Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 315

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P764 Perdue Foods, LLC CUA46060

81527G

27AUG2019 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview 

                                                                                     

                                                                 August 27,

2019 

                                                                                     

                                                                 Perdue

Foods, LLC 

                                                                                     

                                                                 P-764 

                                                                                     

                                                                 Salisbury,

MD Attendees:                ,

 Perdue Foods, LLC 

               

, Perdue Foods, LLC                .

 USDA, P-764 A

meeting was held at 0735 hours in the USDA

Doctors’ Office of P-764, Perdue Foods, LLC in

Salisbury, Maryland between establishment

management and USDA (as directed by FSIS

Directive 6110.1).  I identified myself as 

.  The

establishment management acknowledged they

understood my official capacity through the

conversation. I told and that

the reason for the meeting this morning was an

incident of poultry welfare concern that I had just

observed in the receiving department.  While

performing the poultry good commercial practices

inspection in the receiving department, I was

checking the birds at the dead-on-arrival (DOA)

sorting area and the DOA collection dumpster.  At

0726 hours I observed within the DOA collection

dumpster there were approximately 200 birds and

there was movement noted.  I observed that there

was a bird breathing rhythmically amongst the

pile of denatured birds.  I immediately notified

 who had to

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

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 316

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

remove 2 dead birds from the pile to reveal the

live bird breathing beneath them.  This bird was

responsive when picked up and continued

breathing and moving.  

euthanized this bird upon its

removal from this pile.  

 was also present

and observed these findings.   I reminded the

establishment management that the PPIA and

Agency regulations require that live poultry be

handled in a manner that is consistent with good

commercial practices and that they not die from

causes other than slaughter.  I notified them that

this MOI would be forwarded to the Raleigh

district office and to the District Veterinary

Medical Specialist (DVMS) in case additional

follow-up was recommended. I attest that this

memorandum includes all the information

discussed during the meeting to the best of my

knowledge.  

at P-764, Salisbury, MD)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 317

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P764 Perdue Foods, LLC CUA23131

10112G

12NOV2019 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview November 12, 2019

Perdue Foods, LLC P-764 Salisbury, MD 

Attendees: 

SDA, P-764 A meeting was

held at 1305 hours in the USDA SPHV office of

P-764, Perdue Foods, LLC in Salisbury, Maryland

between establishment management and USDA

(as directed by FSIS Directive 5000.1). I identified

myself as 

acknowledged they understood my official

capacity through the conversation. The reason I

called for this meeting was a poultry welfare

observation that I made at 1245 hours, when I

walked into the evisceration department. I told

 that when I went down to the

evisceration department, I noticed that there were

no birds coming on evisceration lines number 1 or

2, which are fed by kill line number 2. As I walked

lines 1 and 2 towards the rehang area, I saw 2 full

barrels of birds that appeared bright

red / cadavers. These were located just after the

rehang area on side 2 and not in the USDA

inspection area. Upon further inspection, I

observed that one bird did have its head attached

still and the head was bright red, but there did

appear to be a cut of sorts (though it could have

been a “wound” from the head puller and not an

actual kill cut). Most of the birds I could see in the

barrels did not have heads. I walked into the

picking/dressing room and saw that the

establishment associates  were starting to hang

birds onto the kill line (#2) again (after an obvious

very large gap in the line). I observed birds at the

pre-scald area on the line to have cut necks. Some

had some movement but no obvious alertness

indicating life. There did not appear to be

anything wrong in the kill room (post-stun) and

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 318

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

the birds were being cut by the circular kill blade.

The backup slaughter associate was performing

their duties. At the stunner, I saw a maintenance

person adjusting the stunner height (or appeared

to  be doing something of that nature). I began to

think that there had been an event where

cadavers occurred – birds may have died other

than by slaughter, which is a noncompliance with

9 CFR 381.65 (b). I returned to the rehang area

and saw another approximately half a barrel with

birds in it that also appeared red; this barrel was

located closer to the window where birds enter

the rehang department (between the window and

the kill line #1 hock cutter). On the production

floor, I saw the 

 and told him I was concerned

about these barrels of cadavers. He said “What’s

wrong? They didn’t make it to the inspectors.” I

said it was a poultry welfare concern and he had

no response to that, so I went upstairs and

requested to speak with further management. I

spoke with the plant manager (Mr. Kevin Dennis),

who was also concerned and contacted 

for this meeting. In response, said that

at the rehang area they had noticed many red

birds, so they found the problem to be that the

stunner was not operating correctly and too many

birds were missing the kill blade. The backup killer

could not keep up with them all and they went

through the scalders and all the way into the

rehang department. I said it was good that the

establishment found and fixed the problem, but

my concern is the large quantity of birds that

possibly died by means other than by slaughter.

