrim’s Pride, Regulation 381.65b.  1120 hours On

Tuesday June 6, 2017 at 11:20 I, , in the course

of performing the daily Good Commercial Practices task, I

observed  the birds being transported from the Line 1 cage

dump to the live hang area. On the right side of the cage dump

conveyor belt, I observed two birds that had gotten their heads

trapped between the belt and the metal guards that is designed

to prevent this occurrence. At the time I observed this, both

birds were dead and the other birds on the belt were traveling

across the carcasses. I immediately requested that the conveyor

be halted and contacted . He has

the two carcasses removed and made installed a temporary

barrier to allow the process to continue until the end of 1st

shift. At the end of the shift, permanent repairs were made and

the problem appears to have been satisfactorily corrected. I

consider this to be unacceptable since the birds appeared to

have died in a manner other than slaughter and the fact that

this potential point of birds becoming entrapped was brought to

the establishment’s attention during a weekly HACCP meeting

on April 26, 2017. Maintenance had ample opportunity to make

the alteration to prevent the incident I observed on June 6,

2017. Please respond in writing no later than Wednesday June

14, 2017.

P34308 Sanderson

Farms, Inc.

. PHY211904

3712G

2017-04-12 On this day, 4-12-17, at 1500, I found the following animal

welfare concern. While going out back, where the live birds are

dumped onto conveyer belt, I found where the employee

dumping the birds, did not allow the previous cage of birds, get

out of the way, before dumping another cage. I notified the

employee to wait till the birds get out of the way before he

dumps another cage. I notified of my finding.

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 49

EstNbr EstName Task_Code MOI# Date Description

P34668 Simply Essentials

Poultry, LLC

. 000521105

2718G

2017-05-18 I understand that this lot was affected with Reo virus.  This site

has had a history of high death loss.  The birds slaughtered were

a clean-out of the barn.  The number of DOA's and disposed

carcasses was very high.  The source barn is located within 25

miles of the plant and the weather was 84 degrees for a high

temperature.  The death loss occurred throughout the day even

with the normal start early in the morning when it was cool. 

The holding barn has fans on the north and south sides and in

between the trucks and is open on the east side.  There are fans

in the holding area of live hang. DOA losses for other sites on

days before and after have been acceptable.
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 50

EstNbr EstName Task_Code MOI# Date Description

P34668 Simply Essentials

Poultry, LLC

. 000501106

4713G

2017-06-13 6-12-17 Stressed birds/DOAs At approximately 7:00 on June

12 in the holding shed for Establishment P34668, I observed the

following conditions:  four of six outward exhaust fans on the

side of the building were operating, and of the four “walls” of

fans along the docks within the shed, one wall had four of

twelve fans operating; the other 3 walls had zero fans operating.

 The fans on the opposite (airflow inward) side of the structure

were also non-functional.  The fans that were running were the

only ones that were hooked up to a power source.  No misters

were installed.  A maintenance man who was filling the

generators powering the fans said that no birds were held

overnight and the fans are turned on as soon as birds start

showing up in the early morning hours. At 7:00 it was not too

hot in the shed with all of the bay doors open, but there was a

distinct temperature/airflow difference in the cages directly next

to operating fans and those that had a wall of cages blocking

the breeze.  Additionally, at this time there was still an open

bay – if the shed was full, the bay doors closed, or the

temperatures higher (as they were predicted to be for much of

the week), I anticipate that the shed could rapidly become

dangerously hot. In the CO2 stunning area, there were three of

five fans along the wall running, two bay doors open, and a

large industrial fan opposite the room from the other fans to

move air, but it was nonetheless very warm.  When I was in the

area at 10:45, many of the birds on the truck were panting, and

by the time the last of the birds were being unloaded at

approximately 13:00, nearly all of the birds were panting/visibly

stressed. There were ten trucks from one lot presented today. 

The numbers of deads from each load are as follows, with the

first trucks arriving earliest (first truck approximately 4:00 in

stunning area, last truck approximately 13:00): Truck # 

Deads 1 5 2 18 3 19 4 30 5 41 6 

87 7 244 8 179 9 361 10 389 The issue

of adverse environmental conditions resulting in DOAs has been

raised in two previous MOIs and at the most recent weekly

meeting.  In fact, the establishment acknowledged in response

to the 5-19-17 MOI that the non-functional fans were a

contributing cause to a high mortality day; that response also

stated that the fans would be hooked up promptly. It is

unacceptable for birds to be held in stifling heat due to a

longstanding lack of preparation for what are predictable

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 52

EstNbr EstName Task_Code MOI# Date Description

P40183 Sanderson

Farms, Inc.

. PEH291206

2805G

2017-06-05 Establishment P40183, Sanderson Farms, June 2, 2017, 0855

hours. In attendance:

, and

  This Memorandum of Interview (MOI) is issued

for the following potential mistreatment of a live bird in Live

Haul; on June 2, 2017 at approximately 0845 hours while

performing Poultry Good Commercial Practices Task

accompanied by between the offall and the

truck yard, we observed one live bird inside the USDA

Condemned yellow barrel; a Mighty Foam tag was attached to

the handle of the USDA barrel. stayed with the bird

while I went to Evisceration Office to notify and discuss the issue

with notified of the

issue and we all met at the offall. We discussed the issue and 

 asked ; how this bird got inside the USDA

Condemned barrel, why is sanitation using USDA Condemned

barrel to clean up, and what are you going to do with the bird?

He stated that he will find out how the bird got inside the USDA

barrel and he is going to asked sanitation about why are they

using USDA barrel for cleaning purposes. After the discussion

with management they decided to sacrifice the bird, at

approximately 0900 hours 

disarticulated the chicken’s neck in presence of USDA and once

all movement ceased the establishment elected to condemn the

bird.

(b) (6)

(b) (6)

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

(b

) 

(6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 53

EstNbr EstName Task_Code MOI# Date Description

P40183 Sanderson

Farms, Inc.

. PEH520706

3521G

2017-06-21 Establishment P40183, Sanderson Farms, June 16, 2017, 0930

hours. In attendance:

 and 

 This Memorandum of Interview (MOI) is issued for the following

potential mistreatment of live birds in Live Haul; on June 16,

2017 at approximately 0556 hours while performing Poultry

Good Commercial Practices Task inside the offall building, I

observed two live birds inside the USDA Condemned yellow

barrel. I notified and discussed the issue with . After

the discussion with he decided to sacrifice both

birds, at approximately 0615 hours cut the chicken

necks with a knife in presence of USDA and once all movement

ceased the establishment elected to condemn the birds. At

approximately 0930 hours, discussed the issue

with since is not the first time that this happened.

 stated that he will get with sanitation to ask

them, where exactly these birds are being found to try and pin

point where the birds are being left. also stated

that he would get with sanitation to discuss what they are going

to do with the chickens when found during sanitation.

P419 Case Farms

Processing, Inc.

. VDB53120

40005G

2017-04-05 Establishment: 00419P Case Farms 121 Rand St. Morganton,

NC 28655 Establishment Attendee: 

 USDA Attendee: 

At approximately 12:25 on 04/05/17, the inspector on Line 1,

Station 3 identified a chicken with the head intact without neck

cuts indicating the chicken had died other than by humane

slaughter.  I, , confirmed the chicken

had not received any neck cuts. The carcass was condemned.    

PPIA and Agency regulations require that live poultry be

handled in a manner that is consistent with good commercial

practices, and that they not die from causes other than

slaughter. I recommend management review Federal Register

Notice Vol. 70, No. 187, published September 2005 [Docket No.

04–037N] for FSIS recommendations concerning treatment of

live poultry before slaughter. A copy of this federal register

notice can be provided on request. A copy of this MOI will be

forwarded to the District Office and the District Veterinary

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

recommended.

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 54

EstNbr EstName Task_Code MOI# Date Description

P419 Case Farms

Processing, Inc.

. VDB28000

51716G

2017-05-16 Est. P419, Case Farms, 5/15/2017, approximately 2050 hrs. 

Present: , Mr. Robertson,

Assistant Plant Manager and .  On

5/15/2017, at approximately 2042 hours at start up, I observed

a number of red birds on the transfer belt.  Upon closer

examination, one of these birds had its head still attached to its

neck and there were no cuts on the neck, indicating that the

bird had died by means other than slaughter.  I and 

confirmed that there were no neck cuts present on this bird. 

This bird and the other red birds were rejected by the plant.  

went to the stunning/killing area and observed that all

birds he saw were being stunned and cut properly.  I brought

this to the attention of 

and I requested the presence of Mr. Robertson, Assistant Plant

Manager. I pointed out our findings and Mr. Robertson said that

the stunner had not been functioning properly but the situation

had been addressed and corrected by the establishment.  Our

observations concurred with this. This MOI will be forwarded

to the District Office and the District Veterinary Medical

Specialist in case additional follow-up is recommended.  A copy

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

September 2005 [Docket No. 04–037N] was provided.

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

(b) 

(6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 55

EstNbr EstName Task_Code MOI# Date Description

P419 Case Farms

Processing, Inc.

. VDB05020

63922G

2017-06-22 Est. P419, Case Farms, 6/22/2017, approximately 0119 hrs.

Present: Mr. Robertson, Assistant Plant Manager, 

 and At

approximately 0115 hrs after administering relief breaks,

 and observed on the transfer belt a

red bird with its head still attached.  Upon closer examination,

there was no cut mark on the neck indicating that the bird died

by means other than slaughter.  This was brought to the

attention of who

called .  

entered in to the discussion between the

establishment and USDA.  The back-up killer was replaced with

another back-up killer.  No other cadavers were observed on the

line, indicating this was an isolated incident and the situation

was under control.  A similar incident occurred around

5/16/2017. This MOI will be forwarded to the District Office

and the District Veterinary Medical Specialist in case additional

follow-up is recommended. A copy of Federal Register Notice

Vol. 70, No.187, published September 2005 [Docket No.

04-037N] was provided.

(b) (6)

(b) (6)

(b) 

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 56

EstNbr EstName Task_Code MOI# Date Description

P425 Northern Pride,

Inc.

. MYG08100

50003G

2017-05-03 P425 Northern Pride, Inc 06:35 hours: Plant Manager Warren

Leighton, On Monday May 1, 2017 at

approximately 06:25 hours while performing Good Commercial

Practices Verification, I observed a bird that I suspected was still

breathing on the line.  The bird had passed through the blood

tunnel, and from the point of observation the bird had

approximately 52 seconds of travel time on the line prior to

entering the scalder.  I observed the bird did have a cut on the

neck.  As the bird turned the corner and passed out of view I

proceeded to the post picking area.  Approximately 4 minutes

later a well fleshed bird with diffusely red skin exited the picker. 

This bird was also observed by an establishment employee who

approached the line to remove the bird.  I removed the bird off

the line for further examination.  I observed the cut on the neck

was superficial and did not fully sever the carotid arteries and

jugular veins for adequate exsanguination.  I determined the

bird died from means other than slaughter. I placed US Retain

Tag B35188428 on the carcass. At approximately 06:35 hours I

discussed the findings with Plant Manager Warren Leighton.  I

showed him the carcass and the superficial neck cut.  Manager

Leighton mentioned the establishment has a humane handling

protocol and undergoes multiple audits a year which include

humane handling. Manager Leighton stated that he will discuss

this finding with the sticking employee and document the

conversation.  We discussed the importance of humane

treatment of all birds, which Manager Leighton agreed was

important. I advised Manager Leighton that an MOI would be

written and forwarded to the District Office for the 

and ) to

review, should additional follow-up be needed. Respectfully, 

 OFO FSIS

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

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 57

EstNbr EstName Task_Code MOI# Date Description

P425 Northern Pride,

Inc.

. MYG40050

51809G

2017-05-09 P425 Northern Pride, Inc 13:37 hours: Plant Manager Warren

Leighton, On Monday May 7, 2017 at

approximately 13:35 hours while performing Good Commercial

Practices Verification, I observed a bird on the line that had

passed the blood tunnel and was headed to the scalder.  The

bird was rhythmically breathing and blinking.  It had an arched

neck and was moving its head dorsally, and then laterally.  I

stopped the picking line, and Plant Manager Warren Leighton

removed the conscious bird from the line.  At this time it was

observed that the bird did have a cut on the neck, but the cut

was superficial and did not sever the carotid artery and jugular

vein for adequate exsanguination.  

  took the bird to the hanging area where he

rehung the bird for subsequent re-stunning and re-sticking. At

approximately 13:45 hours I discussed the findings with Plant

Manager Warren Leighton.  We discussed that this incident was

the second in two weeks.  (On May 1, 2017 a cadaver was

observed on the line after the observation of a possibly

breathing bird was made prior to the scalder).  Manager

Leighton stated there are two sticking employees, they are both

experienced. Each sticking employee has now been on sticking

duty when a bird was observed by USDA IPP to not be

adequately cut.  Manager Leighton stated he would meet with

both sticking employees after slaughter was completed for the

day to discuss sticking.  He noted that the first week of

production there were problems with heads becoming detached

in the picking machine, and the sticking employees were

warned about this.  Manager Leighton agreed he would rather

have a detached head in the picking machine than a live bird

going through the scalder, and he reiterated he would discuss

the importance of this with the sticking employees. I advised

Manager Leighton that an MOI would be written and forwarded

to the District Office for the 

 and , to review and they will

contact us should additional follow-up be needed. Respectfully,

(b) (6)

, OFO FSIS

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 58

EstNbr EstName Task_Code MOI# Date Description

P425 Northern Pride,

Inc.

. MYG08060

61627G

2017-06-27 P425 Northern Pride, Inc 13:10 hours: Plant Manager Warren

Leighton, On Monday June 26, 2017 at

approximately 13:04 hours while performing Good Commercial

Practices Verification, I observed a bird on the line that had

passed the blood tunnel and was headed to the scalder.  The

bird was rhythmically breathing.  The bird’s eyes were closed

and the bird was not moving its head or neck.  I stopped the

picking line, and removed the

breathing, unconscious bird from the line.  At this time it was

observed that the bird did have a cut on the neck, and there was

a large blood clot that had formed cranially to the sticking

laceration.    took the bird

to the sticking area where the bird’s jugular vein was cut a

second time.  The bird continued to breathe from the time of

removal on the line past the time of the second stick, which was

estimated to be a total of approximately 60 seconds.  The bird

expired approximately 3-4 seconds after the second sick was

administered. At approximately 13:10 hours I discussed the

above observations with Plant Manager Warren Leighton.  I

expressed concern that the bird, although unconscious, was

breathing rhythmically for quite a length of time after removal

from the line.  From the location where birds are observed for

signs of consciousness and rhythmic breathing to entering the

scalder is approximately 50 seconds.  It is quite possible that

this bird, if gone unnoticed, would have died by drowning in the

scalder.  I advised Manager Leighton that an MOI would be

written and forwarded to the District Office for the 

and , to

review and they will contact us should additional follow-up be

needed. Respectfully , OFO

FSIS

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

(b) (6)

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 59

EstNbr EstName Task_Code MOI# Date Description

P44826 Case Farms

Processing, Inc

. 000300005

1422G

2017-05-22 On 5/22/2017 at approximately 12:55 AM, while conducting a

routine walkthrough of the Evisceration department, 

 did make the following good commercial

practices observation.  While standing at the evisceration

rehang table, multiple (6-7), cherry-red cadaver birds with no

neck cuts began appearing on the kill line.  The evisceration

rehang table employee’s removed these birds from the kill line. 

 proceeded back to the kill room to make further

observations.  It was noted that the kill machine had numerous

heads in the blade and that several of the birds appeared to be

too active after the stunner, including some birds that were

noted to apparently be vocalizing after the stunner.  The

evisceration line lead was notified of these problems and the

increased amount of cadavers being seen at the evisceration

rehang table.  While I proceeded back out to the evisceration

rehang table, I observed several more cadavers on the kill line

after the pickers.  Once back out at the Evisceration rehang

table, and 

 were overseeing the removal of the remaining

cadavers from the evisceration line and I notified them of my

observations regarding the kill machine and birds.  

notified me that maintenance was addressing the issue and

followed me back to the kill room to check on the kill machine

and stunner.  Upon further discussion with maintenance, it was

noted that while there had been a stoppage on the kill line due

to a fire alarm, a breaker on the new stunner had tripped and

this caused the birds to be insufficiently stunned prior to

entering the kill machine, resulting in the large amount of

cadavers noted.  Maintenance had switched over the stunning

machine to the back-up breaker and this resolved the issue.  A

follow-up GCP check of 1000 birds at 1:10 AM revealed the

process was under control, with the birds appropriately docile

after the stunner and no birds entering the scald tank

breathing.  Upon checking the condemn barrel at the

evisceration rehang table after the issues were resolved, I noted

approximately 30 cherry red cadaver birds with no neck cuts. 

