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Humane Handling Verification for Livestock and 

Good Commercial Practices for Poultry 

Objectives 

Upon completion of this module, you will be able to accomplish the following without the 

aid of references: 

1. Name the two approved methods of slaughter in the Humane Methods of 

Slaughter Act (HMSA). 

2. Define egregious and non-egregious noncompliance, and given a specific 

scenario, be able to identify regulatory noncompliance, whether it is egregious, 

and what action to take, if any. 

3. Describe the actions an inspector should take when he/she observes an egregious 

or non-egregious incident of inhumane treatment of livestock. 

4. List the steps in performing the Poultry Good Commercial Practices (GCP) task. 

5. Identify regulatory noncompliance with Good Commercial Practices or 

mistreatment of birds and actions to take in each case. 

References 

1. 9 CFR 313: Humane Slaughter of Livestock 

2. 9 CFR 352.10: Exotic Animals; Voluntary Inspection 

3. Humane Methods of Livestock Slaughter Act of 1978 

4. Federal Meat Inspection Act, Section 603 

5. FSIS Directive 6900.2, Rev. 3 – Humane Handling and Slaughter of Livestock 

6. FSIS Directive 6100.1, Rev.3 – Ante-mortem Livestock Inspection 

7. Poultry Products Inspection Act Section 453(g)(5) 

8. 9 CFR 381.65(b): Poultry Products Inspection Regulations 

9. FSIS Directive 6100.3, Rev. 1 – Ante-mortem and Post-mortem Poultry 

Inspection 

10. FSIS Directive 6110.1 – Verification of Poultry Good Commercial Practices 

Livestock Humane Handling Verification 

Introduction 

The Humane Methods of Livestock Slaughter Act (HMSA) of 1978 is the current law 

requiring the humane slaughter of livestock. The 1978 Act made mandatory the humane 

slaughter and handling of livestock in connection with slaughter of all food animals 

slaughtered in USDA inspected establishments. This includes cattle, calves, horses, 

mules, sheep, goats, swine, and other livestock. 

Two methods of slaughter are humane according to the HMSA. The first method 

requires that livestock be rendered insensible to pain on the first application of the 

stunning device before being shackled, hoisted, cast, or cut. This means that the animal 

must be unconscious and unable to feel pain before it is “stuck” (veins and arteries 

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severed so it bleeds out) before it is shackled and hoisted into the air, or before it is 

dropped onto a table/floor. 

The second method is in accordance with the ritual requirements of any religious faith 

that prescribes a method of slaughter where the animal suffers loss of consciousness by 

anemia of the brain caused by the simultaneous and instantaneous severance of the 

carotid arteries with a sharp instrument. This method is known as ritual slaughter. In 

ritual slaughter, the animal’s throat is cut from side to side with a sharp knife, deeply 

enough for the major arteries and veins to be severed. Examples of ritual slaughter 

include Jewish (kosher) slaughter and Islamic (halal) slaughter. 

Additionally, Section 1906 of the HMSA exempts the handling or other preparation of 

ritually slaughtered livestock from the terms of the Act. This means that the statutory 

requirement that livestock be rendered insensible to pain prior to shackling, hoisting, 

casting, or cutting does not apply to the handling or restraint that is immediately 

associated with the ritual slaughter cut. 

Inspection program personnel (IPP) will verify that establishments are meeting 

regulatory requirements by performing the Livestock Humane Handling Verification task 

during every slaughter shift (by a CSI or PHV, in addition to your observations during 

ante-mortem inspection). 

At this time, the HMSA of 1978 does not cover poultry. However, welfare practices for 

poultry are covered by the regulatory requirement for good commercial practices (GCP). 

The regulations for poultry good commercial practices are in 9 CFR Part 381.65. GCP 

for poultry will be discussed later in this material. 

Performing the Livestock Humane Handling Task 

Inspectors assigned to livestock slaughter will verify that establishments comply with the 

humane slaughter law and regulations. IPP perform the Livestock Humane Handling 

Verification task each shift that animals are slaughtered, or when animals are on site, 

even if it is during a processing-only shift. 

When performing the task, make certain not to be predictable in how, where, and when 

observations are performed. Randomly select areas and times such that all areas are 

observed at different times of the day. In addition, vary the route taken to get to the 

areas being observed. The bottom line here is that establishment personnel should not 

be able to anticipate when IPP are going to be observing their humane handling and 

slaughter methods because they are always in about the same place at about the same 

time. 

HATS Categories 

The Humane Activities Tracking System (HATS) categories covered while performing 

the Livestock Humane Handling Verification task include the following: 

I. Inclement Weather (9 CFR 313.1 and 313.2): Under this category, IPP record their 

verification of how the establishment adapts its facilities and handling practices to 

inclement weather to ensure the humane handling of animals. Some things to look 

for include: 

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• Inclement weather (e.g., rain, heat, snow, ice) having adverse effects on 

facilities and animal handling. 

• Animals slipping or falling because of wet floors or because of a buildup of 

snow and ice. 

• Animals with no access to water when water buckets or troughs freeze over. 

• Livestock overheated because of a lack of proper shade or because of a lack 

of water for cooling. 

• Disabled livestock not in a covered pen protected from the elements. 

II. Truck Unloading (9 CFR 313.1 and 313.2): Under this category, IPP record their 

verification of the establishment’s humane handling procedures during livestock 

unloading activities. Some things to look for include: 

• Facility conditions causing injury to animals. 

• Vehicles or ramps not being properly positioned, leading to the injury of 

animals. 

• Animals forced to move faster than a normal walking speed. 

• Animals slipping and falling. 

• Disabled or U.S. Suspect animals not being separated from normal 

ambulatory animals. 

• Animals being prodded excessively or not driven with a minimum of 

excitement and discomfort. 

III. Water and Feed Availability (9 CFR 313.2): Under this category, IPP record their 

verification of the establishment’s compliance with 9 CFR 313.2(e), which requires 

that water be available to livestock in all holding pens at all times, and that animals 

held longer than 24 hours have access to feed. Some things to look for include: 

• Water not accessible to livestock in holding pens. 

• Feed not provided to livestock held for longer than 24 hours. 

• Feed provided not appropriate for species and age. 

IV. Ante-mortem Inspection (9 CFR 313.1 and 313.2): Under this category, while IPP are 

conducting ante-mortem inspection, they are to record the time spent verifying the 

establishment’s facilities and procedures for humanely handling animals during antemortem inspection. Some things to look for include: 

• Livestock being excessively prodded with an electric prod. 

• Livestock being injured because of handling practices. 

• Livestock being moved faster than a normal walking speed. 

V. Suspect and Disabled (9 CFR 313.1 and 313.2): Under this category, IPP record 

their verification of the measures that an establishment takes to ensure that “U.S. 

Suspect” and disabled livestock (9 CFR 313.2(d)) are handled humanely. Some 

things to look for include: 

• Conscious animals being dragged. 

• Disabled animals not separated from normal ambulatory animals. 

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• US Suspect and disabled livestock are not provided or placed in a covered 

pen in compliance with 9 CFR313.1(c) or 313.2(d)(1). 

VI. Electric Prod/Alternative Object Use (9 CFR 313.2): Under this category, IPP record 

their verification of the establishment’s procedures for humanely and effectively 

moving livestock without excessive prodding or the use of sharp objects after antemortem inspection has occurred (9 CFR 313.2). Some things to look for include: 

• Livestock being excessively prodded resulting in overexcitement or injury. 

• Livestock being driven with sharp objects or other means which cause pain or 

injury. 

• Livestock forcibly being pushed or dragged across the floor. 

VII. Slips and Falls (9 CFR 313.1 and 313.2): Under this category, IPP record time spent 

observing whether any animals are slipping and falling as they are handled and 

moved through the livestock facilities. Some things to look for include: 

• Livestock slip and fall due to inadequate footing or improper handling 

practices. 

• Livestock slip and fall because of lack of slip-resistant flooring. 