said that they would take actions to

prevent this and would provide documentation

that their poultry welfare plan was addressing

this. I reminded that the Poultry

Products Inspection Act and Agency regulations

require that live poultry be handled in a manner

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 319

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

that is consistent with good commercial practices

and that they not die from causes other than

slaughter. I notified that this MOI would

be forwarded to the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. I attest that this memorandum

includes all the information discussed during the

meeting to the best of my knowledge. 

Digitally signed by 

Date: 2019.11.13 08:33:10 -05'00'

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 320

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P764 Perdue Foods, LLC CUA43091

20620G

20DEC2019 04C05 Poultry Good

Commercial

Practices

Finalized A meeting was held at 1039 hours in the USDA

SPHV office of P-764, Perdue Foods, LLC in

Salisbury, Maryland between establishment

management and USDA (as directed by FSIS

Directive 5000.1). I identified myself as 

 In attendance was 

acknowledged he understood my official

capacity through the conversation. The meeting

was held to discuss a problem I observed while

performing the poultry good commercial practices

task in the picking room this morning.  At 1019 I

was observing birds on kill line #1 entering the

scalder.  I saw one bird that had a flexed neck and

it was “looking at me” with consciousness.  I took

hold of its head and it reacted in a conscious

manner.  There was some blood on its neck but

the kill cut was not deep / mostly in the skin,

upon palpation.  

) and 

 were also

observing at the same time.  I also told 

, who was just around the corner at the

end of the first scalder on kill line 2. There was no

loss of process control; only 1 bird that I observed

was affected.  I reminded that the

Poultry Products Inspection Act and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and that they not die from causes other

than slaughter. I notified that this MOI

would be forwarded to the District Veterinary

Medical Specialist (DVMS) in case additional

follow-up is recommended. I attest that this

memorandum includes all the information

discussed during the meeting to the best of my

knowledge.

(b) (6)

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 321

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P764 Perdue Foods, LLC CUA28110

22120G

20FEB2020 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview 

                                                                                     

                                                                 February

20, 2020 

                                                                                     

                                                                 Perdue

Foods, LLC 

                                                                                     

                                                                 P-764 

                                                                                     

                                                                 Salisbury,

MD Attendees:                

                

,

USDA, P-764 A meeting was held at 1100 hours

in the USDA SPHV office of P-764, Perdue Foods,

LLC in Salisbury, Maryland.  I identified myself as

acknowledged they understood my official

capacity through the conversation. The reason I

called for this meeting was a poultry welfare

observation that I made at 1048 hours, when I

was performing a poultry good commercial

practices task in the receiving area.  At 1048 hours

I observed a bird that was moving atop a large pile

of birds in the “Dead-on-Arrival” (DOA) dumpster

(which is used for all dead-on-arrivals, euthanized

sick/weak birds, and culled birds).  The bird had

blue denaturant dye on its outer surfaces.  I

immediately notified 

 and he removed the bird from the

dead bin and placed it into the sorting table area. 

The bird continued to have breathing

movements – my observations of breathing

confirmed that the bird was alive and not dead or

exhibiting post-euthanasia neurological

movements.  It was not until I called 

 to the area

(b) (6)

(b) (6)

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 322

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

that the bird was euthanized via cervical

dislocation.   Another concern that I observed at

this same time was the sorting table (where all

non-ambulatory disabled birds end up, along with

dead birds and those for culling to be sorted for

euthanasia or not) was piled 3 to 4 birds deep

beneath the exit of the conveyor feeding it from

kill line 1.  Some birds at the bottom of the pile

were breathing / moving.  There was an

establishment employee actively euthanizing

birds from this pile, but the pile was not spread

out to minimize any suffocation/discomfort (there

was plenty of room around the pile to thin the

pile out). I reminded that the Poultry

Products Inspection Act 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 attest that this memorandum

includes all the information discussed during the

meeting to the best of my knowledge.  

at P-764)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 323

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P7669 Turkey Valley Farms, Inc. RZB080705

1322G

22MAY2019 04C05 Poultry Good

Commercial

Practices

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

At approximately 0630 hours, while performing a

Good Commercial Practices verification task, I

observed 1 out of 100 carcasses showing signs of

consciousness (blinking eyes, open mouth

breathing, raised head, and wing movement)

proceed into the scalder. The establishment had a

back-up killer located approximately 10 feet prior

to the final stunner which is just prior to the

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

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

neck.However, the final stunner was not

positioned high enough to make contact with all

of the birds. 

 was notified immediately. He notified me

that they were training new employees and then

he made adjustments to the stunner. An

additional 100 bird check was conducted at this

time and no further issues were observed.