The observations described above are not compatible with the

establishment’s policies for good commercial practices for

poultry slaughter.

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

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 60

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

. 000341605

4910G

2017-05-10 While I was conducting Poultry Good Comercial Practice Task at

around 4:00pm, I observed a bird on the live hang belt on it's

back struggling to breathe. During this time plant employees

had gone on their break, thus leaving the birds in live hang

unattended. I explained during my weekly meeting with the

establishment management, 5/10/2017, that birds on their

backs can not properly ventilate, which would eventually lead to

suffocation. As I continued to walk down the line, I noticed a

bird with a mutilated left rear leg. The bird was panting, had

pale wattles and comb, and it's eye were closed and neck

extended. The left leg had no feathers or paw remaining and the

skin had been de-gloved (removed). Lying adjacent to this bird

was another leg from a different bird that had been completely

amputated, with the same presentation (no skin, feathers, or

paw). I was not able to identify which bird this leg had come

from, but addressed my findings with 

He informed me that there was an issue with the

cage dumper belt and the live hang belt and he will take care of

this situation promptly. NOTE* There was an error uploading

establishment's response, so it will be copied and pasted below;

Sanderson Farms, Inc. 2076 NC Hwy 20 • St. Pauls, North

Carolina 28384 Telephone (910) 674-4777 • Facsimile (910)

802-4686 June 26, 2006 Memorandum Subject: 

Response to MOI on Good Commercial Practices from

5/10/2017  Date:  5/11/2017 To:      The

management team met on the issues addressed in the MOI to

discuss a further plan of action and assess the corrective actions

implemented on 5-10-17.  The root cause of the incident was a

gap in the divider causing birds to get caught or pinched in

between the divider and the belt.  Maintenance lowered the

divider down to eliminate the gap in between the divider and

belt.  Also, maintenance added removable stabilizers to ensure

the divider is properly adjusted before the next production run. 

We will also have personnel monitoring the live hang belt during

all breaks for the next 30 days to ensure the problem has been 

eliminated.

                                                                                                             

                                                     Respectfully, 

 Sanderson Farms, Inc. 2076 NC Hwy 20 St. Pauls, NC

28384 P-45910

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 61

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

. 000082105

2110G

2017-05-10 On May 10, 2017 at 1830 hours while performing a Good

Commercial Practice task, I observed the following condition at

the live hang belt:  At the very beginning of lunch break and as

the live hang employees were leaving the belt area for their 30

minute break, I observed a live hanger toss one of five

remaining birds that was not hung in a shackle back onto the

belt with the bird landing onto his back and remaining in that

position (birds that remain on their back can not properly

ventilate which would eventually lead to suffocation). The

employee then turned to leave for break. 

stopped the employee and explained to him about

leaving birds on their backs. Also while looking at the live hang

belt, I observed approximately 2 to 3 poultry legs that were

wedged by their feet in a approximately 1-1/2 inch gap that had

developed between the belt and the Teflon partition. The legs

were completely severed at the junction of the Tibia and Femur

with the muscle, skin and feathers still attached. I then took

regulatory control of the live hang belt by applying USDA

Rejected tag # B37028513 and then showing 

 and 

the noncompliance. at 1833 hours. The live hang belt

was released after being repaired by maintenance and

re-inspected by USDA at 1926 hours. There was previous

discussion concerning Good Commercial Practices concerning

the same issues in a plant meeting on May 10, 2017 at 1630

hours.

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 62

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

. 000060505

3111G

2017-05-11 Establishment P 45910, Sanderson Farms, Inc.  May 8, 2017,

0615 hours.  In attendance: and 

 At approximately 6:15

am on May 8, 2017, I went to live hang and observed Good

Commercial Practices.  I saw that the birds were piled up at the

end of the live hang table.  The live hangers was having difficulty

getting the birds out of the pile up, having to tug on the birds to

dislodge them.  Also while observing this pile up, there were 3

birds with their legs stuck underneath the end panel where the

birds were piled up.  Live hang workers cleared the pile up and

removed the birds that had their legs under the panel.  I notified

 of my concerns

that the birds must not be mishandled; he stated that he would

address the issues.  Later in the shift, I also notified 

, of these same observations.  A copy of this

MOI will be submitted to the District Veterinary Medical

Specialist in the Raleigh District Office.

(b) (6)(b) 

(6) (b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 63

EstNbr EstName Task_Code MOI# Date Description

P45910 SANDERSON

FARMS, INC

. 000572005

4018G

2017-05-18 On May 18, 2017 at 1815, the following condition was observed

in the Live Hang room:  At the end of the shift, a live hang

employee was observed picking several birds off the floor, two

of which were very much alive, flapping and kicking vigorously

and placing them into a stainless steel Dead on Arrival (DOA)

bin. The birds did not appear to have received cervical

dislocation. Seeing that USDA personnel and

), was observing the employee as he was walking up

to the DOA bin with the live birds, 

 started yelling for the employee to stop and not put

the birds into the container. The employee apparently, not

hearing, continued to place the birds into the container. 

immediately ran over to the employee and had him remove the

birds from the container and place them on the floor.  USDA,

 performed further ante-mortem inspection

confirming the live condition of the birds. He assessed

consciousness, by performing palpebral reflex on both of the

suspected birds. Palpebral reflex is assessed by gently tapping

along the inner edges of the eyelids with a fingertip. A positive

response is indicated by the animal blinking. The birds had a

positive response to palpebral reflex by blinking their eyes and

even opening their eyes immediately afterwards. Another

indication that the birds were alive was miotic (constricted)

pupils. A properly euthanized bird will have mydriatic (dilated)

and fixed pupils. According to the animal welfare plan from the

establishment, DOA birds will have cervical dislocation

performed by trained personnel, prior to being placed into the

DOA bin.  explained to that the birds had not

been properly euthanized and were still alive. 

 arrived shortly after the incident and

explained his findings and informed him that this would

be documented in an MOI.

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

(b) (6) (b) 

(6) (b) 

(6)

(b) (6) (b) 

(6)

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 65

EstNbr EstName Task_Code MOI# Date Description

P468 Peco Foods, Inc. . JVD321705

0106G

2017-05-06 Est P468, Peco Foods, May 6th 2017, 17:13 hours. In

attendance: and 

 At approximately 17:13 hours,

while observing conditions in the 1st processing room, just prior

to the scalder on line 2, I observed a single bird still breathing

before entering the scalder. I immediately reported my findings

to , who then slowed the line to

bpm. I verified again that no birds were entering the scalder

breathing. At approximately 17:58 hours requested

the line speed be increased to bpm with the replacement of

the current back up killer; I had approved of his request. I

reminded that the PPIA and the agency regulations do

require that live poultry be handled in a manner that is

consistent with good commercial practices (GCP's), and that

they not die from causes other than slaughter. I provided 

a copy of the Treatment of Live Poultry Before Slaughter,

published September 2005, and recommended he review it. I

notified that this MOI will be forwarded to my front

line supervisor as well as the districts District Veterinary Medical

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

Respectfully, P468 Peco

Foods.

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

(b) (6) (b) 

(4)

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

(4)

(b) 

(6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 66

EstNbr EstName Task_Code MOI# Date Description

P46897 IHSAN FARMS,

IIC

. 000580806

3727G

2017-06-27 An observation was made  of  the live hang employees were

grabbing and lifting the birds by their wings totransport them

from a conveyor belt into cones (a distance of approx. 3 feet). I

immediately intervened to prevent the chickens from being

handled in this manner and establishment management

instructed the employees on how to properly pick up and move

the chickens. During the time of observation, the employees

began using proper handling techniques to move the live

chickens after using a translater to help them understand. I had

never seen the birds handled in this manner prior to this date, I

found the two employees were new and once they were

instructed they began to do the job properly. During this

observation even though the handling was questionable no

birds resulted in  dying by means other than slaughter or that

the handling prevented the birds from being properly bled out

before entering the scalder. These  employees behavior was

discussed..  It was found that all birds were appropriately cut

and appeared to have been properly bled out by the time they

reached the scald tank. Also observed was that no birds were

breathing when they entered the scalder.

P51179 Sanderson

Farms, Inc.

. 000021404

4524G

2017-04-24 On April 21, 2017 at approximately 1909 hours while

performing a Good Commercial Practices task at the scalder

entrance on line 2, a live bird was observed to enter the scalding

tank. The bird’s neck was not cut; its head was up, and was still

breathing as it was conveyed into the scalder. When the bird

exited the scalder I confirmed the neck was not cut. 

 observed the cadaver. As

immediate corrective actions said he would counsel

the responsible employee. He believed the employee was

focusing too much on rehanging the birds that were hung by

one leg and needed to focus more on ensuring all birds were

slaughtered. It is important to treat poultry in a way that

ensures they are not breathing and are properly bled out when

they enter the scalder. Employing humane methods of handling

consistent with Good Commercial Practices and 9 CFR 381.65(b)

can help produce an unadulterated product. 

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 67

EstNbr EstName Task_Code MOI# Date Description

P51179 Sanderson

Farms, Inc.

. 000341905

4911G

2017-05-11 On Wednesday May 10, 2016 at approximately 2135 hours

while performing a GCP task in the live hang room a chicken

was observed crushed underneath a belt at the end of the live

hang belt. The chicken was crushed between the belt and the

roller at the end of the live hang belt and was obviously dead.

The carcass was shown to the .

When attempted to remove the carcass it ripped

apart. I asked what he was going to do to prevent

further bird suffering and he said he would increase monitoring

of the area. On Thursday May 11, 2017 was

informed that an MOI about the incident would be

documented. Processing equipment must be maintained in a

manner that will not cause bird injury and suffering. It is

important to treat poultry in a way that ensures they do not die

by means other than slaughter. Employing methods of handling

consistent with Good Commercial Practices and 9 CFR 381.65(b)

can help produce and unadulterated product

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 68

EstNbr EstName Task_Code MOI# Date Description

P51179 Sanderson

Farms, Inc.

. 000171505

4731G

2017-05-31 On Tuesday May 30, 2017 at approximately 2003 hours while

performing a GCP task in the live hang room a weak bird was

sorted off the live hang belt by an employee and placed onto

the floor. picked up the bird by

its head and tossed it onto a small pile of dead birds on the floor

at the end of the belt. The bird was obviously still alive and

breathing. was asked why he picked up the bird by

its head and tossed it. He said he did not know that the bird was

alive. When I asked what he was going to do with

the bird he responded that he was going to wait for it to die. 

was informed that it is unacceptable to pick up live

birds by the head and toss them onto the floor. The bird was

collected by another supervisor and placed onto the kill line.

The incident was discussed with the 

 later in the evening. On Wednesday May 31, 2017

the incident was also discussed with 

 and Plant Manager Mr. John Stedman at the weekly

establishment exit meeting. and Mr. Stedman were

informed that a GCP MOI would be documented. 

stated that he would provide retraining to to

prevent more bird suffering. Picking up live birds by the head

and tossing them onto the floor is not consistent with Good

Commercial Practices because it resulted in needless bird

suffering. It is important to treat poultry in a way that ensures

they do not die by means other than slaughter. Employing

methods of handling consistent with Good Commercial

Practices and 9 CFR 381.65(b) can help produce and

unadulterated product. 

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

(b) 

(6)

(b) (6)

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

(6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 69

EstNbr EstName Task_Code MOI# Date Description

P51179 Sanderson

Farms, Inc.

. 000571406

0301G

2017-06-01 On May 31, 2017 at approximately 1732 hours while

performing a Good Commercial Practices task at the scalder

entrance on line 1, a live bird was observed to enter the scalding

tank. The bird’s neck was not cut; its head was up, and was still

breathing as it was conveyed into the scalder. When the bird

exited the scalder I confirmed the neck was not cut. 

 observed the cadaver. As

immediate corrective actions to prevent ongoing bird suffering

 said he would discipline the responsible employee. 

It is important to treat poultry in a way that ensures they are

not breathing and are properly bled out when they enter the

scalder. Employing humane methods of handling consistent

with Good Commercial Practices and 9 CFR 381.65(b) can help

produce an unadulterated product. 

(b) (6)

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

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 71

EstNbr EstName Task_Code MOI# Date Description

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

 Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046

cc:  Mr. Perry Davis, DM        Mr. Don Coley, DDM        Dr. David

Thompson, DDM        Dr. Larry Davis, DDM        

        

P517 Mar-Jac

Poultry-MS

. QOO15140

60615G

2017-06-15 Good Commercial Practices MOI: On June 15,

2017 @ approximately 1034 hours, I observed a less than good

commercial practice while performing an Ante-mortem and

Good Commercial Practices (GCP) check at P-17766. While

performing the GCP, I noticed that a trailer under the unloading

shed had numerous birds that were breathing rapidly and

gasping with outstretched necks (distressed).  The outside

temperature was 82°F.  The fans surrounding the bird trailers

were blowing at full speed, but no misters were installed

throughout the unloading shed.  

 stated that the misters are only located under the

holding shed.  A survey of the holding shed revealed that the

misters were powered on; however, they had very little output. 

This could only be observed when the fans were not powered. 

In the on state, there was no mist observed or felt in any house. 

The holding shed was free of trailers for the remainder of the

day since the last truck had been transported to the unloading

shed.  was also notified of

this unacceptable practice.  In accordance with FSIS Docket No.

04-037N, Treatment of Live Poultry before Slaughter, live

poultry must be handled in a manner that is consistent with

good commercial practices. In order for this to occur, poultry

must be treated in a manner that will minimize excitement,

discomfort and accidental injury throughout processing.  A copy

of this Memorandum of Interview will be sent to the Jackson

District Office for further review.  Thanks for your attention to

this matter. Respectfully, 

(b) (6)

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

(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 72

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

. KMH49200

51901G

2017-05-01 Mr. Craig Ballentine Complex Manager Wayne Farms, LLC,

P519 525 Wayne Dr. Laurel, MS 39401 Mr. Ballentine, At

approximately 0327 hours on April 28, 2017 while performing

the PHIS Good Commercial Practice in Poultry (GCPIP)

verification task, the following less than GCPIP incident was

observed in the live hang are of P519, Wayne Farms, LLC, Laurel,

MS.   A young chicken was observed at the end of the live hang

conveyor belt in a red container, with chicken manure and

feathers which had collected from the belt.   Only the back of

the bird was visible.  When the manure and feathers were

removed, the bird raised its head.  The bird was viable but had

its head buried under the manure and feathers.   Six live young

chickens were observed at the end of the belt on the floor of the

live hang area.  The bird was removed from the red container by

a plant employee and placed back into production along with

the six other live birds. 

 and 

and were notified.    Allowing birds to

become entrapped under debris can cause suffocation and

death by means other than slaughter.  The establishment has a

responsibility to ensure that all birds on the official premises be

treated in a humane manner to prevent unnecessary suffering,

injury, or death by means other than slaughter while under their

control. A meeting was held briefly with and

 at the time of notification.   A meeting was held with

 and 

 at approximately 2300 hours on April 30, 2017.  

was unavailable at the time of the incident on April 28, 2017.  

 stated any forthcoming response to the GCPIP

Memorandum of Information would be addressed by 

, Wayne Farms, LLC,

Laurel, MS. As per Federal Register Docket Notice 04-037N,

dated September 28,2015, “Treatment of Live Poultry Before

Slaughter”, the Food Safety and Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely prior

to slaughter and abide by Good Commercial Practices (GCPs) as

described in industry guidelines. Respectfully, 

 Canton, MS 9024 1039 W. Fulton St. 