VIII. Stunning Effectiveness (9 CFR 313.5, 313.15, 313.16, and 313.30): Under this 

category, IPP record their verification of the establishment’s procedures to 

appropriately and effectively administer stunning methods that produce 

unconsciousness in the animal before the animal is shackled, hoisted, thrown, cast, 

or stuck. IPP will also verify this HATS category when they identify establishments 

using secondary entrances to move animals into the slaughter area. Some things to 

look for include: 

• Livestock not rendered unconscious with a single application of the stunning 

methodology. 

• No records for carbon dioxide gas concentrations. 

• Use of secondary entrances with potential for injury (or actual injury) of 

livestock. 

NOTE: For animals that are ritually slaughtered, the ritual slaughter cut will not be 

evaluated. But for those establishments that perform ritual slaughter and elect to utilize 

one of the approved stunning methods (found in 9 CFR 313), the stun effectiveness will 

be evaluated. 

IX. Conscious Animals on the Rail (9 CFR 313.5, 313.15, 313.16, and 313.30): Under 

this category, IPP (usually a Public Health Veterinarian) record their verification that 

the establishment ensures that animals do not regain consciousness throughout 

shackling, sticking, and bleeding. This category focuses specifically on the time after 

stunning and throughout the process of shackling, hoisting, sticking, and bleeding of 

the animal. Some things to look for include: 

• Processing (e.g., shackling, hoisting, cutting) livestock not rendered 

unconscious by the method of stunning. 

• Animals regaining consciousness after being stunned. 

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Specific Considerations for the Humane Handling Task 

Truck Unloading (9 CFR 313.1, 313.2) 

Establishment personnel are required to meet the regulatory requirements for humane 

handling and slaughter from the time livestock arrive at the establishment until they are 

killed. This includes handling associated with livestock trailers. Once a vehicle has 

entered the official establishment premises, it is considered part of the premises and is 

subject to the FSIS regulations that ensure humane handling. 

This is an important concept to understand because it means that your responsibility for 

verifying humane handling begins when the animals are coming onto the premises, not 

just once they reach the holding pens. If you observe a humane handling violation during 

truck unloading, you are to follow the same procedure as when a violation is observed 

elsewhere in the facility. 

Truck unloading must be done in a manner that allows animals to be unloaded without 

injury. This includes proper positioning of the trucks, movement of animals while on the 

trucks, and the movement of animals off the trucks into the holding pens. 

Twenty-Eight Hour Law 

The Animal and Plant Health Inspection Service (APHIS) Twenty-Eight Hour Law 

requires transporters to stop at least every 28 hours to provide animals with food, water, 

and rest, and those who do not are in violation of this law. If livestock arriving on 

transport vehicles appear exhausted or dehydrated, IPP need to ask establishment 

management if the truck driver stopped within 28 hours to provide food, water, and rest 

to the livestock. If you do not get a satisfactory response, you will contact your 

supervisor, and he/she may coordinate with APHIS to investigate further. 

Conducting Ante-mortem Inspection on Vehicles 

IPP can enter onto transport vehicles to conduct ante-mortem inspection if establishment 

employees cannot humanely remove disabled livestock from the vehicles. The decision 

to enter a transport vehicle to conduct ante-mortem inspection or to conduct antemortem inspection from outside the vehicle is to be made by each inspector individually 

and is voluntary. Inspection personnel may enter onto the transport vehicle or perform 

ante-mortem inspection from outside the transport vehicle if, in his or her professional 

opinion, he or she can safely and adequately conduct the ante-mortem inspection. No 

adverse or disciplinary action can or will be taken against any inspection program 

personnel choosing not to conduct ante-mortem inspection of disabled livestock on or 

from outside of a transport vehicle. As a general rule, IPP are recommended not to 

inspect livestock on conveyances for safety reasons, but it is not explicitly prohibited. 

Livestock Pens, Driveways and Ramps (9 CFR 313.1, 313.2) 

Personnel responsible for moving livestock must do so with a minimum of excitement 

and discomfort to the animals. The ramps, driveways, and the floors of pens must be 

constructed and maintained so that the livestock have good footing. There are many 

ways this can be accomplished, such as using metal mesh and grooves cut or 

impressed into the cement. Establishments also need to consider the impact that 

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seasonal weather conditions may have on footing. For example, it may be necessary for 

the establishment to use sand or some other material on the floors during the winter to 

overcome slick conditions. 

Livestock pens and driveways should be constructed so that animals are not driven 

around multiple sharp corners. Pens, driveways, and ramps must be maintained in good 

repair. They must be kept free from sharp or protruding objects that can cause injury. 

Loose boards, splintered or broken planks, broken pipe rails, broken unloading ramps, 

and unnecessary openings where the head, feet, or legs of an animal may be injured 

must be repaired. Pens, alleyways, or fencing in disrepair such that an animal may be 

injured as a result is considered a regulatory violation of humane practices. 

When observing the facilities for compliance, remember to look at the off-loading ramps, 

inside the holding pens, at the back of solid gates, inside the single file chute, restraint 

device, and stunning box. You may have to wait until the animals are out of these areas 

before you can complete your verification activities. 

Handling of Livestock (9 CFR 313.1, 313.2) 

Livestock must not be driven faster than a normal walking speed. That is, the animals 

must not be forced by the handlers to move more quickly than their normal walking 

speed. If you see one or a group of animals running, you need to determine what is 

causing the animal to run before deciding if there is regulatory noncompliance. It is 

expected that livestock will be anxious; the key here is whether human actions caused 

the animal to move faster than a walk. 

The use of electric prods, canvas slappers, or any other type of implement must be 

minimized to prevent injury and excitement. The use of implements such as baseball 

bats, shovels, sharp prods, whips, and the like, which in the opinion of the inspector can 

or will cause injury, are prohibited. Electric prods wired into AC current must not carry a 

charge higher than 50 volts. 

Livestock must have access to water at all times while in holding pens. If they are held 

longer than 24 hours, they must also have access to feed. Agency policy is that feed 

must be of appropriate for the age and species of animal being fed. For example, 

feeding hay to bob veal calves held more than 24 hours would not meet the regulatory 

requirement for access to feed, since they usually have not yet been weaned off milk. If 

held overnight, they must have enough room in the holding pen to lie down. 

Animals that are disabled, non-ambulatory, or designated as U.S. Suspect must be 

segregated into a separate pen. The pen must protect these animals from adverse 

weather conditions until you make your ante-mortem disposition, because the weakened 

state of these animals renders them less resistant to even “normal” weather conditions. 

This means that you need to take into account the geographic location of the facility, the 

season, and the current weather conditions when determining if the covered pen meets 

regulatory requirements. It also means that the overall level of cover may change, based 

on the above factors. 

The regulations strictly prohibit dragging or pushing a conscious animal that is disabled 

or unable to walk. Establishment personnel must either stun these non-ambulatory 

disabled animals before dragging them or move the animals by placing them on a skid, 

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stone boat, bucket lift, or some other type of equipment that is suitable for moving a 

conscious disabled animal. 

All non-ambulatory disabled cattle, including non-ambulatory disabled veal calves, that 

are offered for slaughter (including those that have passed ante-mortem inspection) 

must be condemned and properly disposed of in accordance with 9 CFR 309.13. 

Secondary Entrances 

Some establishments may use secondary or alternative entrances, such as alleyways, 

doorways, or passageways, to move livestock into the facility. Secondary entrances are 

considered potential routes of movement to slaughter that differ from the route followed 

by the normal livestock population, which is ante-mortem inspected and passed 

livestock. 

There are several concerns with using secondary or alternative pathways. 

• First, IPP may not be aware that animals are being moved through these 

secondary pathways, so may not be able to determine whether such animals are 

eligible for slaughter. Examples of this include bringing in non-ambulatory 

disabled cattle, dead, or uninspected animals. 

• Second, the nature of the entrance may lead to inhumane handling of the 

animal. For example, the entrance is so small that the animal may be hurt. 

• Third, the equipment used, or lack of equipment, may lead to inhumane handling 

of the animal. For example, ramps may be slippery or missing altogether. 

It is important to recognize that using alternative entrances is not prohibited. However, 

establishments using secondary or alternative entrances must ensure that livestock 

entering the establishment do so under conditions that meet all the relevant statutory 

and regulatory requirements. While performing HATS Category VIII – Stunning 

Effectiveness verification, IPP are to look for evidence that animals are being moved 

through secondary entrances and verify that the situations described above are not 

occurring at the establishment. 