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 324

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P7669 Turkey Valley Farms, Inc. RZB001105

4330G

30MAY2019 04C05 Poultry Good

Commercial

Practices

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

At approximately 0910 hours, while performing a

Good Commercial Practices verification task, I

observed two cherry-red carcasses on the

transfer/rehang table. I did not observe a cut

present on the neck. While examining these two

carcasses, an additional carcass was thrown onto

the table that also did not have a cut present on

the neck. I then proceeded into the picking room

to observe birds prior to the scalder. While

observing birds prior to the scalder, I observed 2

out of 50 carcasses showing signs of

consciousness (blinking eyes, open mouth

breathing, raised head, and active wing

movement) proceed into the scalder. No cut was

present on the neck. ,

 was notified immediately. At this

time, and I observed 1 out of 100

carcasses showing signs of consciousness proceed

into the scalder. stated that the two

back-up killers were inexperienced and he placed

a trained employee into the back-up killer

position. At approximately 0920 hours, an

additional 200 bird check was conducted and no

further issues were observed at this time. Again at

approximately 1100 hours an additional 100 bird

check was conducted and no further issues were

observed at this time.  A similar Good

Commercial Practices MOI was documented on

5/22/19, RZB0807051322G, titled Poultry Good

Commercial Practices / RZB0407050122I.

(b) (6) (b) (6)(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 325

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P7669 Turkey Valley Farms, Inc. RZB320906

1710G

10JUN2019 04C05 Poultry Good

Commercial

Practices

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

At approximately 0910 hours, while observing

operations in the Evisceration Department, I

observed 2 cadavers (cherry-red carcasses with

blood pooling at the neck region) at the USDA

inspection stations and 1 cadaver on the floor

near the rehang/transfer table. Upon inspection,

these birds did not have an adequate cut present

on the neck. I then proceeded into the picking

room to observe birds prior to the scalder.

 was present at this

time. While observing birds prior to the scalder, I

observed 1 out of 100 carcasses showing signs of

consciousness (blinking eyes, open mouth

breathing, and raised head) proceed into the

scalder. No cut was present on the neck. 

, was notified immediately

stated that he would make adjustments to the kill

machine to ensure the cut would be properly

positioned.   At approximately 0920 hours, an

additional 200 bird check was conducted and no

further issues were observed at this time.At

approximately 0930 hours, I informed Plant

Manager, Shawn Kaas, of my observations and

informed him that this is the third similar incident

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

of the issue. A similar Good Commercial

Practices MOI was documented on 5/22/19,

RZB0807051322G, and

5/30/19, RZB0011054330G.

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 326

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P7669 Turkey Valley Farms, Inc. RZB130707

1923G

23JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0650 hours on 7/23/19 while

performing the Good Commercial Practices task in

the picking room I, , noted 5

out of 50 birds enter the scald tank alive. There

had just been a lot change to smaller birds and

the final stunner had not been adjusted to

accommodate the smaller size. There was no

back-up killer present in this area. Of the five birds

seen entering the scald tank alive, none of them

had their throats cut and all were blinking and

lifting their heads. As I was about to leave the area

to find a supervisor an employee came in and

raised the final stunner height so the birds did not

miss the stunner. I observed another 100 birds

and did not see any more live birds. All birds

observed after the final stunner was adjusted had

properly positioned throat cuts. I informed 

 of what I had seen and that I would be

issuing an MOI as this was imperfect conditions.

While there should not be birds entering the scald

tank alive, it was corrected before I went to find a

supervisor. Three previous MOI's have recently

been issued for the same problem. These were

issued on 5/22, 5/30, and 6/10. I performed a

200 bird check at 0900 hours and a 100 bird

check at 1100 hours. No more issues were

observed.