Canton, MS 39046 cc:  Mr. Perry Davis, DM        Mr. Don Coley,

(b) (6)

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

(b) 

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

(b) 

(6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 73

EstNbr EstName Task_Code MOI# Date Description

DDM        Dr. Larry Davis, DDM        Dr. David Thompson, DDM 

              

 (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 74

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

. KMH45040

54402G

2017-05-02 Mr. Craig Ballentine Complex Manager Wayne Farms, LLC,

P519 525 Wayne Dr. Laurel, MS 39401 At approximately

0411 hours on May 2, 2017, while verifying the PHIS Good

Commercial Practices in Poultry (GCPIP) verification task at

P519, Wayne Farms, LLC, Laurel, MS, the following less than

GCPIP incident was observed.   One live young hen chicken from

an approximately 500 bird sample subgroup entered the first

scald tank exhibiting rhythmic breathing, pupillary reflexes,

uplifted head and no cut to the neck.   Verification was made at

the exit of the last picker at approximately 0416 hours.   The

carcass was bright red in appearance, with pooling of blood in

the head, neck, and upper breast consistent with a cadaver.  

requested the cadaver be removed at rehang by a plant

employee.  

 and 

were notified and observed the cadaver removed from the

evisceration line.   A second verification prior to the first scalder

of an approximate 500 bird subgroup had no bird(s) entering

the scalder at approximately 0422 hours.   A visual check of the

kill room evidenced the birds were being stunned properly with

an occasional bird bypassing the kill machine.   Bird(s) entering

the scalder while still breathing is not consistent with GCPIP and

results in adulterated product.  Establishments are responsible

for birds entering the official premises and must employ GCPIP

to prevent unnecessary suffering, injury and death. A meeting

was held in the office of at approximately 0500

hours.   , and

 were present.  discussed the incident and

additional findings with and .  

was advised a GCPIP Memorandum of Information (MOI) would

be issued to the plant.   Mr. Lott stated any forthcoming

response would be made by 

 As per Federal Register Notice Docket 04-037N,

dated September 28.2005, “Treatment of Live Poultry Prior to

Slaughter”, the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to abide by Good Commercial Practices (GCPs) as

described in industry guidelines. Respectfully, 

, Canton, MS 39046 1039 W. Fulton St. 

Canton, MS 39046 cc:  Mr. Perry Davis, DM         Mr. Don

Coley, DDM         Dr. Larry Davis, DDM         Dr. David

(b) (6)

(b) (6)

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

) 

(6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 75

EstNbr EstName Task_Code MOI# Date Description

Thompson, DDM                 

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

) 
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 76

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

. KMH20220

51703G

2017-05-03 Mr. Craig Ballentine Complex Manger Wayne Farms, LLC, P519 

525 Wayne Drive Laurel, MS 39401 Mr. Ballentine, At

approximately 2047 hours while verifying the PHIS Good

Commercial Practices in Poultry (GCPIP) verification task at

Wayne Farms, LLC, Laurel, MS, P519, 3rd shift, the following less

than GCPIP incident occurred.  

 and observed a

live bird with labored breathing and with the head covered in a

pile of Dead on Arrivals (DOAs) outside the live hang pen.  The

DOA bin was not in place and the live birds and DOAs had been

piled on the sidewalk.  requested a plant employee to

summon a supervisor.  Per request, a plant employee

removed the birds from the one by one from the pile.  The DOAs

were decapitated and placed in the DOA bin.   While the plant

employee was removing the birds from the pile, another bird

with labored breathing was removed from the pile of DOAs.  The

moribund birds were euthanized by rapid cervical

disarticulation.  

 and Mr.

Craig Ballentine, Complex Manager were notified.   Birds

entrapped in a pile of DOAs are subject to die by suffocation or

means other than slaughter.   The establishment has a

responsibility to handle birds in their care on the official

premises in a humane manner that will prevent unnecessary

suffering, injury, or death by means other than slaughter. A

meeting was held in the USDA office at approximately 2115

hours.  , and 

 were present.   The less than GCPIP incident and

the contributing factors leading up to the incident, including the

DOA bin not being in place and comingling live birds with DOAs,

were discussed. and were advised a

GCPIP MOI would be issued documenting the incident. As per

Federal Register Docket Notice 04-037N, dated September

28,2005, “Treatment of Live Poultry Before Slaughter”, the Food

Safety and Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely prior to slaughter and

abide by Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

, Canton, MS 9024 1039 W. Fulton St. Canton, MS 39046 

(b) (6)

(b) (6)

(b) (6)

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 77

EstNbr EstName Task_Code MOI# Date Description

cc:  Mr. Perry Davis, DM        Mr. Don Coley, DDM        Dr. Larry

Davis, DDM        Dr. David Thompson, DDM        

        

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 78

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

. KMH47040

63805G

2017-06-05 Mr. Craig Ballentine Wayne Farms, LLC Complex Manager 

525 Wayne Drive Laurel, MS 39440 Mr. Ballentine At

approximately 2227 hours on June 4, 2017, while verifying the

PHIS Good Commercial Practices in Poultry (GCPIP) verification

task at P519, Wayne Farms, LLC, Laurel, MS, the following less

than GCPIP incident was observed.   One live young hen chicken

from an approximately 500 bird sample subgroup entered the

first scald tank exhibiting rhythmic breathing, pupillary reflexes,

uplifted head and no cut to the neck.   Verification was made at

the exit of the last picker at approximately 2230 hours.   The

carcass was bright red in appearance, with pooling of blood in

the head, neck, and upper breast consistent with a cadaver.  

 requested the cadaver be removed at

rehang by a plant employee. 

 was notified and observed the cadaver

removed from the evisceration line.   A second verification prior

to the first scalder of an approximate 500 bird sample subgroup

had no bird(s) entering the scalder at approximately 2237

hours.   A visual check of the kill room evidenced the birds were

being stunned properly with an occasional bird bypassing the

kill machine.  This was determined to be an isolated incident

and not a loss of process control.   Bird(s) entering the scalder

while still breathing is not consistent with GCPIP and results in

adulterated product.  Establishments are responsible for birds

entering the official premises and must employ GCPIP to

prevent unnecessary suffering, injury and death. A meeting was

held in the office of at approximately 0430 hours

on June 5, 2017.   , and 

were present.  discussed the incident and further

findings with was advised a GCPIP

Memorandum of Information (MOI) would be issued to the

plant.   stated any forthcoming response would be

made by . As per

Federal Register Notice Docket 04-037N, dated September

28.2005, “Treatment of Live Poultry Prior to Slaughter”, the

Food Safety Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to abide by

Good Commercial Practices (GCPs) as described in industry

guidelines. Respectfully, ,

Canton, MS 39046 1039 W. Fulton St. Canton, MS 39046 

Cc:  Mr. Perry Davis, DM         Mr. Don Coley, DDM         Dr.

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

(b) (6)

(b

) 
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 79

EstNbr EstName Task_Code MOI# Date Description

Larry Davis, DDM         Dr. David Thompson, DDM         

         

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

) 
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 80

EstNbr EstName Task_Code MOI# Date Description

P519 Wayne Farms

LLC

. KMH01050

64129G

2017-06-29 Mr. Craig Ballentine Wayne Farms, LLC Complex Manager 

525 Wayne Drive Laurel, MS 39440 Mr. Ballentine, At

approximately 2356 hours on June 28, 2017, while verifying the

PHIS Good Commercial Practices in Poultry (GCPIP) verification

task at P519, Wayne Farms, LLC, Laurel, MS, the following less

than GCPIP incident was observed.   One live young chicken

from an approximately 500 bird sample subgroup entered the

first scald tank exhibiting rhythmic breathing, pupillary reflexes,

uplifted head and no cut to the neck.   Verification was made at

the exit of the last picker at approximately 0101 hours.   The

carcass was bright red in appearance, with pooling of blood in

the head, neck, and upper breast consistent with a cadaver.  

 requested the cadaver be removed at rehang

by a plant employee. 

was notified at approximately 0104 hours and

observed the cadaver removed from the evisceration line.   A

second verification prior to the first scalder of an approximate

500 bird subgroup had no bird(s) entering the scalder at

approximately 0106 hours.  A visual check of the kill room at

approximately 0110 hours evidenced the birds were being

stunned properly and the automatic kill machine was operating

properly.  This was determined to be an isolated incident and

not a systemic loss of process control.   Bird(s) entering the

scalder while still breathing is not consistent with GCPIP and

results in adulterated product.  Establishments are responsible

for birds entering the official premises and must employ GCPIP

to prevent unnecessary suffering, injury and death. A meeting

was held in the office of at approximately 0130 hours

on June 28, 2017.  

 and were present.  

discussed the incident and further findings with .  

 stated that a check of the stunner and kill machine by 

 was

within normal operating parameters. was advised a

GCPIP Memorandum of Information (MOI) would be issued to

the plant.   stated any forthcoming response would be

made by . As per

Federal Register Notice Docket 04-037N, dated September 28,

2005, “Treatment of Live Poultry Prior to Slaughter”, the Food

Safety Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to abide by

(b) (6) (b

) 

(6)

(b) 

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

(b) (6)

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

(b) 

(6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 81

EstNbr EstName Task_Code MOI# Date Description

Good Commercial Practices (GCPs) as described in industry

guidelines. Respectfully, ,

Canton, MS 39046 1039 W. Fulton St. Canton, MS 39046 

cc;  Dr. Larry Davis, acting DM         Mr. Don Coley, DDM       

Dr. David Thompson, DDM        

       

P522 Sanderson

Farms, Inc.

(Processing Div)

. IKB510804

2706G

2017-04-06 P-522 On April 6, 2017 at

approximately 0515 while performing a GCP task in the Picking

Room, I observed less than Good Commercial Practices.  I

observed a live bird lying on its back in a drain pan located

under the picking line which runs prior to the kill machine.  The

bird could not right itself.  Water from other birds hung on the

picking line which had just exited the stunner cabinet and

passing over the top of this bird was observed pouring down

onto the front of this bird’s head and body.  The bird was lying

in water collected by the drain pan.       

, with me at the time of this observation

removed the bird from the drain pan.  The bird was breathing

with open eyes and appeared lethargic and/or fatigued as there

was very little movement from the bird when picked up.  The

Picking Room Supervisor placed the bird back on the picking

line at a point in the process that caused the bird to re-enter the

slaughter process for a second time.     I discussed my

observation with Kevin Montgomery,  Plant Manager, and 

.  I reminded management

this was now the third occurrence of finding birds displaced

from the picking line. Two previous findings were discussed in

weekly meetings with plant management of finding birds

located at the stunner exit (one live and one dead bird). 

Discussions with plant management were documented in the

weekly meeting minutes on 3-24-17 and 3-31-17.  Additionally,

I had a separate discussion with of my concern of

allowing the bird to go through the entire slaughter process a

second time.      As per Federal Register Notice Docket No.

04-037N dated September 28, 2005, “Treatment of Live Poultry

before Slaughter,” the Food Safety Inspection Service (FSIS)

strongly encourages all establishments engaged in the slaughter

of poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines. Respectively, Cc Mr.

Don Coley, DDM  

(b) (6) (b) 

(6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 82

EstNbr EstName Task_Code MOI# Date Description

P522 Sanderson

Farms, Inc.

(Processing Div)

. IKB180704

5511G

2017-04-11 : On April 10, 2017 at

approximately 0556 hours while performing a GCP task in the

Live Hang Room, I observed less than Good Commercial

Practices.  When I walked into the room I noted a pile up of

birds (these birds were not decapitated) on the slatted

decapitation table that sits at the end of the live hang belt.  No

one was addressing the pile up of birds when I entered the

room.  I observed one breathing bird lying on this table located

at a point where the moving live hang belt was repeatedly

striking the bird.  

walked up to the table.  He began removing the birds from the

table and placing the birds on the floor.  Twenty one (21) birds

were removed from the table.  As the birds were removed, I

observed one breathing bird located at the bottom of the pile,

lying on its back.  The bird’s head had falling down between the

slatted bars of the decapitation table.  I showed these birds to

.  I notified 

, 

 and 

 of the forthcoming MOI.  This issue has been

discussed with plant management on multiple occasions.  1. 

As documented in the weekly meeting dated 1-27-17, I

discussed with ,

and on 1-23-17 at

approximately 0535 hours, the issue of allowing birds to pile up

on the slatted decapitation table next to the moving live hang

belt.  2.  As documented in the weekly meeting dated 2-17-17,

at approximately 0550 hours, I discussed with 

 the observation at 0541

hours by of a pile of birds at the end of the

live hang table next to the metal grate.   observed

one bird lying on its back trying to right itself as birds were

piling on top of this bird.  She immediately notified 

, and lifted the

bird upright.  3.  As documented in the weekly meeting dated

2-24-17, on 2-23-17 at approximately 0539 hours, I had a

meeting with

 and 

 concerning birds piling up at the end of the live

(b) (6)

(b) (6)

(b) (6)

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

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

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 83

EstNbr EstName Task_Code MOI# Date Description

hang belt.    Two live birds were observed on their backs unable

to right themselves as other birds were beginning to pile up on

these birds at the end of the moving live hang belt.      4.  On

2-28-17, at 0707 hours I discussed with 

 and Mr. Kevin Montgomery, First Shift

Plant Manger, birds piled up on the table at the end of the

rehang belt with one bird lying on its back.  Mr. Montgomery

stated a meeting on animal welfare would be conducted at the

end of the day and promised this issue would be corrected.     

As per Federal Register Notice Docket No. 04-037N dated

September 28, 2005, “Treatment of Live Poultry before

Slaughter,” the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines. Respectively, Cc Mr.

Don Coley, DDM 

(b) (6)

(b) (6) (b) (6)
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EstNbr EstName Task_Code MOI# Date Description

P522 Sanderson

Farms, Inc.

(Processing Div)

. IKB581805

5025G

2017-05-25 The following less than good commercial practices were

observed yesterday at P-522, Sanderson Farms, Collins,

Mississippi: I was informed by my CSIs that the picking line was

down, so I proceeded to the live hang area to observe the

condition of the live birds. Upon entering the live hang area at

approximately 1412 hours, I observed that the outside line was

not moving and there were no birds in the shackles on that line

in live hang. There were approximately 15 dead birds on the

metal table at the end of the line. Within the pile of dead birds I

observed a live bird: The head of the bird was buried beneath

dead birds, but the vent area of the bird was clearly moving in

and out in a rhythmic manner as the bird breathed. 

, was notified of this finding and

informed that live birds buried beneath dead birds may

suffocate, dying from means other than slaughter. This issue

was discussed at second-shift weekly meetings with the

establishment on 1/20/17, 2/2/17, 2/10/17, 4/7/17, 4/21/17,

and 5/4/17. Additionally, Good Commercial Practice MOI's have

been issued for this same problem on 4/11/17 (First Shift) and

2/2/17 (Second Shift). I proceeded to the platform adjacent to

the dumper, where I observed that most of the shackles were

empty. However, there were still live birds hanging in the

shackles in three locations (at the time of my observation the

birds had been hanging on the line for approximately 10

minutes): There were two live birds (one of which was hanging

by one leg only) suspended in the shackles beneath the

push-down bar. I asked area employees why these birds had not

been removed from the line and they stated that the birds could

not be removed from the line because the metal bar was in the

way. There were 2 live birds suspended in the shackles near

where the line makes the first a 90-degree turn as it exits live

hang and proceeds towards the stunner. I asked the employees

why these birds had not been removed since there was nothing

obvious obstructing access to these birds. Area employees

stated that the birds were stuck and could not be removed from

the shackles. There were 10-15 live birds suspended in the

shackles above the catwalk, located just prior to the entrance to

the stunner. I immediately notified 

and ,

of my findings. I proceeded to the front office and informed

(b) (6)

, of my findings, and asked if the

(b) (6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 85

EstNbr EstName Task_Code MOI# Date Description

establishment’s animal welfare program includes a protocol for

dealing with live birds in the shackles in the event of a line

stoppage. stated that live birds were to be

removed from the line in the event of a line stoppage. This

issue was previously discussed at the weekly meeting 3/2/17, at

which time stated that birds are to be removed

from the line in the event of a breakdown lasting more than 3-4

minutes. I subsequently reviewed the establishment’s written

animal welfare protocol titled, “Animal Welfare Plan for

Disruption of Processing” and confirmed that 

is included in the

protocol, although a time frame is not specified. The treatment

of live birds before slaughter is an important animal welfare

concern. Live birds buried beneath dead birds may suffer and/or

suffocate, dying by means other than slaughter. Live birds left

suspended upside down in the shackles for a prolonged period

of time in the event of a line stoppage may suffer and/or die;

this is especially true of birds improperly hung in the shackles or

birds that are already in a compromised state due to disease or

injury. Establishment management is encouraged to review

Federal Register Notice Docket No. 04-037N (dated September

28, 2005) for FSIS recommendations concerning treatment of

live poultry before slaughter. Establishments are strongly

encouraged to abide by Good Commercial Practices.   The

aforementioned observations were discussed today with 

. Respectfully, CC:

 

Mr. Don Coley, Deputy District Manager 

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

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

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

(b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 86

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P522 Sanderson

Farms, Inc.