If IPP find evidence that any of the situations described above are have occurred, they 

are to control the condemned livestock and take a regulatory control action by tagging 

the entrance to prevent its use. If IPP observe that livestock have been inhumanely 

handled because of the nature of the entrance or equipment used, they are to take a 

regulatory control action and document a noncompliance record in as specified in the 

“Enforcement” section later in this module. 

Stunning (9 CFR 313.2, 313.5, 313.15, 313.16, 313.30) 

To meet the statutory requirements in the HMSA, all animals must be rendered 

insensible to pain by a single blow or gunshot or by an electrical, chemical or other 

means that is rapid and effective, before being shackled, hoisted, thrown, cast, or cut. 

This requirement includes cattle, calves, horses, mules, sheep, swine, and other 

livestock. 

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There are some general principles that apply to all stunning methods: 

1. Stunning equipment must be maintained in good repair. Equipment in poor repair 

can interfere with the rapid and effective application of the stunning blow. This 

can result in an incomplete or unsuccessful stun. 

2. Effective stunning requires effective restraint. If an animal is not effectively 

restrained, it will be much more difficult to locate the stunning blow with a high 

degree of accuracy. The stunning area should be designed and constructed to 

limit the free movement of animals. 

3. A well-trained and experienced establishment employee must operate stunning 

devices. The employee must be able to accurately and consistently position the 

stunning devices so that the animal is rendered immediately unconscious. 

4. Animals need to be delivered to the stunning area with a minimum of excitement 

or discomfort. It is more difficult to place the stunning device accurately, and the 

method of stunning may not work as effectively, on an excited or injured animal. 

With any stunning method, it is important to observe the amount of time it takes for the 

animal to begin bleeding out (“sticking”) after being stunned. Although there is no 

regulatory requirement for this time period, if the “stun to stick” interval is prolonged, it 

could result in animals regaining or beginning to regain sensibility on the bleed rail. 

It is also important to perform humane verification at different times of the day. 

Equipment that may be working well in the morning can malfunction later in the day. 

Personnel get fatigued, may feel pressure to get a certain number of animals stunned by 

a particular time, or may be focusing on after-work activities. Animals that have been 

standing around all day can get restless and more difficult to handle quietly and calmly. 

All these things can contribute to careless handling and/or stunning techniques, resulting 

in ineffective stuns. 

The regulations describe four acceptable methods for producing a state of surgical 

anesthesia (surgical anesthesia is defined as a state where the animal feels no painful 

sensations). The four acceptable methods are: 

• Chemical (Carbon Dioxide - CO2) 

• Mechanical (captive bolt) 

• Mechanical (gunshot) 

• Electrical (electrical current) 

Carbon Dioxide (9 CFR 313.5) 

Carbon dioxide gas (CO2) is approved for rendering swine, sheep, and calves 

unconscious. A carbon dioxide gas chamber is designed on the principle that carbon 

dioxide is heavier than normal atmospheric air. The chamber is open at both ends for the 

entry and exit of the animals to anesthetizing CO2 concentrations, or can be a pit 

structure where animals are lowered into the pit then brought out after inducing 

insensibility to pain. For swine only, CO2 can be administered to induce death. Once 

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anesthesia has occurred, the animals are removed from the chamber and are ready to 

be shackled, hoisted, or placed on a table for bleeding. 

The gas must be administered in a way that produces surgical anesthesia quickly and 

calmly, with a minimum of excitement and discomfort to the animals. The establishment 

must maintain a uniform carbon dioxide concentration in the chamber so that the degree 

of anesthesia in exposed animals will be constant. The gas concentration and exposure 

time, also known as the dwell time, must be recorded graphically throughout each day’s 

operation. All gas-producing and control equipment must be maintained in good repair 

and all indicators, instruments, and measuring devices must be available for inspection 

by FSIS. 

Mechanical – Captive Bolt (9 CFR 313.15) 

There are two types of mechanical captive bolt stunners—penetrating and nonpenetrating—used to produce immediate unconsciousness in cattle, sheep, goats, 

swine, and equines. Both types have gun-type mechanisms that fire a bolt or shaft out of 

a muzzle. A measured charge of gunpowder (a blank cartridge) or accurately controlled 

compressed air propels the stunning bolt. A well-trained and experienced establishment 

employee may operate both types. The employee must be able to accurately and 

consistently position the stunning device so that the bolt hits the skull at the right location 

to produce immediate unconsciousness. The employee must also be able to adjust the 

air pressure or detonation charge when the sex, the breed, or the size of the animal 

changes. 

Some establishments have adopted a practice of “double knocking”—that is, the animals 

are stunned with two blows delivered in very rapid succession. The rationale behind this 

procedure is that the consequences of an animal regaining consciousness are so severe 

that establishment managers want to make certain that it will not happen. Therefore, 

there is a second blow as a “security stun” only. The important point to consider here is 

that to meet the statutory and regulatory requirements, the first stun must be effective at 

rendering the animal insensible to pain. 

When fired, the bolt in the penetrating type of captive bolt stunner penetrates the skull 

and enters the brain. Unconsciousness is caused by physical brain damage, sudden 

changes in intracranial pressure, and concussion. Penetrating captive bolt devices 

powered by compressed air must have accurate, constantly operating air pressure 

gauges. The gauges must be easily read and conveniently located for inspection by 

FSIS. The brain from animals stunned with penetrating captive bolts may be saved for 

edible purposes provided the establishment removes the large blood clots, bone 

splinters, hair, and debris from the brain. 

After a Bovine Spongiform Encephalopathy (BSE) positive cow was found in Washington 

State on December 2003, a number of policies were issued to protect the public health 

against BSE. One of these policies involved the prohibition of air-injection stunning of 

cattle. Air-injection stunning is a method of deliberately injecting compressed air into the 

cranial cavity as a part of the stunning process. Therefore, 9 CFR 313.15(b)(2)(ii) states 

“Captive bolt stunners that deliberately inject compressed air into the cranium at the end 

of the penetration cycle shall not be used to stun cattle.” This is to ensure that portions of 

the brain are not translocated into the tissues of the carcass as a consequence of 

humanely stunning cattle during the slaughter process. 

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Many establishments will use the non-penetrating type captive bolt in order to avoid the 

time-consuming task of physically removing large blood clots, hair, bone, splinters, and 

debris from the brain. The non-penetrating (concussion) bolt is similar to the penetrating 

bolt except that it has a bolt with a flattened circular head (mushroom head). When fired, 

the mushroom head meets the skull, but does not penetrate the brain. The animal 

becomes insensible from acceleration concussion and sudden changes in intracranial 

pressure. 

Accurate placement of the stunning blow is very important when using a non-penetrating 

captive bolt stunner. The amount of hair on the animal’s head will also have an impact 

on the effectiveness of the stunning blow. Because there is no physical destruction of 

the brain during non-penetrating stunning, close observation and rapid bleed-out is 

important post-stun to ensure the animal does not regain consciousness. 

Mechanical – Gunshot (9 CFR 313.16) 

Another type of mechanical device used for stunning is the firearm. It can be used on 

cattle, calves, sheep, goats, swine, and equine. The caliber of the firearm must be such 

that a single shot of a bullet or projectile into the animal must produce immediate 

unconsciousness. If a small-bore firearm is used, the regulations identify the following 

types of projectiles as acceptable: 

• Hollow pointed bullets 

• Frangible iron/plastic composition bullets 

• Powdered iron missiles 

Remember that the standard is that every animal is rendered insensible to pain 

(unconscious) by a single gunshot, regardless of the type of projectile used. 

Always consider your safety when observing stunning done with firearms. Ensure that 

you are out of the way of ricochet and standing away from the direction of fire. 

Regardless of the type of projectile, a large percentage of the brain, cheek meat, and 

head trimmings may contain whole or fragmented bullets. Therefore, regulation 9 CFR 

310.18(b) states that after the head is inspected, the brains, cheek meat, and head 

trimmings may not be saved for human food. The only portion of the head that can be 

salvaged for human food is the tongue. 