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 327

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P768+V768 Tyson Foods, Inc. BFC171404

3123G

23APR2019 04C05 Poultry Good

Commercial

Practices

Open At 1130 hours, while performing Good

Commercial Practices and observing the stunners,

cutters, and backup cutters, I, 

 observed an almost-decapitated dead bird

hung in shackles on the line closest to me coming

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

body was slightly curved, with the head hanging

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

and trachea were all that connected the head to

the body. The bird was covered in bright red

blood. The birds to the left and right of the

almost-decapitated bird were also covered in

bright red blood. I did not observe how the bird

was almost decapitated, but due to the amount

and location of the blood, it likely happened

recently, possibly in live hang. The backup cutter

removed the almost-decapitated bird from the

shackles and placed it on the floor. I informed

 of my observation and

showed him the bird at 1135 hours. I also

observed multiple less-than-perfect conditions in

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

chicken heads, and debris dispersed on the floor

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

in three yellow condemn barrels (one full of

decapitated chickens and heads, one 2/3 full of

chicken litter, and one coated in blood) and along

the corner near the white board in live hang at

1137 hours. Three of the yellow condemn barrels

in live hang were thoroughly coated inside with

blood. At about 1139 hours, I observed an

establishment employee transporting live small

birds for decapitation inside a yellow condemn

barrel (the birds were unharmed in the barrel and

were not piled on top of each other). 

Additionally, at 1152 hours, I watched an

establishment employee dump birds from one of

the yellow condemn barrels into the outside

white tote near dumping. The birds in the barrel

had not been decapitated. The employee told me

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 328

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

that the birds had been left over from night shift,

and the contents of the barrel smelled rank. 

When I observed live hangers at 1140 hours, I did

not see any mistreatment of birds. When I again

observed the stunners, cutters, backup cutters,

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

any major issues (only two flies in a yellow

condemn barrel in live hang). I understand that

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

not see a loss of process control, however I am

concerned that live hang may be working faster

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

considering slowing the line speed, but I will be

monitoring live hang for the remainder of this

shift to make sure these issues do not progress to

loss of process control. At 1337 hours, I informed

 of

my observations as described above. They

acknowledged and told me they would investigate

the cause of the almost-decapitated bird. The

meeting concluded at 1344 hours.

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 329

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P7903 Perdue Foods, LLC UYN09140

45426G

26APR2019 04C05 Poultry Good

Commercial

Practices

Finalized Today, April 25, 2019 at approximately 2125

hours, while performing a Poultry Good

Commercial Practices verification in the area

where the DOA truck is located I,

 observed one(1) live bird laying inside of

the truck with several other carcasses that were

present had already been denatured. The plant

employee that was present was verbally notified

and shown the bird in question. ,

was also

verbally notified. The plant employee that was

present was able to remove the live bird from the

DOA truck at approximately 2135 hours. I

reminded of the plant’s responsibility

and obligation to handle the live birds in a

manner consistent with the requirements of FSIS

Directive 6100.3 and the Code of Federal

Regulations. All the aforementioned statements

are true and correct to the best of my knowledge,

as indicated by my electronic signature below.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 330

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P7903 Perdue Foods, LLC UYN53170

65305G

05JUN2019 04C05 Poultry Good

Commercial

Practices

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

while performing a Poultry Good Commercial

Practices verification in the area where the DOA

truck is located I, ,

observed one(1) live and denatured bird laying

inside of the truck with several other carcasses

that had already been denatured. The plant

employee that was present was verbally notified

and shown the bird in question. ,

, was also

verbally notified. The plant employee that was

present was able to remove the bird from the

DOA truck and humanely euthanized it at

approximately 1516 hours. I reminded 

of the plant’s responsibility and obligation to

handle the live birds in a manner consistent with

the requirements of FSIS Directive 6100.3 and the

Code of Federal Regulations. All the

aforementioned statements are true and correct

to the best of my knowledge, as indicated by my

electronic signature below.