(Processing Div)

. IKB341405

1526G

2017-05-26 Yesterday, May 25th, 2017, at approximately 2143 hours, I

observed the following at P-522, Sanderson Farms, in Collins,

Mississippi: The backup cutter on the outside line (the line

closest to the exit door) appeared to miss a live bird that had

itself been missed by the neck cutting machine. I exited the

area and went to the scalder entrance. I observed one live bird

enter the scalder on the outside line. Prior to entering the

scalder the bird was craning it’s neck, flapping it’s wings, and

appeared to be bright and alert. There was no evidence of blood

or a cut on the bird’s neck. I proceeded to the hot rehang area

of the evisceration department and observed a cadaver on Line

One at approximately 2154 hours. The bird was removed from

the line by an area employee and I inspected the carcass: It was

brick red and the head was swollen and fully attached. There

was no evidence of a cut on the neck. I immediately informed

Barry Sparks, Plant Manager, of my findings. Birds that enter

the scalder alive die by drowning rather than by slaughter.

Establishment management is encouraged to review Federal

Register Notice Docket No. 04-037N (dated September 28,

2005) for FSIS recommendations concerning treatment of live

poultry before slaughter. Establishments are strongly

encouraged to abide by Good Commercial Practices. Today,

May 26th, I discussed my findings with 

 Respectfully, CC: 

 Mr. Don

Coley, Deputy District Manager 

(b) (6)

(b) (6)(b) (6) (b) (6)
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P522 Sanderson

Farms, Inc.

(Processing Div)

. IKB521906

0430G

2017-06-30 The following less than good commercial practices were

observed today at P-522, Sanderson Farms, Collins, Mississippi: 

Upon entering the live hang area at approximately 1925 hours, I

observed that there were 15 carcasses on the metal table at the

end of the line. Within the pile of dead birds I observed one live

bird: The head of the bird was buried beneath dead birds, but

the side/breast area of the bird was clearly moving in and out in

a rhythmic manner as the bird breathed. 

 notified of this finding and informed that

live birds buried beneath dead birds may suffocate, dying from

means other than slaughter. extracted the live bird

from the pile and hung it on the line. The bird was clearly alive

as its eyes were open and it had normal muscle tone and head

movement. This issue was discussed at second-shift weekly

meetings with the establishment on 1/20/17, 2/2/17, 2/10/17,

4/7/17, 4/21/17, and 5/4/17. Additionally, Good Commercial

Practice MOI's have been issued for this same problem on

5/25/17 (Second Shift), 4/11/17 (First Shift) and 2/2/17 (Second

Shift). The treatment of live birds before slaughter is an

important animal welfare concern. Live birds buried beneath

dead birds may suffer and/or suffocate, dying by means other

than slaughter. Establishment management is encouraged to

review Federal Register Notice Docket No. 04-037N (dated

September 28, 2005) for FSIS recommendations concerning

treatment of live poultry before slaughter. Establishments are

strongly encouraged to abide by Good Commercial Practices. 

The aforementioned observations were discussed today with

. Respectfully, 

 CC:      

 Mr. Don Coley, DDM 

(b) (6)

(b) (6)

(b) (6) (b

) (b) (6)

(6)

(b) (6)
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EstNbr EstName Task_Code MOI# Date Description

P529 Gold'n Plump

Poultry, LLC

. ODE26110

62906G

2017-06-06 At approximately 1:10pm on June 5, 2017, while conducting a

Good Commercial Practices Task I, , was

looking in the DOA bin. I noticed that the belt that conveys

everything that falls out of the drawers was not operating. I

informed and . He

stated that he had maintenance look at the belt approximately

an hour before and they decided they would repair it after the

end of production. I got a flashlight and looked into the area

where the drawers were emptying out on the belt. I looked at it

from the front where the belt empties into the DOA bin and

from the top where the drawers emptied out. I noted a pile of

feces and feather and soil with a live, immobile chicken on top

of the pile. I asked how he would address live

birds falling into that area and possibly getting trapped.

 responded that he did not know how he

would address that issue. called

maintenance to fix the belt after removing and humanely

euthanizing the live bird at approximately 1:13pm. 

Maintenance got the belt running again at approximately

1:25pm. A pile approximately twelve inches deep of feces and

feathers and soil fell out onto the floor. Buried within that pile

of debris was approximately 6-8 chickens. All the chickens were

dead when they came out of the pile. I could not determine if

they were dead or alive when they dropped onto the pile.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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P529 Gold'n Plump

Poultry, LLC

. ODE25120

63529G

2017-06-29 At approximately 1320 on June 28, 2017, while performing a

Good Commercial Practices Task I noticed 17 cadavers were

marked on the lot tally sheets. There were 49.017 birds

scheduled to be slaughtered in that lot. At approximately 1325 I

discussed the number of cadavers with 

. I asked him why there were so many cadavers

and what he was going to do to ensure fewer cadavers. He

stated that while he was working as the back-up cutter he

noticed that the lot had a large variation in bird size causing the

kill machine to miss a larger than usual amount of birds. He said

when he was done working as the back-up cutter he raised the

kill machine up to try and compensate for the large variation.

He further stated that he would discuss a long-term plan with

his manager and discuss it with me later. At approximately

1350 met with me in the USDA office to

discuss his further plan. He stated that 

would send an e-mail to the live side operations

to request that the “runt” birds be culled by the live side before

being shipped to the plant. He also stated that when he notices

a large variation in bird size, and staffing is available, he will

station two back-up cutters after the kill machine. A similar

situation with increased cadavers on two days was discussed

during the USDA weekly meeting on June 6, 2017. This

discussion was documented in the MOI for that meeting. The

cause was attributed to lack of employee training for these two

days.

(b) (6)

(b) (6)

(b) (6)

Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 91

EstNbr EstName Task_Code MOI# Date Description

to be monitoring areas, watching for fallen birds, and assisting

the foreman when fallen birds are identified.  Birds are to be

retrieved at the time of identification.  The live haul foreman is

to be illuminating the areas with flashlight and assisting the

leads with retrieving birds before the trucks move. I notified 

and that this MOI would be forwarded to the

District Office and to the

 and should the need for

follow-up be recommended. Respectfully, 

 P544-Jennie-O Turkey

Store

(b) (6)

(b) (6)

(b) (6) (b) 

(b) (6) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 92

EstNbr EstName Task_Code MOI# Date Description

P544 Jennie-O Turkey

Store Sales

. KXJ590605

2502G

2017-05-02 United States Department of Agriculture Food Safety and

Inspection Service 123 S. 5th. Av. E. 

Melrose, MN. 56352 

                                                                                                      

           Date: 5/1/2017 TO: and 

FROM:  

 SUBJECT:  MOI-Good Commercial Practice     

At 0745 hours I was on the north side of the Hang and Kill bay

observing Good Commercial Practices. There were three trailers

staged to enter Hang and Kill. The trailer numbers were 9821,

1402 and 0706. All three trailers belonged to flock, 

which  is miles from the Jennie-O-Turkey Store,

Melrose facility. The outside temperature was 32 degrees and a

heavy mist, at the time of my Good Commercial Practices

observations. I observed the back of the three staged trailers

and noted that the back trailer axels and frame work was

packed with snow. The back coops were wet. The turkeys in the

back cages were wet, listless and shivering . The bottom 2 cages

that I could observe well had 1-3 DOAs per cage. There was no

panel protection on the back of the trailers. I observed the sides

of the three trailers which had staggered side panels in place.

The turkeys in the side cages were dry and the cages were drier

then the cages in the back of the trailer. I did not observe any

turkeys shivering in the cages on the trailer’s side. The back of

the trailers did not have any panels. It appears that during the

 mile haul from the farm to the Melrose facility that the

snow, mist swirled up behind the trailer and made the back

cages and turkeys wet and some of the turkeys were

hypothermic.      I demonstrated the three 

trailers to and 

 The two gentlemen said a

further investigation into the wet conditions of the back cages

of the trailers would be performed.      After I entered the

establishment I reviewed the DOA numbers for the 

. The numbers were: Trailer                  

DOAs                                             Trailer                 DOAs 

1304                        19                                                  

1101                    15 0706                 

      38                                                  1402                     47 1406  

                     20                                                   0705                      

5 9821                        13 The average number of DOAs per

(b) (6)

(b) 

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

(b) 

(6)

(b) (4)

(b) 

(4)

(b) 

(4)

(b) (4)

(b) (6) (b) (4)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 93

EstNbr EstName Task_Code MOI# Date Description

load for was 22.4 carcasses.        The next lot

of turkeys processed was from which is 

miles for the Jennie-O-Turkey, Melrose processing facility. The

average number of DOAs per load for was 2.75.

 were similar size birds to .

                Sincerely, 

P544 Jennie-O Turkey

Store Sales

. KXJ450405

2405G

2017-05-05 At approximately 3:10 I was down in the live hang area

observing Good Commercial Practices.  I saw the plant trying to

retrieve a live bird off the hoist before trying to pull an

empty trailer out of the live hang bay.  It took some time to get

the bird out.  When they got the bird out, the live hang lead

person checked for birds on the hoist from the front end of the

truck once more with the flashlight on the driver's side and once

more with the flashlight on the passenger's side before pulling

the truck out.  When the truck was pulled out, however, there

was a bird lying in the wheel tracks on the passenger's side at

the rear end of the hoist.  The bird was bloody and

was convulsing, revealing that it had just been run over. I met

with after the incident, and we initiated discussion

about preventive measures, such as: Ways to prevent birds from

getting down on the hoist where they can get run over, such as

by decreasing the space between the live hang mezzanines and

the live haul trailers. Ways to increase

personnel awareness about birds that do end up down on the

hoist so they can be retrieved without being run over, such as by

checking with the flashlights from both ends of the truck.

P544 Jennie-O Turkey

Store Sales

. KXJ280405

2831G

2017-05-31 While down in the live hang area doing ante mortem on a new

lot of birds, I observed a DOA carcass in the Condemned barrel

exhibiting signs of abuse, such as the skin over the breast of the

bird being torn open, fully exposing the breast meat.  I discussed

with ) that birds should not be

coming off the trucks looking abused like that, and that that

message should be relayed to the live hang and loading crew(s). 

Later I discussed the same with 

  He said he had already heard about my

conversation with , and that they were in agreement that

they don't want their birds being abused either. As of July 6, I

have not seen any more carcasses exhibiting such injuries.

(b) (6)

(b) (6)

(b) 

(6)

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

) 

(b) (4) (b) (4) (b) (4) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 94

EstNbr EstName Task_Code MOI# Date Description

P559 Tyson Foods,

Inc.

. UWC30200

64607G

2017-06-07 At approximately 18:40 hours while giving breaks to Food

Inspectors on Evisceration Line 1, had a bird

presented to him that had a rubber band around its body. The

band was located just behind the wings and encircled the entire

body. It was deeply embedded in the back and breast muscles.

Its long term presence was demonstrated by a heavy band of

fibrous scar tissue proximal and distal to the area where the

band had grown into the tissues. There was also a large area of

inflammatory tissue in the breast muscles proximal to the

banded area. This bird was from the same flock of birds as one

found on day shift with a rubber band similarly located around

its body. Plant is able to identify flock/grower from which this

bird originated.  The bird was turned over to Plant Manager Tim

Peters for his correlation with grow-out personnel. He stated

that this grower had recently replaced nipple waterers in the

house and the rubber bands probably dropped during their

installation.

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 95

EstNbr EstName Task_Code MOI# Date Description

P5787 Pilgrim's Pride

Corporation

. DEB051204

0805G

2017-04-05 On April 4, 2017 at approximately 1223 while performing a

Good Commercial Practices check in the live hang area, I

observed a bird on line that had been hung in the shackle

by both legs and its head. The plant employee immediately

stopped the line and the bird was removed.  The bird’s neck was

bleeding and it was dead.  This bird had died by means other

than slaughter.  During this Good Commercial Practices check I

also observed 2 birds had been hung by both legs in one shackle

and another bird hung by one leg.    When I located

 I informed him about the bird

I had observed that was hung by its head/neck as well as by

both feet resulting in the bird dying by means other than

slaughter.  Hanging any chicken by its head/neck is not

appropriate and USDA takes the humane handling of the

chickens very seriously.         told me

they were training about 4 new hires in the live hang area and

would go back there to see that they were moved to a part of

the line where more supervision would be given to their proper

hanging of the birds.  He assured me that he would make sure

they all understood that hanging any of the birds by the head

will not be tolerated.   This is a reminder that any mistreatment

of birds during processing is a major non-conformance.  A copy

of this MOI will be forwarded to and 

 in the Dallas

District Office and    

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

(b) 

(4)

(b) (6) (b) (6)
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EstNbr EstName Task_Code MOI# Date Description

P5787 Pilgrim's Pride

Corporation

. DEB071406

4228G

2017-06-28 On Wednesday June 28, 2017 at approximately 12:34 PM I was

in the live receiving area performing a Good Commercial

Practices task.  I noted one of the cages had been set aside and

several of the birds had blood on them.  I asked the 

, why the birds had fresh blood on

them and pointed out birds to be removed so that I could

determine which one was injured.  The first bird had fresh blood

on it but I ascertained it did not have any wounds.  The second

bird with blood on it had a severely bruised wing but again no

site for the bleeding was found.  However, the third bird they

removed was actively bleeding from a large gaping wound on its

left breast.  The skin had been torn away and was a hanging flap

of skin.  The wound was approximately 4 x 4 inches in

width/length. There were several plant employees including 

 and present but no one was

taking any steps to alleviate the pain and suffering of this

injured bird.  I then told them the injured bird needed to be

immediately euthanized to alleviate any further pain, suffering

and distress. The bird was still alive and not moribund.  The

plant then euthanized the bird.  I later spoke with 

 and about the

importance of taking action when they observe birds with blood

on them.  Also, that they needed to be more vigilant in the

future and take immediate action so that injured birds are not

left to suffer in pain and distress.       USDA expects all birds to

be treated in a manner that causes the least amount of distress,

discomfort and excitement.  It is expected that all plant

employees will use all due diligence to ensure birds are treated

in the least stressful manner possible.  Therefore, being

proactive in identifying possible instances where harm and or

distress/discomfort may be inflicted upon the birds should be

followed.    A copy of this MOI will be entered into PHIS,

forwarded to the Front Line Supervisor and the Dallas District

Veterinary Medical Specialist. P5787 

Natchitoches, LA

(b) (6)

(b) (6)

(b) 

(6)

(b) (6)

(b) (6) (b) (6)
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EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

. UIO551204

4725G

2017-04-25 At approximately 0530 hours on April 20, 2017, I spoke with

 regarding information that

 told me. She told me that

at approximately 0510 hours, she arrived in Live Hang to see live

hang employees cutting the necks of birds coming out of the

CO2 tunnel and putting them in the DOA bin. I asked 

how he ensured these birds were dead in the tank and he said

he couldn’t verify this information. I spoke with Plant Manager

Jody Long that day and the following day (April 21, 2017 during

the 1030 weekly meeting). Mr. Long looked into the issue and

told me that he looked at the video of the area and birds whose

necks were cut were obviously stiff and in rigor mortis. I

looked at the video with Mr. Long and on April 25,

2017 at approximately 0940 hours. The birds who were

obviously stiff and not moving were put in the DOA bin after a

neck cut. A conscious bird came out of the conveyer who was

sitting upright and occasionally flapping its wings. We saw an

employee reach for it with his knife and withdraw his knife

without cutting the bird. said that was when she

entered the area. Mr. Long said that employees know not to cut

conscious birds. The conscious bird was shackled and sent to the

electric stunner, to be slaughtered as the birds usually are.

