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July 30, 2020 

VIA EMAIL 

Freedom of Information Act Officer

USDA, Food Safety and Inspection Service 

Room 2168 South Building 

1400 Independence Ave., SW 

Washington, DC 20250 

fsis.foia@usda.gov

Re: FOIA Request: Good Commercial Practices Documents 

Dear FOIA Officer:

This letter is a request for public records made on behalf of Farm Sanctuary, pursuant to the 

Federal Freedom of Information Act (FOIA), 5 U.S.C. § 552 et seq. This request satisfies the 

written request requirement pursuant to 7 C.F.R. § 1.5(a). 

Farm Sanctuary hereby requests that you please provide the following documents related to poultry 

slaughter establishment good commercial practices (GCP):

1. All 04C05 inspection task records for non-compliance related to the humane treatment 

of poultry under the PPIA, including Noncompliance Records (NRs), and Memoranda 

of Interview (MOIs), issued during the period from December 12, 2019 through the 

date this request is processed. 

2. All remaining records in FSIS’s possession related to the humane treatment of poultry 

under the PPIA, including Memoranda of Interview, Letters of Concern, and Letters of 

Cause, issued during the period from December 12, 2019 through the date this request 

is processed. 

Please provide the records in the format that will ensure the most expedient response (e.g., 

electronically, by hard copy, or on CD-ROM). Please provide the records as soon as they are 

available.

If you deny access to any of the requested records or otherwise deny any part of this request, 

please provide Farm Sanctuary with all reasonably segregable, non-exempt portions of the 

relevant records. See 5 U.S.C. § 552(b). Additionally, please describe the deleted material in 

detail, cite the statutory basis for the denial, and explain the basis for your belief that the material 

FOIA-2020-00471

Rec'd 7-31-2020
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is exempt. Farm Sanctuary further requests that you separately state your reasons for not 

invoking your discretionary powers to release the requested documents in the public interest. 

Finally, please notify Farm Sanctuary of any appeal procedures available under the law, as well 

as the office and address where such an appeal can be sent.

We also request that, consistent with the 1996 amendments to FOIA, and the FOIA Improvement 

Act of 2016, FSIS post all inspection task records for non-compliance related to the humane 

treatment of poultry under the PPIA, including Noncompliance Records (NRs), and Memoranda

of Interview (MOIs) and all remaining records in FSIS’s possession related to the humane 

treatment of poultry under the PPIA, including Memoranda of Information, Letters of Concern, 

and Letters of Cause online in the agency’s electronic reading room, for review by Farm 

Sanctuary and other interested members of the public. These documents have been released by 

FSIS and requested at least three times; additionally, because of these documents’ subject matter, 

these are and will continue to be the subject of numerous requests for substantially the same 

records. Accordingly, we request that FSIS proactively make these documents available in its 

electronic reading room and post all such documents that it produces to FOIA requesters online 

from this point forward. 

Fee Waiver

Farm Sanctuary is a nonprofit organization that was founded in 1986 to combat the abuses of 

factory farming and encourage a new awareness and understanding about farm animals. Today, 

Farm Sanctuary is the nation’s largest and most effective farm animal rescue and protection 

organization. The information sought in this request will be used to educate the public about the 

treatment of farm animals in slaughter facilities. The information the records contain would 

contribute significantly to the public understanding of humane and public health issues at major 

slaughter facilities as well as the evidence relied upon by the agency in reaching decisions 

regarding the treatment of farm animals.

The records covered by this request are not posted publicly or otherwise published, and Farm 

Sanctuary has no intention to use the information disclosed under this request for financial gain. 

If, however, the waiver is denied and the request will involve more than two search hours or 

more than 100 pages of documents, and fees will exceed twenty dollars ($20.00), please notify 

Farm Sanctuary immediately by telephone before the request is processed so that Farm 

Sanctuary can decide whether to pay the additional fees or to appeal the denial of the request for 

waiver. 
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If you have any questions regarding this request, you may contact me at or 

The records and any related correspondence should be sent 

to my attention at the address above. 

Sincerely,

Emily von Klemperer

General Counsel

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