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 331

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P794 B&B Poultry Co., Inc. UCB29120

74117G

17JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized On July 16th, 2019, at approximately 15:15

hours, I witnessed the following in the live hang

area, several birds scattered in various dangerous

places in live hang.  Two Birds were found in the

blood pit, one bird found adjacent to the scald

tank while being drenched with over flowing

water from the scalder.  Approximately 10 to 12

birds found in the lower section of the live hang

area adjacent to the blood tank.  I informed the

area supervisor to stop hanging birds. I continued

my inspection and found 2 live birds in one

condemn barrel and another two live birds in a

second condemn barrel. I also saw one bird

outside next to the truck that delivers the live

birds. All birds were removed and placed in

cages. I informed Mrs. Cruz plant manager and

of my findings. At

15:30 hours I returned to the live hang area and

found two additional live birds in dangerous

areas, one bird was found under the cages on a

belt that moves them forward and another bird

was found underneath the scald tank. Both birds

were removed and placed in cages, at 15:40 hours

regulatory control action was released.  At 15:45

hours I discussed my findings with Mr. Josh Fisher

co-owner. I stressed the dangers of having live

birds in condemn barrels due to the risk of

suffocation and near trucks or under the cages

due to the threat of being crushed. He agreed that

my findings were not acceptable and stated his

employees recently had training regarding the

safe handling of birds.

P794 B&B Poultry Co., Inc. UCB15100

93410G

10SEP2019 04C05 Poultry Good

Commercial

Practices

Finalized On September 10, 2019, at approximately 0725

hours the following was observed in the live hang

room. One live bird was found in the condemned

barrel.   was

shown the condition of the live bird and took

immediate action by removing the live bird and

placing it on the line.

(b) (6)(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 332

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P843 Pilgrim's Pride Corporation PZA451305

4508G

08MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0937 hours, while performing a

Good Commercial Practice task, I, 

 went in the door at the lower end of

Evisceration Department that leads into the

Picking Room. While watching the birds go into

the scalder for approximately one minute and 37

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

The chicken’s head was lifted upward and its eyes

were blinking. Upon further investigation, I went

to the Upper End of the Evisceration Department,

where the birds exit out the Picking Room into the

Evisceration Department. I wanted to follow the

bird into the Evisceration Department. While

moving into the area, at approximately 0941

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

member taking the bird off the line and putting it

into a USDA yellow condemn barrel. I took the

bird out of the USDA yellow condemn barrel for

further observation. The bird’s throat had not

been slit. IPP had to ring bell for

. He agreed with my

observation. 

 were notified of this serious matter. 

This is a repeat MOI for live birds entering the

scalder. See MOI entitled, “Live birds going into

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

preventive measure was ineffective in preventing

recurrence.

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

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 333

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P855 Pilgrim's Pride Corporation FDA20140

62507G

07JUN2019 04C05 Poultry Good

Commercial

Practices

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

hours. In attendance: ,

while conducting post-mortem

inspection at the inspection stations in the

evisceration department on Wednesday, May 29,

2019, observed the following:  At 0920 hours, I

observed a cadaver presented to the inspection

station on Station 1.  I immediately

informed Marion Furcron of the noncompliance. 

At 0946 and 0950 hours, I observed two cadavers

presented to the inspection stations on 

Station 1 and Station 2, respectively.  I

immediately informed of the

noncompliance.  At 1001 hours, I observed a

cadaver presented to the inspection station on

 Station 3.  I immediately informed 

 of the noncompliance.  Each of the

carcasses had the same presentation as grossly

bright red in color throughout the entire body, the

heads were attached, and the necks were not at

all cut, which indicates that the carcasses entered

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

the cadavers were placed on the PHV shackles for

the plant to confirm the findings.  No one from

the plant responded to the observations at the

time of my observations.  The plant response was

received on June 4, 2019 by .  It

stated as follows: “Corrective actions for

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

were cadavers found coming off of both picking

lines that made it to the USDA inspector stations. 

After investigation it was found that they were a

result of picking room lead giving breaks and not

catching all uncut birds at kill station.  Employee

was removed from the line and written up by

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

while I was conducting post-mortem inspection at

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

(b) (6)

(b) (4) (b) (4) (b) (6) (b) (4) (b) (6) (b) (6) (b) (7)(A)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 334

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Task

Code TaskName Status MOI Agenda

the inspection stations in the evisceration

department on Monday, June 3, 2019 at 0915

hours, I observed a carcass being presented to the

inspection station on Line 1 Station 1 that was

clearly a cadaver.  The carcass was grossly bright

red in color throughout the entire body, the head

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

which indicates that the carcass entered the

scalder alive and not at all bled out.  I

immediately informed the plant 

 of my observation and noncompliance. 