P579 Jennie-O Turkey

Store Sales, Inc.

. UIO001406

4507G

2017-06-07 I spoke to at 0915 hours regarding

three cadavers that were presented to USDA inspection between

0800 and 0915 hours. The birds had dark purple splotchy skin

that extended up the neck and inadequate cuts to the neck. Two

of the three birds had only a skin cut without a neck muscle cut

and the third bird had a cut trachea without any neck muscle

cut. was notified about the inadequate cuts and

bleeding. told me at 0915 hours that the auto-killer

was adjusted to make a deeper cut, employees would check the

auto-killer at least , and the issues will be

addressed with the backup neck cutter.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)(b) (6) (b) (6) (b) (6) (b) (4)
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EstNbr EstName Task_Code MOI# Date Description

P579 Jennie-O Turkey

Store Sales, Inc.

. UIO490706

5613G

2017-06-13 While performing antemortem inspection this morning, I spoke

with at approximately 0405 hours

regarding a bird stuck in a truck cage door. This bird had his

head, part of his neck, part of a wing, and part of a leg stuck

outside the cage in a manner such that he could not pull these

body parts back in the cage. No swelling, bleeding, or abnormal

breathing patterns were observed. While this bird was loaded

poorly, the truck had been parked in the shed for some time

and had not been noticed by plant employees. and I

discussed Good Commercial Practice procedures. Not only was

this bird not secured in a manner that minimized discomfort,

this bird could potentially have had breathing difficulties or

severe bruising. USDA employees will continue to monitor the

holding sheds.

P6164A Foster Poultry

Farms

. OIJ580904

5305G

2017-04-05 On April 4, 2017, at approximately 0925 hrs, I, 

 of P6164A, while on a GCP inspection observed a

fully-awake bird hanging in the shackles, having passed the

automatic slitter and back-up slitter, passed the head puller, and

progressing toward the scalding tank Before entry into the

tank, , removed the bird

from the line.  Upon examination, I found the bird’s throat was

only superficially cut, insufficient for slaughter as the bird was

fully alert and ambulatory.  then returned the bird

to the live-hang belt-trough for re-hang. In a meeting

immediately thereafter with , I described the event

and my findings with .  

proposed some corrective actions.  I asked him to notify

me of the establishment's final corrective actions, when they

were complete.This event is associated with a similar awake and

un-cut bird on shackles event on February 21, 2017,

documented in the establishment meeting MOI of February 23,

2017.

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

(b) (6)

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

(b) 

(6)
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EstNbr EstName Task_Code MOI# Date Description

P646 JCG Foods of

Georgia, LLC

. XAA01230

50130G

2017-05-30 On May, 29, 2017 at approximately 1453 hours, 

 while performing good commercial practice task in the

live hang area observed team member pick up DOA from the

floor and throw it in the red bin.  The bin was full and the team

member began to pull it to be dumped in the offal drain.  As the

team member started to dump the bin she asked him to stop so

she could observe the birds in the bin.  The team member began

to hand pick up the birds one by one and throw them in the

drain.  Halfway down in the bin observed a live bird

breathing hard, this bird had dead birds piled on top of it and

would have been dumped in the drain alive.  This establishment

had a similar incident that occurred and had put in place that

they would remove the heads of birds prior to placing them in

the DOA bin, they failed to do this.  Their failure to remove the

heads prior to putting them in the DOA bin has been discussed

with management as recently as 2 weeks ago when they were

observed throwing them in the bin without removing their

heads.  The bird was removed from the red bin and hung on the

line to be slaughtered.  Management, specifically 

 and Johnny Center, the second shift

manger, was notified of their failure to comply with good

commercial practices.  They stated that they had a new

employee in live hang performing this job.  Mr. Center stated

that training would be completed with the supervisor

concerning putting new personnel on these duties.  The PPIA,

Agency Regulations, and Federal Register do require that live

poultry be handled in a manner that is consistent with good

commercial practices.  I notified Mr. Center that this issue would

be documented in a MOI and will be forwarded to the District

Office and the District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended.

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EstNbr EstName Task_Code MOI# Date Description

P6504 Peco Foods, Inc. . CHK33120

65809G

2017-06-09 At 1215 hours on Friday 9 June 2017 during a routine

antemortem check and GCP verification, the following issues

were discovered during the course of inspection: 1.)  The

individual in charge of the dumper was dumping birds too early,

leading to birds being dumped on top of birds on the transverse

belt.  This was the 3rd time I have witnessed this in 2 weeks. 

The establishment was warned about this behavior and was told

that all birds had to be off of the transverse belt before dumping

a fresh cage to minimize injury and violation of GCPs. 

Premature dumping can cause suffocation, broken wings,

broken legs, and bruising, which, unrelated or not, has been

seen in post-mortem inspection at an increased rate in the 3

weeks I have been detailed to this plant.  2.)  There was 1

trailer remaining in the holding sheds.  The fans were off

because maintenance was replacing the water nozzles.  It is

close to the hottest part of the day with the ambient

temperature being recorded by The Weather Channel at 80

degrees F. 3.)  The individual running the bar in live hang that

controls the advance of the belt allowed birds to back up at the

end of the belt.  One bird's head was stuck under the partition

at the end of the belt and was trapped between the rolling belt

and the partition while the belt was rolling and was left there

for several minutes until I drew the individual's attention to this

problem and he removed the bird.  Further, the individual

controlling the speed of the belt forcefully jerked the bird from

under the partition even while the belt was still rolling.  This

could be construed as "egregious."  The plant has been warned

about birds piling up at the end of the belt and being pulled

under and into the partition without being hung on the shackles

in a timely manner by me last week (the week of 28 May 2017).
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 101

EstNbr EstName Task_Code MOI# Date Description

P6505 Norman W.

Fries, Inc.

. BBA310805

4111G

2017-05-11 Est. P-6505, Norman W. Fries Inc.,May 10,2017, 1100 hours. In

attendance: , 

 At

approximately 1040 hours while performing A scheduled

Poultry Good Commercial Practices procedure in the Cage

Dump Area, I observed one live chicken with it's leg hung on the

right side of the Cage Dump Belt. The other birds were rolling off

this belt over this chicken. I also observed a dead chicken with

it's leg hung on the left side of the of the same belt. This bird

had been dead so long that it was stiff when removed from the

belt. I notified and of this finding.I

reminded and that the PPIA and the

Agency regulations do require that live poultry be handled in a

manner that is consistent with good commercial

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

than slaughter

P6505 Norman W.

Fries, Inc.

. BBA280805

5011G

2017-05-11 Est. P6505, Norman W. Fries Inc., May 10, 2017, 1040 hours. In

attendance:

 At approximately 1040 hours, while performing

a routine Poultry Good Commercial Practices, and

myself observed a chicken with it's leg hung on the right side of

the Cage Dump Belt. This was causing the other chickens to

travel over this chicken. I informed of this finding. I

reminded that PPIA and Agency regulations do

require that live poultry be handled in a manner that is

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

not die from causes other than slaughter. I informed 

and that I would be documenting this

incident on an MOI. At approximately

1300 hours, I was informed that repairs had been made to the

Cage Dump Chute to prevent the chickens from getting their

legs caught at the edge of the belt. also informed

me that he had ordered two mirrors that will be hung to enable

the operators to check the belt to ensure no birds were hung in

the future.

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EstNbr EstName Task_Code MOI# Date Description

P6651 Tyson Foods Inc. . MSO01180

54409G

2017-05-09 On Tuesday May 9, 2017 at approximately 1423 hour while

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed a large (approximately two foot) pile

of feathers and filth densely packed at the end of the live hang

belt leading to the dead on arrival transfer belt.  Last night I

spoke with a supervisor after finding a live bird in this pile and

expressed my concern that this could lead to birds becoming

crushed and dying by means other than slaughter which would

result in a Good Commercial Practices MOI.  This area needed to

be kept free of debris to prevent birds from being trapped in

debris and becoming crushed/suffocating.  Today when I saw

the pile of debris I again expressed my concerns to the live hang

supervisor at which time I was told that it would be cleaned out

at break time.  I took my flash light and looked closer and saw a

breathing bird buried in the feathers and filth that was in

imminent danger of dying by suffocation.  I notified the

supervisor that there was a live bird in the pile and it needed to

be cleaned immediately.  The supervisor and an additional

employee cleaned out about half of the pile and a second live

bird was removed from deep in the debris.  I checked the pile

again and there was a third live/breathing bird towards the

bottom of the pile that I asked them to get out as well.   I had

them remove the rest of the debris under the belt to verify there

were no more live birds in the pile.  I explained at this time that

the USDA FSIS takes treatment of birds prior to slaughter very

seriously.  If the birds would have been allowed to remain in the

pile of debris until it was cleaned out at break they would have

died by means other than slaughter, which is unacceptable. 

This area needs to be cleaned and monitored for live birds at all

times.  Once the incident occurred today supervision was

informed that an MOI would result from these issues. As per

Federal Register Notice Docket No. 04-037N dated September

28, 2005, Treatment of Live Poultry before Slaughter, the Food

Safety Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of poultry to make

every effort to treat poultry humanely and abide by the Good

Commercial Practices (GCPs) as described by industry

guidelines. My observations are consistent with less than good

commercial practices. A copy of this Memorandum of

Interview will be forwarded to appropriate personnel in the

District Office. Respectfully submitted on May 9, 2017. 

(b

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Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 104

EstNbr EstName Task_Code MOI# Date Description

 Cc: Dr. David Thompson, DDM 

 

P6651 Tyson Foods Inc. . MSO18210

62528G

2017-06-28 On Wednesday June 28, 2017 at approximately 1931 hour

while performing an Ante Mortem inspection and a Good

Commercial Practice Check with ,

I observed a live bird intermingled in a pile with six other dead

birds at the end of the belt that exits the live hang area.  An

additional large dead bird exited the belt landing on top of the

live bird pinning it in the pile of dead birds putting it in

imminent danger of becoming crushed/suffocating and dying by

means other than slaughter.  The establishment employee that

normally disposes of the dead birds and monitors for any live

birds walked by the pile, glanced over and continued to walk

into live hang with the door closing behind him.  Shortly

thereafter was walking by

the area about to exit to the live dock area when I motioned for

him and pointed out the live bird under the dead ones in the

pile.  He retrieved the live bird and put it back into production. 

A meeting was held with at that time

discussing Good Commercial Practices in depth.  I explained that

live birds should not comingle with the DOA birds as this puts

them at risk for suffocation / becoming crushed.  Once the

incident occurred was informed that an

MOI would be issued. As per Federal Register Notice Docket

No. 04-037N dated September 28, 2005, Treatment of Live

Poultry before Slaughter, the Food Safety Inspection Service

(FSIS) strongly encourages all establishments engaged in the

slaughter of poultry to make every effort to treat poultry

humanely and abide by the Good Commercial Practices (GCPs)

as described by industry guidelines. My observations are

consistent with less than good commercial practices. A copy of

this Memorandum of Interview will be forwarded to appropriate

personnel in the District Office. Respectfully submitted on June

28, 2017. Cc: Dr. Larry Davis, DDM 

Mr. Donald Coley, DDM 

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Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 105

EstNbr EstName Task_Code MOI# Date Description

P6666 Koch Foods of

Gadsden, LLC

. GQH56120

53631G

2017-05-31 On Tuesday May 16, 2017 while performing an Ante Mortem

inspection and a Good Commercial Practice Check, I observed

several incidents of unacceptable bird handling/mistreatment.

At approximately 0009 I entered the live hang area; 

 had been present as well.  There is a metal plate

preset that dead on arrival birds roll under to become separated

from the live birds that get hung on the shackles. Live birds were

piling up at the end of the first belt that feeds evisceration lines

one and two. The birds were continually rolling under the metal

plate as well as over the top of the plate. On several instances

legs, wings and heads would get hung under the plate. The belt

operator continued to move the belt forward despite a pile of

birds being present and pressed up against the plate. The

Supervisor lowered the speed of the belt two different times.

After each time the birds were still piling at the end of the belt.

During these observations three completely flattened/crushed

and blood soaked dead birds came in over an approximately ten

minute period. After the third bird was seen and the birds were

no longer piling at the end of the belt I went to observe the

dump cage area to try to determine the cause of the crushed

birds. The establishment employee that was operating this

particular dump cage was the same one that was leaving birds

in cages and soaking them with the water pressure hoses that in

part resulted in the Good Commercial Practice Memorandum of

Interview GQH0812054831 issued the previous night’s shift. At

approximately 0024, the first cage that was observed to be

dumped, I observed a bird get crushed under the cage. Once the

cage was automatically moved back away from the belt bringing

birds into the establishment there was a bloody, badly injured

bird that had been crushed under the cage. The operator went

out to the bird, attempted to cervically dislocate the bird and

threw it from the dump cage stage to a condemned barrel that

was on the ground. I asked the operator to not dump any more

cages and to please get his supervisor. came

out to meet me and I informed him of the incident, explained to

him this was again unacceptable treatment of birds and that I

was going to apply a Tag not to let the employee operate any

further and we needed to have a meeting in the USDA office. I

applied U.S. rejected Tag B3802788 at approximately 0026. At

0028 I observed the bird that had been thrown into the

condemned barrel and it was still breathing. I looked up to the

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Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 106

EstNbr EstName Task_Code MOI# Date Description

catwalk where the Supervisor was still present and informed

him that the bird was still alive. The dump cage operator then

stated that he had, “broke its neck.”  This was the only bird

present in the barrel, I reached in the barrel, felt the bird’s chest

and then again notified the Supervisor that the bird is alive, it

was breathing and had a heartbeat. I also asked if they could

please humanely euthanize the bird. The employee then came

down and manually decapitated the bird. A meeting was then

held with establishment

 and at approximately 0037 hour.

The incident, the gravity of the situation and that further

documentation would occur were explained during the meeting.

The proposed corrective actions were that the employee would

be suspended, retrained on animal welfare issues prior to being

allowed to return to work and a back-up operator would be

utilized. Maintenance would also fabricate a slide to prevent

birds from being able to climb back onto the stage where the

cages are moved as the second dump cage stage has that could

likely be started in the morning. I informed them that I would

remove the Tag when a new employee was in place and observe

operations. The Rejected Tag was removed at approximately

0052. As per Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live Poultry before

Slaughter,” the Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the slaughter of

poultry to make every effort to treat poultry humanely and

abide by the Good Commercial Practices (GCPs) as described by

industry guidelines. My observations are consistent with less

than good commercial practices. A copy of this Memorandum

of Interview will be forwarded to appropriate personnel in the

District Office.  

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Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 107

EstNbr EstName Task_Code MOI# Date Description

P6666 Koch Foods of

Gadsden, LLC

. GQH08120

54831G

2017-05-31 On Sunday May 14, 2017 at approximately 2350 hour while

performing an Ante Mortem inspection and a Good Commercial

Practice Check, I observed a weak moribund dorsally recumbent

bird with shallow respirations in an empty cage loaded onto a

trailer that was full of other empty cages. Additionally the bird

had deep lacerations to each of its digits on its right limb.  The

bird appeared to be suffering and in danger of dying by means

other than slaughter due to its weak condition.  At that time I

asked , who had been with me, to get a

supervisor.  came to the trailer where

the bird was located.  I explained at this time that this was

unacceptable to leave a bird in a cage and for birds to die by

means other than slaughter, I also pointed out the severe injury

to the birds digits and let know that USDA FSIS

takes mistreatment of birds very seriously.  I also notified him

that there had been three loose birds in the yard with fork lift

drivers driving around and USDA had to search for an

establishment employee to come catch the birds, this could lead

to birds becoming crushed. There was also a fourth bird loose in

the trailer holding shed.   At approximately 0010 hours while

observing the dump cages, an additional bird was seen that had

been left in a cage on the dump cage platform.  Once the cages

are dumped they are then sprayed out with high pressure water

to clean them prior to being automatically moved to the end of

the platform where they are picked up by the forklift.  The bird

that had been left in the cage had been sprayed with the

pressurized water and the doors to the cages had been closed;

the cage was being moved to the end of the platform to be

picked up by the forklift and none of the establishment

employees had seen the bird.  At that time USDA waved at the

dump cage operator and asked him to stop what he was doing

and notified him that a bird was still in the cage.  The employee

got the bird from the cage and returned it to production.  

again got .  I informed him of the

incident and this was at this point was going to result in an MOI

and potentially further action if bird mistreatment continued to

occur.  An additional GCP check was done at approximately

0135, at 0139 myself and were standing on the

catwalk observing the same cage dump region, with the same

operator working, where the previous incident occurred and

again a bird was left in the cage, went unnoticed by both the

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Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 108

EstNbr EstName Task_Code MOI# Date Description

cage dump operator and the supervisor and was drenched with

water by the pressure hose.  I immediately told the supervisor

and showed him the bird.  He had the dump cage operator

remove the bird and place it back into production.  I asked the

operator to stop dumping the cages while I filled out U.S.