Electrical (9 CFR 313.30) 

The final method approved for stunning animals is electrical current. Electrical stunning 

is used for hogs, calves, sheep, and goats. While approved for use in cattle, this is not a 

common practice. It is most widely used for hogs. The animal is restrained so that the 

electric current can be applied with a minimum of excitement and discomfort. There are 

two types of electrical stunning—head-only and head-to-body (cardiac arrest) stunning. 

Head-only stunning induces a grand mal epileptic seizure, resulting in insensibility to 

pain. Cardiac arrest stunning will induce a grand mal epileptic seizure and cardiac 

fibrillation—essentially inducing a heart attack. This means that the head must be 

stunned first (or simultaneously with the heart) because to stun the chest first would 

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cause pain but not insensibility, which is a violation of the humane handling 

requirements. 

The placement of the electrodes varies from establishment to establishment. It can be 

across the head only (head-only stunning), on the head and thoracic region (cardiac 

arrest stunning), or across the head only then thoracic region only (two-phase stunning). 

The design of the stunning wand can vary considerably (one or two pieces). Whichever 

way is used, the current passing through the animal must be enough to ensure surgical 

anesthesia throughout the bleeding operation. The operator must control the timing, 

voltage, and current so that each animal is properly stunned. If too much current is 

applied in the stunning process, hemorrhages or other tissue changes can occur that 

could interfere with the inspection procedure. Too high an electrical current can damage 

capillaries, resulting in multiple pinpoint hemorrhages in the muscle tissue. This is 

commonly referred to as "splashing" or "speckling". If this condition is seen on the 

postmortem disposition rail, it would be prudent to investigate the stunning process and 

discuss the findings with establishment managers. 

To meet the statutory requirements, animals must be stunned prior to being shackled, 

hoisted, thrown, cast, or cut. With head-only stunning the stun to bleed interval should 

not exceed 30 seconds. This is not a regulatory timeframe, but if the “stun to stick” 

interval is prolonged, it could result in animals regaining or beginning to regain sensibility 

on the bleed rail. In cardiac arrest stunning, the stun to stick interval is not as critical 

because the animal is much less likely to regain sensibility. However, some 

establishments have had problems with cardiac arrest stunned animals regaining 

consciousness and stunning effectiveness must be verified on a regular basis. 

Ritual Slaughter (HMSA) 

Slaughtering is permitted without a stunning device in accordance with ritual 

requirements. An example would be kosher slaughter. The animal is fully conscious 

when the stick or cut takes place. In kosher slaughter, the cut is done by a shohet 

(slaughterer) chosen from the community, trained in the dietary laws of the Jewish 

religion, and supervised by a rabbi in his area. The cut is made with a razor-sharp knife 

called a chalef that is honed after each cut. 

In halal slaughter, a person of the Islamic faith or a designee performs the ritual cut. A 

prayer to Allah is recited during the procedure. You may see a lot of variation in how 

halal slaughter is done. Many religious authorities will accept stunning either before or 

after the ritual slaughter cut. If a ritual slaughter establishment does choose to use one 

of the approved stunning methods, either before or after the ritual cut, IPP will evaluate 

HATS Category VIII – Stunning Effectiveness (Chaper III. Section II.C. of the directive). 

The ritual slaughter cut and the handling and restraint that immediately precedes that cut 

is often called the “ritual bubble”. The activities that occur within that “ritual bubble” fall 

under Section 1906 of the HMSA and are protected as part of the Constitutional right of 

religious freedom. This does not mean that Agency personnel are to ignore completely 

what happens within the “ritual bubble”. What it means is that Agency personnel do not 

enforce humane handling regulations within that “ritual bubble”. That said, if you see 

something during the “ritual bubble” that concerns you, contact your immediate 

supervisor and the District Veterinary Medical Specialist (DVMS) for guidance on what 

action can be initiated. 

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It is important to understand that ritual slaughter establishments are required to meet all 

the humane handling regulatory requirements except stunning prior to shackling, 

hoisting, throwing, cutting, or casting. All animals must be unconscious or insensible to 

pain prior to any dressing procedures such as head removal, skinning, leg removal, ear 

removal, horn removal, or opening hide patterns. 

When you perform your humane verification activities in a ritual slaughter situation, you 

will observe all HATS categories except stunning effectiveness (unless the 

establishment chooses to employ one of the approved stunning methods either before or 

after the ritual cut). For example, you will verify the availability of water, check the 

condition of pens and ramps and that there is no excessive prodding in any part of the 

establishment when moving animals. You will also verify that after the ritual cut (and any 

additional cuts to facilitate bleeding) no dressing procedure (e.g., head removal, 

skinning, leg removal, ear removal, horn removal, opening the hide) is performed until 

the animal is insensible to pain. 

Assessing Unconsciousness (9 CFR 313.5, 313.15, 313.16, 313.30) 

Livestock must remain insensible to pain (unconscious) from the time they are stunned 

until they are dead. You can use the following signs to verify that animals are insensible 

to pain (unconscious): 

1. The head dangles from a flaccid (limp and flexible) neck. If the animals are 

suspended from an overhead rail, the head should hang straight down. This can 

be difficult to see if the animal is lying on its side. 

2. The tongue may hang straight down and out of the mouth. 

3. The eyelids should be wide open, and the pupils fully dilated so, at a distance, 

the eyes appear black. 

4. There is no vocalization—lowing, bellowing, bleating, or squealing. 

You may observe movement of the head and neck. This movement can be because of 

involuntary reflexes caused by random firing of damaged muscle neurons. It can be 

associated with movement of equipment. However, it may also be voluntary movement 

because the animal is regaining consciousness. 

Some of the signs that an animal might be returning to sensibility include: 

1. Rhythmic breathing. Keep in mind that anesthetized animals can breathe 

rhythmically, so this should only be assessed in conjunction with other signs. 

2. Eye reflex in response to touch. This sign is not used for electrically stunned 

animals. Also, be very aware of safety if using this method to check insensibility. 

3. Spontaneous natural eye blinks without touching the eye or eye area, or 

conscious eye movement. 

4. Tense and moving tongue or lips. 

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These signs need to be carefully assessed and interpreted, as they are indications that 

the animal may be returning to consciousness or that the stunning was ineffective. They 

are not, in and of themselves, a definitive determination that the animal is conscious and 

able to feel pain. 

A previously stunned animal that has regained sensibility (consciousness) may vocalize. 

It may also demonstrate a “righting reflex”. The term “righting reflex” is used to describe 

the physical actions taken by an animal to move itself into a normal lying, sitting, or 

standing posture. For example, a conscious cow hanging from a bleed rail will show a 

contracted back, stiff extended neck and rigid extended forelegs as it tries to pull itself 

into a normal upright position. An animal lying flat on its side may try to lift its head and 

may try to roll up onto its chest or stand. On occasion, you may see an animal’s neck 

flex laterally—that is, to one side—after it’s been stunned and hoisted. Do not mistake 

this sideways spasm for a “righting reflex”; make sure you look at the head to determine 

if the animal is unconscious. Vocalization and the righting reflex are always signs that 

the animal is conscious and able to feel pain. 

When assessing unconsciousness, you need to observe the animals at different places 

along the bleed rail. For example, you could perform verification just after stunning when 

the animal is in the shackle pit. Then, you could observe animals after they have been 

hanging on the bleed rail for several minutes. Always be aware of your safety when 

performing verification of unconsciousness. 

If you observe an animal regain consciousness after stunning, you must contact your 

supervisor immediately and take the actions described in the “Enforcement” section 

below. 

If the establishment participates in the Agriculture Marketing Service (AMS) National 

School Lunch Program (NSLP), determine whether the establishment is meeting the 

AMS Animal Welfare Requirements, including a review of all humane handling records 

generated in accordance with this program. If you have reason to believe that the 

establishment is not fully following its AMS NSLP humane handling obligations, notify 

your immediate supervisor and the DVMS. 

If the establishment has an identified robust systematic approach, verify that the 

establishment is following its written animal handling program. If the establishment is not 

following its program, first discuss your observations with establishment management. 