The cadaver was placed on the PHV shackle for

the plant to confirm the findings.  No one from

the plant responded to the observation at the

time of my observation.  The plant response was

received on June 4, 2019 by   It

stated as follows: “Corrective action for cadavers

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

by a back-up killer with more experience than the

one we had on the line during the week of

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

for breaks and the one she was replaced with on

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

of time in the past while working for the

company.  This employee was a rehire and will be

retrained on the new back up killer SOP along

with anyone who is sent to the kill room in the

future for any length of time.” During a meeting

with management on June 4, 2019, I reminded

management that the PPIA and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and that they not die from causes other

than slaughter. I notified management that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.  

Respectfully, ,

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 335

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Task

Code TaskName Status MOI Agenda

P890 Peco Foods, Inc. CYD29030

40830G

30APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 11:30 pm on the night of

4/24/19 was just finishing

his first set of breaks when he noticed several

members of Plant management and personnel

rushing to the back dock area.He immediately

followed to see what was happening when he

observed a plant’s Yard Dog truck suspended with

front wheels off the ground and its cab pointing

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

attached to the cab was laying flat on its right

side.Live and dead chickens were seen scattered

around the overturned truck with most chickens

still inside the cages piled on top of each other at

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

 and 

informed and

 that the

birds needed to be removed humanely and that

all live and dead birds should be accounted for.

Because of the way the trailer was positioned and

cages still being attached to the trailer by chains,

each cage had to be removed by forklift one at a

time and some had to be cut loose with a cutting

torch. This took considerable time (approximately

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

probably allowed for many of the birds trapped

under the piles to suffocate and

monitored the plant’s removal

and separation of live and dead birds at all times

and made sure that denaturant was applied to the

combos they were placed in. When the process

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

and 5 smaller combos of dead birds totaling 2,969

birds which were killed by means other than

slaughter or an approved euthanasia method. This

GCP-MOI is being issued to the plant to document

basically a process control failure which led to

mistreatment, harm, and deaths of birds on its

regulated premises.                                                  

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 336

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

                                                 (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 337

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Code TaskName Status MOI Agenda

P890 Peco Foods, Inc. CYD45040

74512G

12JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Shannon Hendry Peco Foods, Canton, MS 

Plant Manager 1039 W. Fulton St. Canton, MS

39046 Mr. Hendry, At approximately 0130

hours on July 12, 2019 while performing the Good

Commercial Practices (GCP) in Poultry verification

task, the following less than GCP was observed. 

Two (2) live chickens were comingled with 4 Dead

on Arrival (DOA) birds at the South end of the live

hang conveyor in the live hang area.  Both birds

exhibited pupillary reflexes, movement on being

picked up, and rhythmic breathing.  Both live

birds were returned to the picking line and placed

in production. At approximately 0135 hours, 4

cadavers were removed from the picking line at

the exit of the last picker by a plant sorter.  At

approximately 0137 hours, 2 live birds  with no

visible cut to the neck  were observed entering the

scald tank.  At approximately 0139 another live

bird with no visible cut to neck was observed 

entering the scald tank.  At approximately 0141

hours 2 cadavers with pooling of blood in head

and neck exhibiting a reddish-purple hue exited

the last picker.  At approximately 0143, another

cadaver with pooling of blood in the head and

neck exhibiting a reddish-purple hue exited the

picker.  

and 

were notified.  After replaced the back

cutter with another plant employee, a second

verification at the entrance of the scalder was

performed.  No live birds were observed entering

the scalder during this observation.  This was

considered to be an isolated incident and not a

systemic event or loss of process control. 

Allowing live birds and DOAs to be comingled

with live birds can lead to death due to

suffocation.  Birds entering the scalder live causes

unnecessary suffering and death resulting in

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 338

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adulterated product.  Poultry establishments must

take every available precaution to prevent

unnecessary injury, suffering, and death of birds

while on the official premises. 

, and 

met in the USDA breakroom at

approximately 0200 hours to discuss the less than

GCP incident.  The chain of events leading up to

the observation, the observation of live birds

entering the scalder, and the barrel checks at the

exit of the last picker were discussed.  Immediate

corrective actions included replacement of the

backup cutter with another plant employee. 

Observations at the exit of the last picker revealed

55 cadavers were removed from the picking line

within a relative short time span of approximately

30 minutes, although only 3 birds were seen

entering the scald tank at 2 separate times during

the observation of approximately 500 birds at the

entrance of the scalder by .  The

comingling of live birds with DOAs after the plant

culling process was also discussed.  was

advised a GCP Memorandum of Information

would be documented in the Public Health

Information System and sent to 

for review. As per Federal Notice Vol. 70, No.