Rejected Tag B38027087, I had to walk down the stairs of the

catwalk, around the outside of the cage dump stage and up

another set of stairs to apply the tag; while doing this the

operator dumped an additional cage after being informed to no

longer do so in front of supervision.  The tag was applied at

0144 and he was again told to no longer operate nor remove

the tag.  Supervision was told to meet with me in the USDA

office when they had corrective actions to resume operations to

prevent reoccurrence.  A meeting was held with the following

establishment and

.  I was told that an additional employee would

be stationed to the side of the dump cages as a temporary

corrective measure to monitor for birds left in cages until lights

could be installed over the cages which could possibly be done

in the morning.  I told them that we could try these measures

and see if they would work but this could not continue to

happen and I would remove the Rejected Tag.  The tag was

removed at approximately 0210.  After removing the tag, which

occurred during lunch break I walked through live hang.  Where

the second belt from the far dump cage, there are two, enters

the building the protective rubber flap that prevents the birds

from getting into the belt gears was bent away there was a live

bird tucked under the belt in between the gears that was at risk

of being crushed when the belt was restarted.  Additionally at

the end of the belt there were 12 dead birds with two additional

live birds in the pile at the very end of the belt.  There were not

any establishment employees or any supervisors in the area.  I

immediately went to the supervisor’s office to find 

 at approximately 0216 and asked him to accompany me

to the area to show him these situations.  I informed him that

the protective cover to the belt/gears must be fixed prior to

resuming production after lunch break.  He had already been

informed earlier in the evening that live birds could not

intermingle with dead birds.  At approximately 0309 

 informed me that the belts covers had been fixed, I

observed the corrective actions.  Metal plates had been put up

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Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 109

EstNbr EstName Task_Code MOI# Date Description

in place of the previous rubber ones, production resumed at

approximately 0310. was verbally informed

that due to birds being repeatedly mistreated by establishment

personnel, the incidents described above occurring in such a

short period of time, Supervision not reacting and correcting the

bird handling/mistreatment, the establishments equipment in

disrepair that could have caused further injury to birds, as well

as live birds comingling with dead birds that formal

documentation would occur. As per Federal Register Notice

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

Live Poultry before Slaughter,” the Food Safety Inspection

Service (FSIS) strongly encourages all establishments engaged in

the slaughter of poultry to make every effort to treat poultry

humanely and abide by the Good Commercial Practices (GCPs)

as described by industry guidelines. My observations are

consistent with less than good commercial practices. A copy of

this Memorandum of Interview will be forwarded to appropriate

personnel in the District Office. Respectfully submitted, 

(b) (6)

(b

) 

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Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 110

EstNbr EstName Task_Code MOI# Date Description

P727 Simmons

Prepared Foods,

Inc.

. VCF321305

2902G

2017-05-02 On May 2, 2017, at approximately 11:00 hours, 

, met with 

  The following is a synopsis of the discussion

and events regarding not slaughtering in accordance with good

commercial practices:  At approximately 06:35 hours while

attempting to find to determine the reason for early

break, observed maintenance personnel in the hanging

room. While looking for in the live hang area, I

observed that birds and carcasses had been left on the line for

Kill Line 2. As I observed the live birds/carcasses, I observed the

establishment had performed kill cuts on carcasses between the

end of the guide bar for the heads/necks and as far as they

could reach toward the stunner (approximately 6 carcasses). I

observed four carcasses that were in the neck/head guide bar.

The carcasses appeared stunned with no kill cut across their

neck. As I continued observing, I observed approximately 20

birds in the stunner. After  waiting an appropriate amount of

time in which the carcasses should have regained consciousness

and observing no breathing, I requested . After testing

to determine if the carcass was responsive to stimuli,  the

carcasses were removed from the line. Three of the four

carcasses were deceased with the fourth (which was in the

widest part of the guide bar) resumed breathing and regained

consciousness upon removal.  Based on my professional

experience, knowledge, and observations, the carcasses most

likely asphyxiated from the neck/head guide bar. Then, I

informed that allowing carcasses to asphyxiate is not

consistent with being slaughtered in accordance with good

commercial practices. informed me repeatedly that

the line broke down and inquired about how they were

supposed to prevent unanticipated equipment breakdowns. I

informed that carcasses must be slaughtered in

accordance with good commercial practices and although

equipment breakdowns cannot be anticipated, we still cannot

allow carcasses to die by asphyxiation or other methods

inconsistent with good commercial practices.  At approximately

07:05 hours, the establishment resumed production on Kill Line

1 as company break had ended. I observed that a large number

of birds were fluttering as they approached the kill machine and

after passing through the kill machine. The establishment had

two back-up killers present which were struggling to perform kill

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Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 111

EstNbr EstName Task_Code MOI# Date Description

cuts on the carcasses. This indicated to me based on my

professional knowledge and experience that the stunner had not

been turned on.  The establishment immediately corrected

and was later confirmed by establishment management.  Once

the line was repaired (approximately 40 minutes after the

malfunction of the kill line), the carcasses from the stunner were

removed from the line and disposed of via condemn barrels. At

approximately 11:00 hours, I met with and informed

him that birds must be slaughtered in accordance with good

commercial practices. My observations indicated that they had

not and that I was issuing an MOI documenting our discussion. 

At this time, I also discussed my observations regarding the

carcasses that appeared to enter the kill machine without being

stunned.   verbally informed me of plans to prevent

recurrence and I requested those plans in writing. A verbal

synopsis of the actions that will be taken when a Kill line

malfunctions were: stunners turned off, birds removed to

prevent drowning/persistent stunning, and kill cuts will be

performed on birds within the head/neck guide bar to prevent

asphyxiation. The meeting was adjourned at approximately

11:10 hours.

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EstNbr EstName Task_Code MOI# Date Description

P727 Simmons

Prepared Foods,

Inc.

. VCF240906

3529G

2017-06-29 On June 26, 2017, at approximately 07:15 hours

 and 

 met with .  

The following is a synopsis of the discussion regarding cervical

dislocation and the establishment’s animal welfare plan. 

 reviewed the animal welfare plan for the procedure

regarding cervical dislocation. The animal welfare plan states

the thumb and index finger will be placed at the back of the

skull and the legs are quickly pulled with the other hand. 

expressed concern about whether this was the method

that the employees were utilizing. inquired about

where the method was acquired from was informed

that procedure was adapted from live haul. informed

 and that they appear to pull more on the

neck than the legs and sometimes will twist the neck resulting

in decapitation of the bird. informed establishment

management that two or three birds were decapitated while

attempting to perform cervical dislocation.  There wereseveral

others (approximately 5-6) that had severe fluttering of the

body muscles for greater than 30 seconds as they traveled down

the conveyor. The establishment informed me that they would

perform retraining of personnel that perform cervical dislocation

to ensure that the procedure is being implemented as written. 

The meeting was adjourned at approximately 07:35 hours.

P7470 Mountaire

Farms Inc. - NC

Division

. YRA241606

3414G

2017-06-14 While observing the plants GCPs at 16:16 I observed a live bird

in the dead on arrival bird bin half way buried. The bird looked

distressed at the time.  I informed 

 of my findings. He immediately removed the live

bird from the bin.  The cause was determined to be that the

dead on arrival belt monitor left his station for a moment and

the line running. 

added an additional monitor to the system to prevent

any future occurrence.

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EstNbr EstName Task_Code MOI# Date Description

P764 Perdue Foods,

LLC

. CUA40130

42910G

2017-04-10 At 1057, while touring the picking room, I was observing birds

enter the scalder and noticed a bird with its head flexed towards

me.  This is abnormal, as all of the other birds (that had been cut

and bled out properly) had their heads and necks fully extended

and dangling freely.  There was no obvious neck cut; however,

the cut would have been on the side furthest away from me and

I cannot be absolutely certain there was no cut.  I was able to

briefly touch this bird's head and it looked at me consciously

and applied some resistance to my touch before it then entered

the scalder.  I had no time to intervene.  I immediately notified

 and , who were nearby.  At

1405, I had a meeting with )

and

 We discussed the above incident.  They told me they

will do retraining of the backup killers and other receiving team

employees.

P764 Perdue Foods,

LLC

. CUA17130

50211G

2017-05-11 During a walk-through with the Raleigh District Office DVMS,

both stunners (one on each kill line) were observed to be full of

water with birds hanging above and heads/necks submerged in

the electrified water.  The twenty or so birds in each stunner

were observed to be lifeless and got that way as a result of

asphyxiation instead of proper slaughter.  Upon recognizing that

the situation existed, a plant employee opened the valve on the

stunner to lower the water level.  

was informed in the

receiving office at approximately 12:30 pm and indicated that

appropriate disciplinary action would be taken for poor job

performance.  

was later informed of the incident in the main hallway of the

plant.  He indicated that this condition was handled

appropriately several other times during the day, but this time it

was overlooked. I have provided plant management with a copy

of the Federal Register Notice 04-037N, “Treatment of Live

Poultry before Slaughter.”   This information can assist the

establishment in considering means of assessing and improving

their handling and slaughter procedures, by adopting a

systematic approach which focuses on treating poultry in a

manner that minimizes excitement, discomfort, and accidental

injury during the entire time that live poultry are held for

slaughter.

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(b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 114

EstNbr EstName Task_Code MOI# Date Description

P7669 Turkey Valley

Farms LLC

. RZB250505

1723G

2017-05-23 Est. 7669p, Turkey Valley Farms, May 25th, 2017. In

attendance: and Steve Seward,

General Manager On Monday 5/15/17 I observed that the

breeder hen lot from Missouri had 118 out of 5184 head

Dead-On-Arrival (2.28%). During the weekly meeting on 5/18/17

the establishment was notified of this finding and Mr. Seward

emailed me on Friday stating that there were storms in Missouri

(as well as Marshall, MN) the evening that the birds we loaded

and traveling. He stated that he firmly believes the high DOA

rate on Monday can be attributed to the storms seeing that

birds came from the same flock on Tuesday and Wednesday

with no DOA issues. I reviewed the last 5 months of PHIS

information (January 1, 2017- May 25, 2017). There were 14

lots with DOA counts exceeding 1% of which 9 instances were

breeder hens from various growers in Missouri, 2 were from the

same flock of light hens from Nebraska, and the remaining 3

flocks were from Minnesota. During weekly meeting

discussions, Mr. Seward informed USDA that the high counts

were due to inclement weather. The following DOA counts were

observed: 1/5/17: 5 out of 256 (1.95%) breeder toms from

Minnesota 1/9/17: 160 out of 9,966 (1.61%) breeder hens from

Missouri * 1/27/17: 177 out of 5,760 (3.07%) breeder hens

from Missouri 2/3/17: 449 out of 38,368 (1.17%) light hens

from Nebraska 2/8/17: 86 out of 7,018 (1.23%) breeder hens

from Minnesota 2/9/17: 639 out of 34,772 (1.84%) light hens

from Nebraska 3/9/17: 273 out of 4,999 (5.46%) breeder hens

from Missouri 3/14/17: 39 out of 252 (15.47%) breeder toms

from Minnesota 3/20/17: 111 out of 8,154 (1.36%) breeder

hens from Missouri * 3/27/17: 137 out of 8,043 (1.70%)

breeder hens from Missouri* 4/10/17: 223 out of 10,766

(2.07%) breeder hens from Missouri * 4/26/17: 101 out of

6,704 (1.50%) breeder hens from Missouri 5/15/17: 118 out of

5,184 (2.28%) breeder hens from Missouri * 5/25/17: 106 out

of 4,346 (2.44%) breeder hens from Missouri On 5/25/17, a

discussion with Mr. Seward was held. I informed him of the

above dates and DOA numbers. He notified me that he has

observed that the majority of issues are from flocks slaughtered

on a Monday, these have been marked with (*) on the list. We

discussed updating the GCP paneling procedures and

conducting training for semi-drivers. Mr. Seward informed me

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 115

EstNbr EstName Task_Code MOI# Date Description

that he would look to modifying their scheduling due to time of

loading and/or inclement weather forecast.

 
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 116

EstNbr EstName Task_Code MOI# Date Description

P855 Pilgrim's Pride

Corporation

. FDA53230

43327G

2017-04-27 Est. P855, Pilgrims Corporation, USDA Office, April 27, 2017,

10:47 PM. In attendance: 

 On 4/27/17 at approximately 2:30 AM during the

performance of a routine SPS task I observed

a pile of commingled live and dead birds at the doorway to the

live hang room on the L1 side, piled several birds high and

approximately 6x6 feet in area. It did not appear the live birds

were being smothered or suffocated, although they were unable

to move around freely.   was

picking up and throwing away dead birds. I left and attempted

to find  to notify her of the situation. I was unable to

locate her and decided to check the L2 side of the live hang

room. At approximately 2:40, observed birds being

piled too high in the dumper cages, to the extent that birds

were nearly touching the top of the cages. She informed 

 of this and at that time observed the pile of birds on the

floor on live hang Line 1. She left to inform of this

Good Commercial Practice violation.   At approximately 2:41

AM I observed another much more extensive pile of

commingled live and dead birds on the Line 2 side of the live

hang area, several birds high and extending from the wall on the

right all the way to the entrance to the door. I observed

breathing live birds in the pile underneath dead birds. Their

breathing appeared labored and difficult. While I did not

observe suffocated cyanotic birds, the amount of dead birds in

the pile was so excessive as to create the potential conditions

that lend themselves to smothering and/or suffocation. There

were no establishment employees picking up birds on this side.

 At 2:42 AM I took immediate regulatory control action and

informed that they would need to stop hanging

on Line 2 until the situation was corrected and the birds were

picked up off of the floor. Hanging was stopped and live birds

were sorted from dead birds, which were thrown away.  I

observed incidents in which two undersized birds were picked

up from above, being grabbed over the wings and neck area

with a single hand instead of by the leg and then tossed onto

the belt. I informed of these

incidents at this time. Once the birds were picked up off the

floor and humane conditions restored I released the line at

approximately 2:47 AM. Inspection stated that while (b) (6)

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

(b) (6)

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

(6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 117

EstNbr EstName Task_Code MOI# Date Description

was in the process of picking up the dead birds, the fact

that the birds were piled up to the point of commingling dead

and live birds is an indicator that the process is out of control.

Employing humane methods of handling consistent with Good

Commercial Practice can help produce unadulterated product. 

Plant Response stated that while they want to

keep the lines full, humane handling procedures and good

commercial practices are a priority. He stated that there is

usually a person assigned to pick dead birds off the floor but

they have had issues with staffing. 

has been instructed that when shorthanded hangers

should be pulled off of the line to pick up dead birds.  The

proposed corrective action is to add an additional responsibility

to the SSOP for live hangers. Live hangers already rotate

positions on the hanging line , wherein the first

hanger on the line rotates to the last position. The proposed

modification for the SSOP would add a responsibility to pick up

dead birds off of the floor during the rotation before returning

to the line. This modification will require corporate approval to

become formalized but the establishment has already

implemented this procedure within the live hang department.   