Document the discussions in a MOI. If the establishment continues to ineffectively 

implement its written animal handling program, notify your immediate supervisor and the 

DVMS of your concerns by email. 

Odd-Hour Verification Visits 

Performing unannounced humane handling verification at a time when IPP are not on 

duty is another component of HATS. Contact your immediate supervisor and the District 

Veterinary Medical Specialist (DVMS) if you think you need to perform humane handling 

verification when there is no assigned tour of duty for inspection and services. 

The IIC, in conjunction with the FLS and DVMS, determines how frequently IPP need to 

perform off-hour inspection to observe the livestock facilities and handling practices. 

This decision is based on establishment history or other observations, such as: 

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• A significant percentage of animals are unloaded outside normal hours of 

operation when Federal inspectors are not on duty. 

• Animals are frequently held over the weekend and automatic watering 

devices are not present in pens and/or that there is no access to food within 

24 hours of their receipt at the facility. 

• Animals delivered outside the regular tour of duties are found with injuries 

during ante-mortem inspection. 

• Non-ambulatory or disabled animals are being delivered to the establishment 

outside the regular tour of duty when inspection program personnel (IPP) are 

not on duty. 

• Phone calls have been received from eyewitnesses alleging inhumane 

handling practices during times when IPP are not on duty. 

All time incurred in the performance of off-hour inspection will be paid as nonreimbursable overtime. Document your observations on FSIS Form 8100-1 (updated as 

of June 2020 and available in the FSIS Forms Library), and record time under the 

appropriate HATS category in a directed Livestock Humane Handling Verification task 

on the date the odd hours inspection is conducted. If noncompliance is identified, write 

the NR on the date the odd hours inspection is conducted. 

Systematic Approach 

There is no regulatory requirement for an establishment to use a systematic approach to 

humane handling and no requirement that such approach, if used, be in writing. 

However, an establishment may choose to develop and implement in a robust way a 

written animal handling program that effectively addresses the four aspects of a 

systematic approach that FSIS outlined in the 2004 Federal Register Notice. For a 

systematic approach to be considered “robust,” it would have to be written. These four 

steps are: 

1. Conduct an initial assessment of where, and under what circumstances, 

livestock may experience excitement, discomfort, or accidental injury while being 

handled in connection with slaughter, and of where, and under what 

circumstances, stunning problems may occur; 

2. Design facilities and implement practices that will minimize excitement, 

discomfort, and accidental injury to livestock; 

3. Evaluate periodically the handling methods the establishment employs to ensure 

that those methods minimize excitement, discomfort, or accidental injury and 

evaluate those stunning methods periodically to ensure that all livestock are 

rendered insensible to pain by a single blow; and 

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4. Respond to the evaluations, as appropriate, by addressing problems 

immediately and by improving those practices and modifying facilities when 

necessary to minimize excitement, discomfort, and accidental injury to livestock. 

If the establishment has a robust systematic approach, FSIS will take that into 

consideration should it be necessary to determine how to proceed when an incident 

occurs that involves egregious inhumane treatment. 

When establishment management states that it believes it has an animal handling 

program that equates to a robust systematic approach, you are to ask to review the 

program and any records generated during its implementation. As a part of performing 

your daily humane handling verification task, which includes observations for the 

Humane Activities Tracking System (HATS), observe the establishment employees 

handle and slaughter animals. Verify that establishment employees are following their 

animal handling program and are implementing effective corrective actions when 

appropriate. 

Recognize that the establishment is not required to provide you access to a written 

humane handling program. However, without access to the written program, you will not 

be able to verify effective implementation of a humane handling program that the 

establishment considers as systematic. Because a documented systematic approach is 

not a regulatory requirement, failure to implement provisions of such a program is not a 

noncompliance unless such failure to implement results in an identifiable failure to meet 

specific regulatory requirements. 

If an establishment claims to have implemented a robust systematic approach, but you 

observe that the establishment is not following the written animal handling program, first 

discuss your observations with establishment management and document this 

discussion in a MOI. If you continue to observe ineffective implementation of the animal 

handling program, notify the DO (DVMS) and your immediate supervisor of your 

concerns by email. This notification serves as documentation of your concerns. 

Enforcement 

The thought process that you should follow when performing humane handling 

verification includes: 

1. Is there noncompliance? 

2. If so, is it egregious? 

3. What action(s) should be taken? 

If you observe a humane handling noncompliance, you must take immediate action if 

animals are being harmed. For example, if you observe an employee driving livestock 

with an instrument (e.g., the edge of a shovel, a pointed metal prod) that can cause 

injury, you must stop that action from continuing. 

Once that is done, your next step is to decide if the noncompliance is egregious or nonegregious, because the actions you take will be dictated by that determination. An 

egregious humane handling noncompliance is so serious that it warrants an immediate 

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suspension of the assignment of inspectors under the authority of the Rules of Practice 

(9 CFR 500.3(b)). 

Non-egregious Noncompliances 

When a noncompliance is observed, 9 CFR Part 313.50 specifies a progression of 

enforcement actions allowing for an escalating response by IPP when the establishment 

does not comply with the humane slaughter of livestock regulations. 

• First, notify establishment management of the humane handling noncompliance, 

if not already done when addressing the needs of the animal. 

• Second, request that establishment management immediately correct the 

situation and take the necessary steps to prevent recurrence. 

• Third, document the noncompliance in a noncompliance record (NR). 

If necessary, take a regulatory control action (RCA) to prevent further injury to animals or 

to prevent injuries from occurring to other animals. You will also take the appropriate 

regulatory control action if you do not receive an adequate response or corrective 

actions to the NR or if the noncompliance observed continues to occur. The appropriate 

regulatory control action depends on the nature of the noncompliance. Remember that 

the goals of applying a tag are to control the situation and prevent further injury or 

distress to animals. 

• If the noncompliance is the result of facility deficiencies, disrepair, or equipment 

breakdown, but is not immediately causing injury or distress to livestock, attach a 

U.S. Retained/Rejected tag to the noncompliant equipment/pen/etc. 

Noncompliance examples include holes in pen floors or fences that can 

trap/injure an animal’s legs or feet. 

• If the noncompliance is the result of establishment employee actions in the 

handling or moving of livestock and animals are being injured or treated 

inhumanely, attach the tag either at a point specific to the location and nature of 

the violation or to the alleyways leading to the stunning area. Noncompliance 

examples include animals driven faster than a normal walking speed or animals 

slipping and falling because of slick floors. 

The tag will remain in place until the establishment operator implements appropriate 

immediate actions and measures to prevent recurrence. The tag shall not be removed 

by anyone other than an inspector. All livestock slaughtered prior to the tagging may be 

dressed, processed, or prepared under inspection. 

Whenever a non-egregious noncompliance with the humane slaughter requirements is 

observed, inspection personnel must document the incident in a NR and send a copy to 

the DVMS at the District Office. It is important that it clearly and specifically describe 

exactly what was observed, including any response by the animal (if the noncompliance 

involved animal discomfort or injury). Specify all the relevant regulations that pertain to 

the incident. At the top of Block 10 (where the noncompliance is described) on the NR, 

list the HATS category (or categories) you were performing when you saw the 

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noncompliance. If the noncompliance is covered by a second HATS category, note both 

categories on the NR. 

If the establishment continues to have noncompliances or does not adequately correct 

previously documented noncompliances, the IIC is to communicate this to the FLS and 

DVMS. The IIC will work with the FLS and DVMS to determine if a Notice of Intended 

Enforcement (NOIE) should be issued for multiple noncompliances. 

Egregious Noncompliances 

Under the Rules of Practice, 9 CFR 500.3(b), FSIS can suspend assignment of 

inspectors at an establishment without prior notification for humane handling 

noncompliances. Humane handling noncompliances for which immediate suspension is 

warranted are termed “egregious.” 