187, Docket No 04-037N dated September

28,2005, “Treatment of Live Poultry Prior to

Slaughter”, the Food Safety and Inspection Service

(FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to make every

effort to treat poultry humanely and abide by

Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

, Canton, MS 9024 1039 W.

Fulton St. Canton, MS 39046 cc:  

              

        

              

(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: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 339

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P890 Peco Foods, Inc. CYD23150

80228G

28AUG2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 8:52 am, I, 

 entered the picking room to perform a

check for Good Commercial Practices (GCP). I

observed there were no birds on the picking line

in front of the back-up kill person as he was

leaving his station for the 9:00 am company

break. I walked to the picking line just prior to the

scalder and observed the last of the birds hung on

the picking line. I immediately observed one (1)

live chicken on the picking line prior to him

entering the scalder. The bird was blinking his

eyes. As I pulled his head slightly toward me, he

began chirping repeatedly, lifting his head and

flapping his wings. I observed the bird had no cuts

to the neck and no bleeding. The end of the

picking line held approximately 60 birds since live

hang operations had stopped for the company

break. I saw no additional live birds entering the

scalder during the GCP check. I went to the last

picker where the plant sorter stands and waited

until the plant sorter observed and removed the

cadaver bird from the picking line. I immediately

informed 

of the observation at 8:52 am

and of the forthcoming GCP MOI, documenting

the incident and my meeting and communication

of these facts to plant management. A single

finding of a live bird entering the scalder

represents poultry mistreatment. Reference:

Federal Register Docket #04-037N At

approximately 9:22 am, I returned to the picking

room after the company break. I monitored the

birds on the picking line for approximately three

minutes. No live birds were observed entering the

scalder during this observation. The finding before

the company break appeared to be an isolated

incident and not a loss of process control. A

similar finding of a live bird entering the scalder

was documented on GCP MOI dated 7/12/2019.

In response to that GCP MOI, plant management

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 340

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

stated in part, that the plant employee

responsible for the role of backup killer did not

perform his duties as instructed. All night shift

employees that perform or could perform this

duty or could perform this duty in case of absence

have been retrained on proper backup killer

responsibilities and procedures. Superintendent

and supervisors in the evisceration department

have been retrained as well. A copy of this

Memorandum of Interview will be forwarded to

appropriate personnel in the Jackson District

Office. Respectfully submitted, 

 Establishment 00890 P/1 Canton, MS 

Cc: 

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

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 341

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P890 Peco Foods, Inc. CYD36030

10127G

27JAN2020 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 10:30 pm the night of

11/24/2019 was just

finishing performing a Pre-Operational SSOP

Review and Observation Task when she observed

a less than GCP occurrence. She noticed several

members of Plant management and personnel

rushing to the picking room. She followed and

observed 

 having to cut the necks of birds as they

passed down the line. Upon further investigation,

she was informed that the backup bird killer had

failed to stop evisceration line after several birds

had passed without proper stunning and neck

cutting. Plant management had become aware of

the situation using local cameras and provided

corrective actions and had the situation under

plant control at this time. notified

 (who had performed GCP at

10:10 pm and all was normal) of the situation and

they met with ,

who explained what had occurred and the

response of the plant. The incident appeared to be

an isolated one in which the plant responded to

quickly and effectively. This MOI is being written

and submitted to make a record of the events so

that if this situation happens again further USDA

actions may be required and imposed.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 342

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB25190

62107G

07JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized On June 7, 2019 at approximately 1635 a bird

came to Station 3 with the head still

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

was engorged with blood, and from the base of

the neck to the head was discolored a dark

purple. The bird was not cut to facilitate bleeding

of the carcass, nor was the head removed by the

head-puller placed prior to the scalder. I notified

who took the bird to 

and then disposed of the carcass. This

establishment has a zero tolerance policy for any

live birds entering the scalder according to their

Poultry Care Process. The establishment has a

plan in place for handling animals from the time

they enter the premises. The last MOI written

regarding deviation from Good Commercial

Practices was received by the plant on June 4,

2019 citing that the establishment failed to

slaughter poultry in accordance with Good

Commercial Practices.