With regard to the mishandling of the undersized birds

 stated that he did not believe that the birds were being

mishandled, as they were not grabbed by the wings or necks

themselves. He made available the Pilgrims Corporation Animal

Welfare Procedures Training, 2016 Revision.

(b) (6)

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

(b) 

(6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 118

EstNbr EstName Task_Code MOI# Date Description

P9197 Perdue Foods,

LLC. Woodville,

NC Plant

. UAB59120

43612G

2017-04-12 At approximately 0845 hours while performing Good

Commercial Practices (GCPs) with ; in the live

hang room we observed an establishment’s associate throw one

live bird from the floor onto the incoming conveyor belt.

Unfortunately, I was unable to stop the employee from

throwing the bird; however I discussed with the associate not to

throw birds onto the conveyor belt. I was unable to determine if

the bird suffered any ill effects. I notified 

and of the issue. 

 counseled the employee on humanely handling

birds according to the establishment’s poultry welfare

procedures. At approximately 1030 hours, 

performed a follow-up GCPs task and she observed an

establishment’s associate pick up ten live birds and properly

placed them on the conveyor belt. A copy of this compliant has

been sent to the 

 and .

(b) (6)

(b) (6)

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

(b) (6)

(b) (6)

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 119

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

. YXA551604

3613G

2017-04-13 At approximately 1437 hours inspection personnel on line 1,

station 2 and station 3 notified me that they held back 1 carcass

each for final disposition.  Upon examination I observed the skin

and neck of both carcasses to be cherry red and petechiation of

the breast muscles.  The carcasses were condemned and

documented as cadavers.  

was notified and observed the cadavers.  had

establishment personnel make adjustments to the kill blade.  

At approximately 1600 hours while traveling to line 1, to

provide inspection breaks, the inspector at station 2 notified me

of 2 carcasses and the inspector at station 3 notified me of 1

carcass being held for final disposition.  Upon Examination I

observed the skin and neck of the 3 carcasses to be cherry red

and petechiation of the breast muscles.  The carcasses were

condemned and documented as cadavers.  At approximately

1650 hours the inspectors on line 1, station 2 and station 3

notified me of 2 additional carcasses (1 at each station) being

held for final disposition.  Upon examination I observed the skin

and neck to be cherry red and petechiation of the breast

muscles of both carcasses.  These carcasses were condemned

and documented as cadavers.  I then went to the kill line to

investigate further.  The establishment’s back-up kill employee

on the large bird line was having trouble keeping up with the

number of birds that were missing the kill blade.  I then traveled

further down the kill line where an additional back-up kill

employee is usually stationed however; there was no employee

in place.  As I was observing the birds moving down the line, I

observed 1 bird with its head raised and eyes blinking, which

had missed the kill blade and the back-up kill employee had also

failed to exsanguinate the bird.  

 appeared beside me and I showed him the live

bird traveling toward the scalders.  

 and I went to the entrance of the

scalder.  When the live bird appeared attempted to

remove the bird but was unable to unseat its legs from the

shackles.  called over the radio for the line to be

stopped however the live bird was partially submerged into the

scalder as the line stopped.  removed the bird

from the line plus an additional live bird (head raised, eyes open

and blinking and no cut to the neck) that had not entered the

scalder.  I notified and 

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

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

(6)

(b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 120

EstNbr EstName Task_Code MOI# Date Description

 of the cadavers observed at post

mortem inspection and the observation of a live bird entering

the scalder.  In response, management replaced the back-up kill

personnel and added an extra back-up kill employee to the large

bird kill line.  At approximately 1800 hours (start of lunch

break), inspection personnel on line 1, station 2 and station 4

notified me that they held back 1 carcass each for final

disposition.  Upon Examination I observed the skin and neck of

the station 2 carcass to be cherry red and the carcass at station

4 body, neck and head were cherry red with no cut to the neck. 

These 2 cadavers were identified during the time that

establishment management was initiating corrective measure

for the live bird entering the scalder. At approximately 1900

hours I returned to the kill line and verified that the corrective

measure was in place.  No live birds were observed entering the

scalder.  It is recommended that establishment management

review the Federal Register on “Treatment of Live Poultry before

Slaughter”, published September 2005 for FSIS

recommendations concerning treatment of live poultry prior to

slaughter.  I notified that

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

Veterinary Medical Specialist (DVMS) in case additional

follow-up is recommended. Respectfully, 

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

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 121

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

. YXA181704

3114G

2017-04-14 At approximately 2145 hours while performing Good

Commercial Practice (GCP) verification I observed a live hang

employee, on the small bird live hang line, pick a live bird up,

hold the bird with one hand by the hips and throw it toward a

shackle.  The bird's right hock landed in the shackle while the

left hock and leg remained dangling.  

 was notified of the mistreatment

of the live bird during shackling. The live hang employee was

immediately removed from the live hang area.  

stated that the employee was disciplined and all live hang

employees will be re-trained on humane handling. It is

recommended that establishment management review the

Federal Register (attached) on “Treatment of Live Poultry before

Slaughter”, published September 2005 for FSIS

recommendations concerning treatment of live poultry prior to

slaughter.  I notified that this

MOI will be forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case additional

follow-up is recommended. Respectfully,     

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

(b) (6)

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

(b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 122

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

. YXA501605

0119G

2017-05-19 At approximately 1718 hours while performing Good

Commercial Practice verification I observed that there was no

denaturant on the birds in the DOA bin.  I removed several birds

off the top and noticed that there were a couple of layers of

DOAs that did not have a denaturant.  

 came over to the DOA bin and as we were

moving DOAs around in the bin, a few of them were moving. 

Upon investigation, a live bird was found buried under

approximately 4 DOA birds.  I then traveled outside to the

dumping station and observed a trailer of live birds stationed in

the direct sunlight, with no fans or misters.  The outside

temperature was approximately 87 degrees Fahrenheit.  

 and 

were notified of the possible suffocation of the live bird in the

DOA bin and the mishandling of birds that could cause death

prior to slaughter.  Two “fire fans” were placed beside the trailer

to cool the birds. It is recommended that the establishment

management review the Federal Register (attached) on

“Treatment of Live Poultry before Slaughter”, published

September 2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  I notified 

 that this MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. Respectfully, 

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

(b) (6) (b) 

(b) (6)

(b) (6) (b) 

(6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 123

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

. YXA581805

4323G

2017-05-23 At approximately 1953 hours while verifying Good Commercial

Practice in the cage dump area, I observed 3 live birds under the

small bird dump station.  I continued outside to perform

antemortem inspection of the live birds in the trailers.  Upon my

return I observed an establishment employee gathering the

loose live birds under the dumping station and tossing them

over the stainless steel wall of the live hang belt and onto the

belt that transfers the live birds into the facility.  While catching

the last bird the employee grabbed and carried the live bird by

the head and neck then tossed the live bird over the stainless

steel wall of the live hang belt and onto the belt that transfers

the live birds into the facility.  This stainless steel wall is

approximately 7 to 8 feet off the ground. 

 was notified of the mistreatment

of birds and advises the establishment that preventing

mistreatment of poultry decreases the production of

adulterated carcasses. It is recommended that the

establishment management review the Federal Register

(attached) on “Treatment of Live Poultry before Slaughter”,

published September 2005 for FSIS recommendations

concerning treatment of live poultry prior to slaughter.  I

notified that this MOI will be forwarded to the

District Office and the District Veterinary medical Specialist

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

Respectfully,   Allen Harim Foods,

P-935 Harbeson, DE. 19951

(b) (6) (b) (6) (b) (6) (b) (6)
Table:Memorandums of Interview (MOIs) in response to FOIA 2017-00274_July 14, 2017. 124

EstNbr EstName Task_Code MOI# Date Description

P935 Allen Harim

Foods, LLC.

. YXA071006

3923G

2017-06-23 June 23, 2017 Subject:           Memorandum of Interview 

                        Mistreatment of live poultry             A meeting

was held in USDA office at P-935 on Friday June 23, 2017 at

1210 hours with 

 concerning the following Good Commercial Practices: 

On Friday June 23, 2017, one of the Inspectors on Evisceration

Line 1 Station # 3 called me for Veterinary disposition. Upon

examination of carcass, I observed that head of the carcass was

intact with no cut on neck veins. The facial area was swollen;

skin around the neck area was purple in color while rest of the

carcass was bright red in color. The carcass was condemned and

documented as cadaver. was immediately

notified of the finding. The Poultry Products Inspection Act

(PPIA) and the agency regulations do require that poultry must

be slaughtered in accordance with good commercial practices in

a manner that will result in thorough bleeding of carcasses and

ensure that breathing has stopped prior to scalding so that birds

do not drown or die other than slaughter. It is the Agency’s

expectations that all Good Commercial Practices be correctly

and effectively implemented. told me that back up

killers will get write up as per establishment policy and an

additional back up killer was placed on Kill line 1. 

assured USDA that the matter would be resolved. A copy of

this Memorandum of Interview will be forwarded to Front Line

Supervisor (FLS) in case additional follow-up is recommended

and a copy will be placed in the official USDA file.  Please feel

free to contact me with any questions or concerns. Sincerely, 

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

(b) (6)

(b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 1

EstNbr EstName NR# Date Task Regs Description

P687 House of

Raeford

XRA262

205233

1N-1

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

05/31/2017 while performing a Good Commercial

Practice (GCP) in the Live Hang Area I observed

the following Good Commercial Practice

noncompliance: Birds (32) that died from causes

other than slaughter.  The birds were hanging by

their feet in shackles while their heads were still

submerged in water inside the Stunner. As I

observed the birds there was no chest movement

or any signs indicating that they were still alive. I

took regulatory control by placing US RETAINED

TAGS # B33564115 and # B33564128 on the Kill

Line at the point where the birds entered and

exited the Stunner. I asked a plant employee to

locate his Supervisor and ask him to come to Live

Hang. When 

 arrived I showed him the birds in the

Stunner which were not breathing and informed

him a Good Commercial Practice noncompliance

with the above cited regulations existed due to

birds had died other than by slaughter.  Live Hang

employees removed the birds from the Stunner,

placed them in condemned barrel where they

were denatured and then transported to the Offal

Area. The Kill Line initially stopped at

approximately 0120 hours on 5/31/17 due to

mechanical breakdown. 

observed a second GCP noncompliance at

approximately 0230 hours on the morning of

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

another mechanical breakdown at 0215 hours.

Upon arrival  to Live Hang she

observed seventeen birds (17) which had died

other than by slaughter on the Kill Line in the

Stunner. She asked 

to remove the deceased birds

from the line. After the birds were removed from

the line they were placed in a condemn barrel;

denatured and taken to the Offal Area. She

notified 

 of her findings. This is a Other Consumer

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

(b) (6) (b) (6) (b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 2

EstNbr EstName NR# Date Task Regs Description

Protection noncompliance due to establishment’s

failure to implement the process/procedure to

prevent birds from dying other than by slaughter. 

All noncompliance and noted potential

noncompliance are discussed with plant

management during weekly meetings between

USDA and plant management personnel. This NR

was submitted to plant management on

06/01/2017.
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 3

EstNbr EstName NR# Date Task Regs Description

P843 Pilgrims Pride PZA490

404361

0N-1

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

was observed.  As I was giving the USDA inspector

relief breaks starting at approximately 0430

hours, I condemned 3 birds as cadavers.  I notified

 that I was seeing increased

numbers of cadavers.  I continued to condemn

birds as cadavers after this notification.  The

inspectors at all stations were also condemning

birds as cadavers during this time.  After the relief

breaks were over, I proceeded to the scald tank

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

bleed tank before the birds enter the scald tank. 

He constantly was having to cut the necks of live

birds that had missed the kill machine or had

miscuts so that they were still alive with eyes

blinking, and breathing as they were approaching

the scald tank.  While I was observing him at

approximately 0505 hours, I saw a bird that he

overlooked about to enter the scald tank.  This

bird was awake with its head up, looking around,

eyes blinking, and had rhythmic breathing.  The

back up killer was attending to other birds which

had been missed by the kill machine.  I took

regulatory control by stopping the line and

pointed out the missed bird.  He cut the neck and

I restarted the line.  In the period of about 3

minutes, I had to stop the line several times in

order for him to attend to birds about to enter the

scald tank alive.  At no time did he attempt to

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

up with the birds that were alive with

rhythmic breathing.  came

during the time I was stopping the line.  He

observed the situation and left.  Then the

establishment stopped the line.  I went to the kill

machine and saw that there were several people

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

killer location.  Once the line started again, the

problem was not resolved and instead appeared

to be worse and I continued to stop the line

multiple times for uncut birds or birds with

(b) (6) (b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 4

EstNbr EstName NR# Date Task Regs Description

missed cuts that were not bleeding out

completely and were still alive, blinking, and

breathing as they were about to enter the scald

tank.  told me that I needed to speak

with 

and that he was on his way.  I took regulatory

control and stopped the line and did not restart it

again at this time (approximately 0517 hours). 

 came and we discussed the

situation.  I informed him of the lack of process

control and the resulting noncompliance with the

above regulation.  He stopped hanging birds and I

allowed the line to restart in order to move the

birds along that were already on the line.  As

there were still many uncut or miscut birds that

needed the attention of the second back up killer,

I continued to ensure the line was stopped

periodically so that no bird entered the scald tank

alive.  investigated the situation

during this time and reported that the bicycle

wheel was not working properly and the water

had been turned off.  Adjustments were made and

then I relinquished regulatory control and verified

that the process was back in control

(approximately 0529 hours).

(b) (6) (b) (6)(b) (6) (b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 5

EstNbr EstName NR# Date Task Regs Description

P165H OK

Foods

Processing

Plant

DAF332

205502

9N-1

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

evisceration/slaughter floor, I observed the

following non-compliance. At 2138 hours, I 

 observed that Evisceration line 1 and Kill

Line 1 had stopped for an unknown length of

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

approximately 2139 hours, I observed that the

stunner for Line 1 had not been lowered. 

Approximately 30 birds were submerged, limp,

and lifeless in the stunner. These birds had

drowned in the stunner.  At 2141, an employee

arrived to lower the stunner, which was too late.

These birds had already expired.  Line 1 started

back up at approximately 2142. I took a visual

regulatory control action and had the line

stopped. arrived

and he and an employee removed the

drowned/dead birds from line 1 in my presence.

After the birds were removed, I observed the

stunner, to ensure no other birds had died by

drowning. The kill line was released and restarted

at approximately 2145. I continued to observe the

slaughter process, to ensure no other

non-compliances. These birds died other than by

slaughter. The requirements of 9 CFR 381.65(b)

were not met.

(b) (6)

(b) 

(6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 6

EstNbr EstName NR# Date Task Regs Description

P550 Simmons

Prepared

Foods, Inc.

XWN34

050551

01N-1

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

hours while observing the kill process as part of

the good commercial practices check, I observed

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

stand and leave his station. I observed a chicken

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

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

to prevent this bird from entering the scalder

alive. I notified of the

noncompliance. He had the lead replace the

back-up killer to take him to the office for

counseling. I then restarted the kill line at

approximately 1210 hours. The above described

event reflects a lack of process control in the kill

area. The establishment failed to meet the

requirements of 9 CFR 381.65(b) which requires

poultry to be slaughtered with good commercial

practices that will result in thorough bleeding of

the carcasses and ensure that breathing has

stopped prior to scalding.”

(b) (6) (b) 

(4)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 7

EstNbr EstName NR# Date Task Regs Description

P550 Simmons

Prepared

Foods, Inc.

XWN59

140651

14N-1

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

1350 hours while performing a good commercial

practices check, I observed that the back-up killer

was not on his stand on the kill line that feeds

evisceration lines and When I saw a bird not

killed by the machine, I stopped the line. The

back-up killer appeared from the blood tunnel.