So, what is an egregious noncompliance? Webster’s Dictionary defines egregious as 

“conspicuously bad or flagrant.” The Agency defines it as any act or condition that 

results in severe harm to animals, for example: 

1. Making cuts on or skinning conscious animals; 

2. Excessive beating or prodding of ambulatory or non-ambulatory disabled animals 

or dragging of conscious animals; 

3. Driving animals off semi-trailers over a drop off without providing adequate 

unloading facilities (animals are falling to the ground); 

4. Running equipment over animals; 

5. Stunning of animals and then allowing them to regain consciousness; 

6. Failing to immediately (or promptly) render an animal unconscious after a failed 

initial stunning attempt (e.g., no planned corrective actions); 

7. Multiple ineffective stun attempts (2 or more) that are due to one or more of the 

following establishment failures to properly handle or stun the animal: 

a. Failure to immediately (or promptly) apply the corrective actions that 

demonstrates a blatant disregard for animal discomfort and excitement; 

b. Failure to adequately restrain an animal; 

c. Failure to use adequate stunning methods (e.g., inadequate air pressure, 

inadequate caliber, insufficient electric current) for the animal being stunned 

(e.g., species of animal, size of animal, etc.); 

d. Poorly trained/untrained operator of inexperienced operator; or 

e. Prolonged discomfort and excitement of the animal due to the inability to 

render it insensible/unconscious after the application of the immediate (or 

prompt) corrective actions. 

8. Dismembering conscious animals, for example, cutting off ears or removing feet; 

9. Leaving disabled livestock exposed to adverse climate conditions while awaiting 

disposition; or 

10. Otherwise causing unnecessary pain and suffering to animals, including 

situations on trucks. 

This is a list of some actions that are considered egregious. Each incident of inhumane 

slaughter or handling needs to be assessed individually by IPP. 

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If you observe a violation that you believe is egregious, your next set of actions will 

depend on whether or not you are the IIC. If you are the IIC, place a U.S. 

Retained/Rejected tag at the appropriate place and inform establishment management 

that you are communicating with the FLS, District Office and DVMS to discuss the 

incident and recommend that a suspension without notification be imposed in 

accordance with 9 CFR 500.3(b). 

If you are not the IIC, attach a U.S. Retained/Rejected tag at the appropriate place, and 

inform establishment management that you are taking a regulatory control action and 

that no more animals can be slaughtered until you contact the IIC. Whichever action is 

taken, all livestock slaughtered before the action may be dressed, processed, or 

prepared under inspection. 

The IIC will immediately notify the FLS, District Office and the DVMS of the incident to 

discuss and recommend a suspension action. 

The IIC will also document the facts that serve as the basis of the suspension action in a 

noncompliance record (NR) and promptly provide that information electronically to the 

DO and the DVMS for their use. The NR will form the basis of the Notice of Suspension 

documented by the DVMS and DO staff and of the Administrative Enforcement Report. 

NOTE: Until September 2020, IPP were instructed to issue an MOI in response to 

observations of egregious inhumane handling. FSIS Directive 6900.2, Revision 3 directs 

IPP to issue an NR for any humane handling noncompliance, whether egregious or nonegregious. 

Delayed Implementation – Egregious Noncompliances 

The IIC may also recommend the District Office delay implementing the suspension 

action if immediate action is likely to result in further inhumane treatment of additional 

animals, until he/she can ensure that animals on-site or in-transit have been handled 

humanely. An example is a line stoppage that may result in animals having to stay on a 

truck on an extremely hot day. The IIC should encourage establishment management to 

redirect as many animals that are en route as possible and to order the stoppage of 

further loading of animals onto trucks at the source location. The IIC needs to consider: 

• What immediate corrective action is the establishment taking? 

• How likely is it, given the establishment's history, that the corrective action will be 

effective in preventing a recurrence of the root cause of the situation? 

• How many animals are on premises or en route that will need to be slaughtered? 

• What conditions threaten the welfare of the animals if they are not promptly 

slaughtered? 

The IIC needs to let the District Office know that the suspension action should be 

delayed to prevent the further inhumane treatment of animals. Also, a line inspector 

trained in humane handling must be moved to an appropriate area to directly observe 

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establishment employees handling or slaughtering animals, which may require a line 

speed adjustment according to staffing standards in 9 CFR 310.1. 

The IIC may allow slaughter to continue at a reduced line speed for a limited time on her 

or his own authority. This is not intended for a “kill-out” of animals at the facility; it is only 

for a “kill-down” to ensure that the number of animals to be held on-site meets the 

requirements for holding animals overnight. Contact your supervisor if you are 

concerned about allowing slaughter to continue at reduced line speeds. 

When the IIC determines that animals will not be subjected to inhumane handling, the 

suspension must be promptly implemented. IICs are to document their observations and 

actions in a MOI and submit it to the District Office. 

Enforcement Discretion – Egregious Noncompliances 

When certain conditions are met, the IIC can recommend that the egregious act be 

subject to enforcement discretion and recommend issuance a Notice of Intended 

Enforcement (NOIE) rather than a notice of suspension. This would be when the 

establishment has met all the following conditions: 

• Does not have any recent humane handling related enforcement actions; 

• Has consistently been meeting the humane handling regulatory requirements; 

• Has been operating under a written animal handling program that establishment 

management has proffered as a robust systematic approach and made 

accessible to IPP; and 

• Has demonstrated the robustness of the program to IPP by effectively and 

consistently implementing all aspects of its program. 

The discretion to recommend this enforcement action is based on the Rules of Practice 

regulation (9 CFR 500.3(b)) which states: “FSIS also may impose a suspension without 

providing the establishment prior notification because the establishment is handling or 

slaughtering animals inhumanely.” In determining whether the egregious act is an 

anomaly, and whether the establishment should be allowed to continue to operate, the 

IIC, FLS, DO, and DVMS are to consider: 

• Whether the establishment is operating under an animal handling program that 

provides for how the establishment will respond if an unforeseeable event of this 

type occurs; 

• Whether there is any basis for concern that the planned response in the 

establishment’s animal handling program will not effectively address the problem; 

and 

• Whether the establishment has consistently and effectively implemented their 

animal handling program over time. 

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NOTE: If an establishment is suspended (Notice of Suspension (NOS)) or receives a 

Notice of Intended Enforcement Action (NOIE) due to an egregious inhumane handling 

or slaughter event, they will no longer be considered by FSIS to have a robust 

systematic approach. The establishment will need to proffer corrective actions and 

preventive measures to the DO in order to develop a verification plan. The establishment 

may request a review of their system after the suspension has been lifted to determine if 

their system is again robust. 

Exotic Species 

Exotic animals (voluntary inspection) are covered under 9 CFR 352.10. This section 

includes regulations that address humane handling during ante-mortem inspection and 

stunning practices to render animals unconscious. The regulation states, “Humane 

handling of an exotic animal during ante-mortem inspection shall be in accordance with 

the provisions contained in 9 CFR 313.2”. This covers unloading procedures, methods of 

moving exotics through the holding facility, handling of disabled animals, access to water 

and feed if held over 24 hours, and the effective application of stunning methods. 9 CFR 

Part 352.10(a)(5) states that “Stunning to render the animals unconscious shall be in 

accordance with 313.15 or 313.16.”, which are the stunning by captive bolt and by 

gunshot sections of the humane handling regulations, respectively. 

Livestock specified by 9 CFR 352 include antelope, bison, buffalo, catalo (cattalo), and 

deer. Additionally, exotic animals are defined by 9 CFR 352.1(k) as any reindeer, elk, 

deer, antelope, water buffalo or bison. 

If you have questions or concerns about repetitive noncompliances with exotic animal 

humane handling and slaughter, contact the DVMS. Although we cannot take action 

under the Rules of Practice, 9 CFR 500.3(b), these issues can be effectively addressed. 

If IPP observe an egregious humane handling noncompliance, they should immediately 

take a regulatory control action to prevent continued egregious humane handling and 

orally notify the establishment management that the District is being contacted. IPP will 

then work with the DVMS and District Office personnel to document the noncompliance 

in an MOI, and District Office personnel may initiate a denial of service action. 

Custom Exempt Operations 

The FMIA (21 U.S.C. 610(b)) prohibits slaughter or handling of livestock in connection 

with slaughter in any manner not in accordance with 7 U.S.C. 1901-1906 (HMSA). This 

applies to all animals on the premises of a federally-inspected establishment whether 

those animals are designated for slaughter under federal inspection or for slaughter 

under a Custom Exempt program. 