The supervisor came and I talked to him about the

problem, then we restarted the line. I also

discussed it with the superintendent, then went to

the evisceration area. A supervisor told me an

inspector on line had just hung back two birds

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

that they were cadavers. I then went to the

picking room to look at the birds going to the

scalder on that kill line. I was accompanied by the

. I observed the

birds heading from the blood tunnel to the

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

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

from the line. The above described event reflects

a lack of process control in the kill area. The

establishment failed to meet the requirements of

9 CFR 381.65(b) which requires poultry to be

slaughtered with good commercial practices that

will result in thorough bleeding of the carcasses

and ensure that breathing has stopped prior to

scalding.” A similar finding in which the

same back-up killer left his station was

documented on an NR #XWN3405055101/1N on

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

the establishment to that NR was "Employee was

terminated." This further planned action was not

implemented or was insufficient to prevent

today's finding. Associated noncompliances are

discussed in the weekly meeting with plant

management. The weekly meetings are

documented on an MOI and a copy of the MOI is

provided to plant management. Continued

repetitive noncompliance with regulatory

requirements could result in increased

(

b

(

b

(b) (6) (

b

(b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 8

EstNbr EstName NR# Date Task Regs Description

administrative/regulatory actions as described in

9 CFR 500.4. You have the right to appeal this

decision as delineated by 9 CFR 381.35.

M1328

9

Cargill Meat

Solutions Corp.

NRD43

070626

24N-1

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

performing a good commercial practices check to

ensure birds were being processed according to

regulation 9CFR 381.65(b), I observed a

non-compliance. A bin containing approximately

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

appeared to be very red in color. The birds had

been picked but not opened. Upon further

inspection the birds exhibited the signs of having

died by means other than slaughter. The skin was

very red, severe congestion in the proximal neck

near the head and inadequate or no cuts for

bleeding were observed by me, and

 I then checked birds on the kill line and

observed several hens and shorter

toms improperly cut and still breathing but not

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

the line at the scalder and was sitting in the floor

because it had not died on the line prior to the

scalder. A regulatory control action was taken by

stopping the kill line. was notified

of the non-compliance and shown the breathing

and improperly cut birds. He investigated the

situation and after approximately 15 minutes to

alleviate the concern placed another backup killer

downstream to catch any missed birds and

identify birds prior to the scalder to allow them

time to bleed before going into the scalder. It

appeared that all the cadavers seen in the

condemned bin in the live hang area had been

removed at the hock cutter area. The live bird on

the floor was removed and dispatched of properly

and the birds improperly killed on the line were

re-cut and allowed to bleed properly. The

establishment's process for ensuring birds meet

the regulatory requirements was not adequate as

evidenced by the cluster of cadaver's and the

other situations described above.

(b) (6) (b) (6) (b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 9

EstNbr EstName NR# Date Task Regs Description

P72 Tyson Foods,

Inc

JPJ1319

054904

N-1

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

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

GCP for Live Hang Area.  When I arrived and my

eyes were adjusting to the dark conditions I

noticed DOA birds piled down the left wall of the

hanging belt and a large pile at the end of the

belt.  After a few minutes I noticed movement

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

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

point I turned my light on and observed

approximately 6 birds in different positions

struggling to breath with DOA carcasses piled on

top of them.  I also noticed several birds with feet

sticking out from under DOA carcasses that were

kicking; some vigorously at times.  It was very

apparent that the live birds buried under the

DOA’s were smothering from pressure and lack of

oxygen.  At this time I stopped both live hang lines

and requested get .  At

0437 hours arrived and began digging

thru the birds down the left wall; he found

approximately 3 to 5 live birds buried in this pile

as well.  There were approximately 100 – 150

DOA’s piled up with approximately 20 live birds

buried completely or partially.  At 0445 hours I

observed the DOA belt going outside; the

carcasses on the outside appeared to be disposed

of correctly and humanely.  At 0447 hours

maintenance arrived to work on the DOA belt. 

After speaking to management I learned that a

truck had turned over during the night and the

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

Management was aware and 

stated that he had watched a couple of the

cages of birds being dumped.  Management failed

to notify USDA in any manner.  was

notified at approximately 0430 hours by

 that numerous Cadavers were being

found on his line.  At approximately 0420 hours

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

Cadavers in the transfer area both on the belt and

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

(b) (6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 10

EstNbr EstName NR# Date Task Regs Description

in the floor.  The plant failed to meet 9CFR

381.65(b).  Production was shut down from 0425

hours until end of shift.

P468 Peco Foods,

Inc.

JVD062

205480

6N-1

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

Saturday May 6th 2017 at approximately 21:30

hours, I observed the

following noncompliance while performing a

Good Commercial Practice verification task, (3)

three birds within five minutes on line 2 entered

the scalder still breathing and multiple birds not

properly bled out. I immediately took regulatory

control action by slowing the line speed from 

birds per minute to birds per minute. I

reported my observations to 

 who was the individual to slow the

line speed. I returned to observe line 2 for another

5 minutes and verified that the pattern of birds

dying other than by slaughter had discontinued. I

verified line 1's speed at birds per minute of

the same lot and observed birds being bled and

slaughtered in conjunction with agency statutes

and regulations. During the time of this regulatory

failure P468 was slaughtering heavier than

average birds (projected weight of

9.91-10.21/bird) then what they are normally

used to; lot AR origins. The process the

establishment is using to slaughter poultry on line

2 is not in a manner that ensures that breathing

has stopped before scalding, so that the birds do

not drown, and that slaughter results in thorough

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

P468 failed to implement their Animal Welfare

Guidelines under the heading of slaughter. The

line speed remains at bpm for line 2 during

heavier than average bird weight slaughtering,

ensuring the slaughter process is under control,

birds do not enter the scalder breathing, and that

adequate bleed out times for these larger birds

are met.  was

notified of the forthcoming non-compliance

(b) (6)

(b) (6) (b) 

(4)

(b) 

(4)

(b) 

(4)

(b) (b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 11

EstNbr EstName NR# Date Task Regs Description

M7100 Tyson Foods,

Inc.

ZHB532

106202

8N-1

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

1820 hours the following noncompliance was

observed: on

Line 1 station 4 stopped the line and rung the

buzzer for me . She informed

me that while inspecting she had condemned

several cadaver carcasses one behind the other.

She stated that after the third carcasses she

informed plant management but nothing was

done to correct the problem and the cadaver

continued to come down the production line and

were condemned. The evisceration line was

stopped and the inspectors were evacuated to the

office because of chemical spill in the

chemical room. The plant was notified of the

process out of control and the forth coming

noncompliance. 

, stated that the killing machine blade was

not working properly. Evisceration line was

started and verified that the stunner,

killing machine blade and back-up killer was

working properly and process was back in control.

   The plant was notified of the process out of

control and the forth coming noncompliance. 

, stated that the

killing machine blade was not working properly. 

The total numbers of cadavers condemned for the

shift were 24. This does not meet the regulatory

requirements of 9CFR381.65 (b).

P325 Tyson Foods,

Inc.

YDM45

210630

22N-1

2017-06-22 04C05 381.65(b) At 2114, I observed 7 cadavers in the condemn

barrel at the rehang station. Five of the cadavers

still had their heads attached, and the heads did

not have a neck cut. Two of the cadavers had their

heads removed. I demonstrated the cadavers to

 and told him this

was a noncompliance according to 9 CFR

381.65(b). Given the appearance of the carcasses,

the birds were alive when entering the scald tanks

and as such died by means other than slaughter.

This is not in accordance with good commercial

practices. I asked to slow the lines to 

(b) (6)

(b) (6)

(b) (6)

(b) 

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

(6)

(b) 

(4)

(b) (6)(b) 

(4)

Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 13

EstNbr EstName NR# Date Task Regs Description

two people sorting the entire truck of DOA birds. 

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

B38087081 to live hang and instructed 

that the tag would not be removed

until all live birds had been sorted from DOA

birds.  At 2147 I observed that all DOA birds had

been sorted and proceeded to remove the tag

from live hang. Live birds in cages with Dead on

Arrival birds will result in birds dying by crushing

and is not consistent with Good Commercial

Practices. It is important to treat poultry in a way

that ensures they do not die by means other than

slaughter. Employing methods of handling

consistent with Good Commercial Practices and 9

CFR 381.65(b) can help produce and

unadulterated product. As preventive measures

 told me he would document a

standard procedure for the proper sorting of DOA

birds.

(b) (6)

(b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 14

EstNbr EstName NR# Date Task Regs Description

P206 Pilgrim's Pride

Corporation

KCC121

105503

0N-1

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

Tuesday, May 30, 2017 at approximately 0815

hours, I, , observed the

following noncompliance of regulation 381.65(b). 

While performing Operational SSOP Review and

Observation task, approximately 12 cadaver birds

were observed at the Pinning/Sorting station in

the Picking Room. The birds were bright cherry

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

to indicate that they had gone through the kill

machine properly.  On the others, it was difficult

to discern if there were cuts because the carcasses

had gone through two head pullers prior to

getting to the stations. I notified 

 who in turn

notified the Live Hang Supervisor.  In the

meantime, cadavers continued to intermittently

arrive at the Pinning/Sorting station.  The Live

Hang supervisor stated that she had a new person

backing up the kill machine.  Since the plant had

stopped hanging for the 0830 company break, I

instructed that when they started up

after break, they were to decrease the linespeed

in evisceration from birds per minute to 

bpm to assure that the employees performing

backup killing duties could adequately back up

the equipment to prevent birds from getting by

and entering the scalder still breathing.  I

proceeded to inform 

and Ms. Tonja Byers, Plant Manager of

the increased incidence of cadavers.  The

establishment investigated the incident and found

that the back up killers did not have sufficient

training to prevent birds from getting by the kill

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

kill machine was not the appropriate size for the

birds that were being slaughtered at the time. 

The appropriate sized blade was put onto the kill

machine.  The establishment also adjusted to

stunners to get a more complete stun so that

birds would enter the kill machine more

(b) (6)

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

(b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 15

EstNbr EstName NR# Date Task Regs Description

uniformly. An extra back up killer was added to

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

incidences of cadavers reaching the Pinner/Sorter

station.  The plant was allowed to slowly increase

the linespeed after demonstrating with each

increase that the problem had been taken care

of.  There were a total of 27 cadavers that reached

the station and all were condemned. The PPIA (21

U.S.C. 453(g)(5)), and 9 CFR 381.90, provide that

poultry carcasses showing evidence of having died

from causes other than slaughter are considered

adulterated and must be condemned. Pleaser

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

a similar noncompliance of the establishment's

failure to adhere to performance of Good

Commercial Practices. You are hereby advised of

your right to appeal this decision as delineated by

381.35 of 9 CFR.
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 16

EstNbr EstName NR# Date Task Regs Description

P7044 Tyson Foods,

Inc.

GJJ230

006171

7N-1

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

picking room verifying conditions 17 cadavers

were observed on the floor next to the drain.  The

carcasses had the heads attached, the body was

red in color and the heads were dark red to

purplish in color.  There was also a cadaver with

the head attached on the floor next to the hock

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

more cadavers were observed on the picking lines

and removed.  The carcasses had the heads

attached, the body was red in color and the heads

were dark red to purplish.  Another cadaver with

head attached was in the catch bin below the

hock cutter on line two.  

 was notified and shown all 21 cadavers. 

All 21 birds were condemned.  had

maintenance adjust the blade on the automatic

knifes and adjusted the stunners.  This is

noncompliance with 381.65(b) which states

“Poultry must be slaughtered in accordance with

good commercial practices in a manner that will

result in thorough bleeding of the carcasses and

ensure that breathing has stopped prior to

scalding”.    

(b) (6)

(b) (6) (b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 17

EstNbr EstName NR# Date Task Regs Description

P509 Koch Foods

LLC

IPG500

004130

3N-1

2017-04-02 04C05 381.65(b) The following occurred on the shift beginning

04/02/2017.  At approximately 2157 hours, while

performing a bird check on the picking line before

the First Scalder, I observed one (1) live bird

travelling the line to said scalder.  No cut was

observed on the bird's neck.  

, was immediately notified. 

At approximately 0120 hours, while performing a

bird check on the picking line before the First

Scalder, I observed two (2) live birds travelling the

line to the scalder.  The first bird had a small cut

on the neck, but still attempted to turn its head

upright.  The second travelled with one leg free,

with no cut upon its neck.  The decision to

perform the second picking line check came after

observing two (2) unbled cadavers at Line ,

Inspector Unit 1 while relieving the Line

Inspector.  ,

was immediately notified.  An extra back-up was

observed to be in place at 0129.  Another picking

line check was performed at approximately 0134,

with no live birds observed travelling to the

scalder.

(b) (6)

(b) (6) (

b
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 18

EstNbr EstName NR# Date Task Regs Description

P533 Hain Pure

Protein

Corporation -

FreeBird East

AKB071

205321

6N-1

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

May 16, 2017 at approximately 0715 hours there

was the following noncompliance of regulation

381.65(b).   noted a large number

of empty shackles at the conclusion of giving

online inspection breaks.  went to live

receiving where he found plant management

removing dead birds from the live receiving belt. 

He was informed that there was a mechanical

issue with the dumper to hang room transfer belt

and live birds had smothered due to the dumper

belt continuing to dump live birds on top of each

other.  At this point no more birds were being

added and plant management was fixing the

equipment.  verified that condemned

birds were dead.  then notified me, 

.   I traveled from another establishment

and by the time I arrived to live receiving all dead

birds had been removed, condemned, and

operations were operating normally.  I met with

.  He stated

that 198 birds had died by means other than

slaughter and that it was due to the transfer belt

‘slipping’ and not operating as intended.  The belt

had been tightened and the plant wants to install

an independent turn off switch for the dump belt

that allows the transfer and hang room belts to be

run to clear without that dumper belt continuing

to run.  The PPIA (21 U.S.C. 453(g)(5)), and 9 CFR

381.90, provide that poultry carcasses showing

evidence of having died from causes other than

slaughter are considered adulterated and must be

condemned.

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

(b

) 

(6)

(b) (6)
Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 19

EstNbr EstName NR# Date Task Regs Description

M7559 David Elliot

Poultry Farm

Inc.

SNA331

106011

9N-1

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

slaughter at P134, after the conclusion of the

day’s slaughter it was determined that there were

525 Dead On Arrival (DOA) chickens. The increase

in DOAs is likely consistent with the effects from

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

The Poultry Products Inspection Act (PPIA) (21

U.S.C. 453(g)(5)), 9 CFR 381.65(b), and 9 CFR

381.90 provide that poultry carcasses showing

evidence of having died from causes other than

slaughter are considered adulterated and must be

condemned. The regulations also require that

poultry be slaughtered in accordance with GCP,

which means treated humanely.  It appears that

the Est. has lost control of its process for handling

birds and thus is not operating in accordance with

Good Commercial Practices for Poultry. On 06-13

-17 1337 DOA were noted at this Est. The

increased number of DOAs today is a

noncompliance with 9 CFR 381.65(b) which states

in part that Poultry must be slaughtered in

accordance with GCP.  I informed Mr. Moshe Fink,

establishment owner, of this noncompliance.

P44826 Case Farms

Processing, Inc

000390

304392

6N-1

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

Poultry good commercial practices for poultry

slaughter task at the chicken dumper in the live

hang station I observed the employee who

operates the dumper, dumped a cage full of birds

on top of  birds which were on the conveyor

belt. He should have waited till the conveyor get

cleared and there were no more birds on the

conveyor. This is incompatible with 9 CFR 381.

65(b). was

notified of the noncompliance.

(b) (6)

Table: Noncompliance Records(NRs) in response to FOIA 2017-00274_July 14, 2017 21

EstNbr EstName NR# Date Task Regs Description

P45131 Farbest Foods,

Inc.

000420

504512

8N-1

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

performing CI duties, I observed a bird with a

substantial amount of airsacculitis in the cavity.

This was an unmarked bird. Upon closer

examination I saw another bird with airsacculitis

in the cavity. I notified I looked at

more unmarked birds and they were also infected

with airsacculitis. After viewing marked birds and

unmarked birds there were approximately 40+

birds that had airsacculitis in the cavity that

wasn’t removed. was also notified. I

continued observing both marked and unmarked

airsacculitis birds with airsacculitis in the cavities

until approximately 1230hrs., when the lot

change occurred. Reg. 381.84 Carcasses of

poultry with evidence of extensive involvement of

the air sacs with airsacculitis or those showing

airsacculitis along with systemic changes shall be

condemned. Less affected carcasses may be

passed for food after complete removal and

condemnation of all affected tissues including the

exudate.

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