When FSIS IPP are on-site performing assigned official duties related to regulated 

product, and there is concurrent handling and slaughter of livestock under a Custom 

Exempt program, Agency expectations are that if IPP observe inhumane handling or 

slaughter practices of custom exempt livestock, they are to take the following actions: 

• Immediately notify establishment management of their observations and request 

that establishment management address the issue; 

• Document their observations in an MOI; 

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• Provide a copy of the MOI by email to their immediate supervisor, and to the 

DVMS or a DDM if the DVMS is not available. 

• Provide a copy of the MOI (printed or electronic) to establishment management. 

The District management team will take any further actions.

Poultry Good Commercial Practices (GCP) Verification 

There is no humane handling statute requiring humane handling for poultry. However, 

there is a regulatory requirement that poultry be slaughtered using Good Commercial 

Practices (GCP). This regulatory requirement will be verified while performing the Poultry 

Good Commercial Practices task. 

In the PPIA Section 453(g)(5), a poultry product is adulterated if, among other 

circumstances, it is in whole, or in part, the product of any poultry which has died 

otherwise than by slaughter. The regulations require that poultry be slaughtered in 

accordance with good commercial practices, in a manner that will result in thorough 

bleeding of the poultry carcass and will ensure that breathing has stopped before 

scalding (9 CFR 381.65(b)). Poultry that are still breathing on entering the scalder die 

from drowning, not from slaughter, and are considered adulterated and unfit for human 

food. These “cadavers” are automatically condemned on post-mortem inspection per 9 

CFR 381.90. 

On September 28, 2005, the Agency published a Federal Register Notice, Docket No. 

04-037N, Treatment of Live Poultry Before Slaughter. In that FR Notice, humane 

handling terminology was used for the first time by the Agency when describing the live 

poultry being handled in a way consistent with good commercial practices. FSIS went on 

to describe a systematic approach for industry to use. The Agency defined a “systematic 

approach” as one in which establishments focus on treating poultry in such a manner as 

to minimize excitement, discomfort, and accidental injury the entire time that live poultry 

is held in connection with slaughter. Recognize that this approach is voluntary on the part 

of industry. Also recognize that it signals a change by the Agency to a more assertive 

approach to the handling of live poultry. 

FSIS Directive 6100.3, Ante-Mortem and Post-Mortem Poultry Inspection and FSIS 

Directive 6110.1, Verification of Poultry Good Commercial Practices provide guidance on 

performing GCP verification activities. Additional information is available in a Humane 

Interactive Knowledge Exchange—HIKE 01-05—addressing the issue of humane 

handling of poultry. It discusses the observation of still-breathing chickens entering the 

scald tank and identifies the enforcement actions that are taken by IPP when 

noncompliance with regulatory requirements is observed. 

GCP Verification Activities 

IPP assigned to poultry slaughter facilities are expected on a daily, per shift basis when 

the establishment slaughters, to perform a Poultry Good Commercial Practices 

Verification task. 

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To perform the task, you will do the following: 

• Schedule the task on your Task Calendar in PHIS. 

• Initiate or claim the task in PHIS by selecting the component in the Inspection 

Results section of PHIS. 

• Visit the receiving through pre-scald areas to systematically observe whether 

establishment employees are mistreating birds or handling them in a way that will 

cause death or injury or prevent thorough bleeding or result in excessive 

bruising. 

• Record the task outcome in Inspection Results by selecting the verified 

regulations and checking the appropriate boxes. If noncompliance is found, 

complete the Noncompliance Record (NR). 

Some things to look for include: 

• Establishment employees breaking birds’ legs to hold them in the shackles, 

• Birds frozen inside cages or frozen to the cages in cold weather, 

• Birds dead from heat exhaustion—you would primarily see heavy panting in 

poultry suffering from heat stress, or 

• Establishment employees driving over live birds with equipment or trucks in 

the unloading or live hang area. 

If the poultry are stunned prior to bleeding, check the stunning equipment to ensure it is 

functioning properly. Poultry that have been effectively stunned will have an arched neck 

and tucked-in wings posture. 

Check in the bleeding area to determine if the bleeding equipment is functioning 

properly. One way that you might be alerted to problems with the bleeding equipment is 

if the line inspectors report increased number or clusters of cadavers at inspection 

stations or increased numbers of bruised wings or legs. 

Once a week, IPP are to randomly select a day to review establishment records 

documenting adherence to good commercial practices. This review takes the place of 

observation in the receiving through pre-scald areas. Recognize that establishments are 

not required to maintain written records of good commercial practices. If records are not 

kept, IPP are to visit the receiving through pre-scald areas as above. 

If such records are kept and made available, IPP are to review a sample of the records 

and assess whether there is evidence that the establishment is monitoring its GCPs in 

the receiving through pre-scald areas. An establishment may use video surveillance of 

live poultry handling areas and can offer this as a form of record. IPP are also to 

determine if there is enough information in the records to judge that the establishment is 

following good commercial practices. If there is not enough information to make that 

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judgment, IPP are to visit the receiving through pre-scald areas to verify compliance with 

the statute and regulations. 

Enforcement 

During poultry handling and slaughter, IPP are to document through NRs or MOIs 

establishment failure to follow GCP. From a regulatory perspective, adherence to GCP is 

a process control issue and not a bird-by-bird performance standard issue. 

If the establishment is not following good commercial practices, and birds are dying 

other than by slaughter, you are to document a noncompliance record citing 9 CFR 

381.65(b), using the poultry good commercial practices task in PHIS. IPP are to write 

NRs for GCP noncompliance only when they can demonstrate that an establishment has 

lost process control and that there is an ongoing trend of birds dying otherwise than by 

slaughter. 

Writing a GCP NR 

1. IPP are to document loss of process control by the establishment, and thus not 

operating in accordance with GCPs, when there is repeated occurrence of birds: 

a. Dying otherwise than by slaughter (repeatedly entering the scalding tank 

while still breathing); and 

b. Not being appropriately bled out (as evidenced by equipment malfunction that 

results in increased numbers or clusters of cadavers being condemned); or 

c. Being intentionally and repeatedly mistreated by establishment personnel. 

2. IPP should consider the following questions to determine if there has been a loss 

of process control: 

a. What is the problem? 

b. How long did the problem last? 

c. How did the establishment react? 

d. How did they correct the problem, and did it recur? 

e. What were the periods of control? 

3. IPP are to document the noncompliance with 9 CFR 381.65(b) when the 

establishment is not following GCPs. An isolated incident does not represent a 

loss of process control and should be documented in a mistreatment MOI, not an 

NR. IPP are not to quote the Humane Methods of Slaughter Act of 1978. Refer 

to attachments 1 and 2 of FSIS Directive 6110.1 for an example of an NR for 9 

CFR 381.65(b) noncompliance in PHIS. 

Poultry Mistreatment MOIs 

Poultry Mistreatment MOIs are primarily issued when the establishment is mistreating 

birds at any point prior to the kill step, but the mistreatment event does not demonstrate 

that the establishment’s process is out of control. The MOI documents the discussion 

between IPP and establishment management about the poultry mistreatment event. In 

addition, you are to document the discussion and any planned actions on the part of the 

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establishment in a MOI. Give a copy of the MOI to establishment management, keep a 

copy in the inspection file, and send a copy to the DVMS. 

1. IPP should document a poultry mistreatment MOI when, for example: 

a. Isolated instance of a bird still breathing when entering the scalder. 

b. Unusually high number of injuries to birds such as broken legs, wings, but 

no evidence of intentional mistreatment. 

2. After observing poultry mistreatment, IPP should: 

a. Notify the establishment immediately. 

b. Discuss the mistreatment after the event is resolved and advise the 

establishment that preventing mistreatment decreases the production of 

adulterated carcasses. 

c. Document the discussion, and any further planned actions proffered by 

the establishment. 

DVMS 

The District Veterinary Medical Specialist (DVMS) will review the MOIs and GCP NRs 

and determine if additional action is warranted. The correlation includes review to 

determine accuracy and consistency of documentation. In specific situations, after 

review of mistreatment MOIs, the DVMS may need to notify appropriate state officials. 

If you have questions or concerns about what you observe during poultry slaughter, 

contact the DVMS for guidance. 

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Attachment 1 

Overview of the Humane Handling and Slaughter Regulations (9 CFR 313) 

A. Regulations related to livestock pens, driveways and ramps 

9 CFR section 313.1 states: 

(a) Livestock pens, driveways and ramps shall be maintained in good repair. They shall 

be free from sharp or protruding objects which may, in the opinion of the inspector, 

cause injury or pain to the animals. Loose boards, splintered or broken planking and 

unnecessary openings where the head, feet, or legs of an animal may be injured shall be 

repaired. 

(b) Floors of livestock pens, ramps, and driveways shall be constructed and maintained 

so as to provide good footing for livestock. Slip resistant or waffled floor surfaces, 

cleated ramps and the use of sand, as appropriate, during winter months are examples 

of acceptable construction and maintenance. 

(c) U.S. Suspects (as defined in 9 CFR 301.2(xxx)) and dying, diseased, and disabled 

livestock 9 CFR 301.2(y) shall be provided with a covered pen sufficient, in the opinion 

of the inspector, to protect them from the adverse climatic conditions of the locale while 

awaiting disposition by the inspector. 

(d) Livestock pens and driveways shall be so arranged that sharp corners and direction 

reversal of driven animals are minimized. 

B. Regulation related to handling of livestock 

9 CFR section 313.2 states: 

(a) Driving of livestock from the unloading ramps to the holding pens and from the 

holding pens to the stunning area shall be done with a minimum of excitement and 

discomfort to the animals. Livestock shall not be forced to move faster than a normal 

walking speed. 

(b) Electric prods, canvas slappers, or other implements employed to drive animals shall 

be used as little as possible in order to minimize excitement and injury. Any use of such 

implements which, in the opinion of the inspector, is excessive, is prohibited. Electrical 

prods attached to AC house current shall be reduced by a transformer to the lowest 

effective voltage not to exceed 50 volts AC. 

(c) Pipes, sharp or pointed objects, and other items which, in the opinion of the 

inspector, would cause injury or unnecessary pain to the animal shall not be used to 

drive livestock. 

(d) Disabled livestock and other animals unable to move. 

(1) Disabled animals and other animals unable to move shall be separated from normal 

ambulatory animals and placed in the covered pen provided for in section 313.1(c). 

(2) The dragging of disabled animals and other animals unable to move, while 

conscious, is prohibited. Stunned animals may, however, be dragged. 

(3) Disabled animals and other animals unable to move may be moved, while conscious, 

on equipment suitable for such purposes; e.g., stone boats. (e) Animals shall have 

access to water in all holding pens and, if held longer than 24 hours, access to feed. 

There shall be sufficient room in the holding pen for animals held overnight to lie down. 

(f) Stunning methods approved in section 313.30 shall be effectively applied to animals 

prior to their being shackled, hoisted, thrown, cast or cut. 

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C. General regulatory requirements related to approved stunning methods 

Appropriate stunning methods are required for an establishment to be in compliance with 

the HMSA. When stunning is done correctly, animals feel no pain, are rendered instantly 

unconscious, and remain unconscious until slaughtered. There are four methods of 

stunning approved for livestock. A summary of these approved stunning methods 

appears below (refer to 9 CFR sections 313.5, 313.15, 313.16 and 313.30). 

Chemical; carbon dioxide 

Regulatory requirements for the use of carbon dioxide as a humane method of slaughter 

are specified in section 313.5 and include, among other things, the following: 

1) Carbon dioxide gas may be used to slaughter and handle sheep, calves and swine. 

2) The carbon dioxide gas shall be administered in a chamber so as to produce surgical 

anesthesia (a state where an animal feels no painful sensation) before the animal is 

shackled, hoisted, thrown, cast, or cut. Animals shall be exposed to the carbon dioxide 

gas in a way that will accomplish the anesthesia quickly and calmly. 

3) Gas concentrations and exposure times shall be graphically recorded throughout 

each day’s operation. 

4) It is necessary that the operator be skilled, attentive, and aware of his or her 

responsibility. 

Mechanical; captive bolt 

Regulatory requirements for the use of captive bolt stunners as a humane method of 

slaughter are specified in section 313.15 and include, among other things, the following: 

1) Captive bolt stunners may be used to slaughter and handle sheep, swine, goats, 

calves, cattle, horses, mules, and other equines. 

2) The captive bolt stunners shall be applied to livestock so as to produce immediate 

unconsciousness in the animals before they are shackled, hoisted, thrown, cast, or cut. 

3) The stunning operation is an exacting procedure and requires a well-trained and 

experienced operator who must use the correct detonating charge with regard to kind, 

breed, size, age, and sex of the animal to produce the desired results. 

4) Stunning instruments must be maintained in good repair. 

Mechanical; gunshot 

Regulatory requirements for the use of gunshot as a humane method of slaughter are 

specified in section 313.16 and include, among other things, the following: 

1) Shooting by firearms may be used to slaughter and handle cattle, calves, sheep, 

swine, goats, horses, mules, and other equines. 

2) A single shot delivery of a bullet or projectile into the animal is to produce immediate 

unconsciousness in the animal before it is shackled, hoisted, thrown, cast or cut. 

3) Firearms must be maintained in good repair. 

4) The shooting operation is an exacting procedure and requires a well-trained and 

experienced operator who must be able to accurately direct the projectile to produce 

immediate unconsciousness. 

5) The operator must use the correct caliber firearm, powder charge and type of 

ammunition to produce instant unconsciousness in the animal. 

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Electrical; stunning or slaughtering with electric current 

Regulatory requirements for the use of electric current as a humane method of slaughter 

are specified in section 313.30 and include, among other things, the following: 

1) Electric current may be used to slaughter swine, sheep, calves, cattle, and goats. 

2) The animal shall be exposed to the electric current in a way that will accomplish 

surgical anesthesia (a state where an animal feels no painful sensation) quickly and 

effectively before they are shackled, hoisted, thrown, cast, or cut. 

3) It is necessary that the operator of electric current application equipment be skilled, 

attentive, and aware of his or her responsibility. 

4) Suitable timing, voltage and current control devices shall be used to ensure that each 

animal receives the necessary electrical charge to produce immediate 

unconsciousness.9 

Enforcement 

CFR 313.50 Tagging of equipment, alleyways, pens, or compartments to prevent 

inhumane slaughter or handling in connection with slaughter. 

When an inspector observes an incident of inhumane slaughter or handling in 

connection with slaughter, he/she shall inform the establishment operator of the incident 

and request that the operator take the necessary steps to prevent a recurrence. If the 

establishment operator fails to take such action or fails to promptly provide the 

inspector with satisfactory assurances that such action will be taken, the inspector shall 

follow the procedures specified in paragraph (a), (b), or (c) of this section, as 

appropriate. 

(a) If the cause of inhumane treatment is the result of facility deficiencies, disrepair, or 

equipment breakdown, the inspector shall attach a ``U.S. Rejected'' tag thereto. No 

equipment, alleyway, pen or compartment so tagged shall be used until made 

acceptable to the inspector. The tag shall not be removed by anyone other than an 

inspector. All livestock slaughtered prior to such tagging may be dressed, processed, or 

prepared under inspection. 

(b) If the cause of inhumane treatment is the result of establishment employee actions in 

the handling or moving of livestock, the inspector shall attach a ``U.S. Rejected'' tag to 

the alleyways leading to the stunning area. After the tagging of the alleyway, no more 

livestock shall be moved to the stunning area until the inspector receives satisfactory 

assurances from the establishment operator that there will not be a recurrence. The tag 

shall not be removed by anyone other than an inspector. All livestock slaughtered prior 

to the tagging may be dressed, processed, or prepared under inspection. 

(c) If the cause of inhumane treatment is the result of improper stunning, the inspector 

shall attach a ``U.S. Rejected'' tag to the stunning area. Stunning procedures shall not 

be resumed until the inspector receives satisfactory assurances from the establishment 

operator that there will not be a recurrence. The tag shall not be removed by anyone 

other than an inspector. All livestock slaughtered prior to such tagging may be dressed, 

processed, or prepared under inspection. 

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