(b) (4) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 343

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB05170

64013G

13JUN2019 04C05 Poultry Good

Commercial

Practices

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

 found a bird on the line

with the head still attached and no evidence of a

neck cut.  She showed the bird to 

 and .  When I inspected the

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

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

knife machine and the headpullers.  There was

some evidence of a cut to the lower mandible

having removed keratin layers from the beak, but

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

was swollen and the head and neck both dark

purplish-red in color.  Regulations require that

birds shall have died by bleeding out before

entering the scalder; this was not possible in this

case, since there was no cut from which the bird

could bleed out and the head and neck were

engorged with blood.  It is a failure of Good

Commercial Practices to allow birds to enter the

scalder without being bled out, because such

birds are unsalable, and because of the possibility

of such birds drowning in the scalder, which is

inhumane.   This establishment has a zero

tolerance policy for any live birds entering the

scalder according to their Poultry Care Process.

The establishment has a plan in place for handling

animals from the time they enter the premises. 

The last MOI written regarding deviation from

Good Commercial Practices was received by the

plant on June 7, 2019, citing that the

establishment failed to slaughter poultry in

accordance with Good Commercial Practices.

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 344

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB30110

70805G

05JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized On 7/3/19 at approximately 1030 hours the

inspector on line #1 stand #1 presented me a

cadaver bird. The bird was bright red and still had

its neck and head attached. The neck of the bird

had no cut mark on it and was fully intact,

providing further evidence that the bird died from

the scalder which is a means other than slaughter.

I informed , and

showed him the bird. I reminded that

the PPIA and Agency regulations require that live

poultry be handled in a manner that is consistent

with good commercial practices and that they not

die from causes other than slaughter. I referred

 to Federal Register Notice Vol. 70, No.

187, which he has, and I recommended that he

review it for FSIS recommendations concerning

treatment of live poultry before 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.

(b) (6) (b) (6) (b) (6)(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 345

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB36090

74915G

15JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0645 hours after giving breaks I

was presented with two cadaver birds one from

line #1 stand #1 and the other from line #1 stand

#3. Both birds still had their heads and necks

attached which where bright red. The neck of the

bird from Line #1 Stand #1 had no cut mark on it

and was fully intact. The bird from line #1 stand

#3 had an approximately 1⁄4 inch break in the skin

just caudal to the head that did not penetrate into

any of the deeper tissue past the skin. The

condition in which the birds were presented

provided strong evidence that the birds died from

the scalder which is a means other than slaughter.

I informed 

and and

showed them the birds. I reminded them that the

PPIA and Agency regulations require that live

poultry be handled in a manner that is consistent

with good commercial practices and that they not

die from causes other than slaughter. I referred

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

which the plant was given, and I recommended

that they review it for FSIS recommendations

concerning treatment of live poultry before

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.

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 346

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB50110

74216G

16JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized On 7/16/19 at approximately 0925 hours the

inspector on line #1 stand #1 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red. The neck of the

bird had no cut mark on it and was fully intact,

providing further evidence that the bird died from

the scalder which is a means other than slaughter.

I informed , and

 about

the bird that had been presented to me. I showed

 the bird. I reminded that the

PPIA and Agency regulations require that live

poultry be handled in a manner that is consistent

with good commercial practices and that they not

die from causes other than slaughter. I referred

 to Federal Register Notice Vol. 70, No.

187, which he has, and I recommended that he

review it for FSIS recommendations concerning

treatment of live poultry before 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.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 347

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB52080

74419G

19JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized On 7/16/19 at approximately 0135 hours the

inspector on line #1 stand #1 placed a suspected

cadaver bird on the USDA hook for veterinary

disposition. I examined the bird at approximately

0152 hours. The bird had its head and neck

attached which was bright red. The neck of the

bird had no cut mark on it and was fully intact,

providing further evidence that the bird died from

the scalder which is a means other than slaughter.

I informed , about

the bird that had been presented to me. I showed

 the bird. I reminded that the

PPIA and Agency regulations require that live

poultry be handled in a manner that is consistent

with good commercial practices and that they not

die from causes other than slaughter. I referred

 to Federal Register Notice Vol. 70, No.

187, which he has, and I recommended that he

review it for FSIS recommendations concerning

treatment of live poultry before 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.

(b) (6) (b) (6) (b) (6) (b) (6)(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 348

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB47120

71724G

24JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized On 7/23/19 at approximately 1250 hours the

inspector on stand #1 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red. The neck of the

bird had no cut mark on it and was fully

intact, indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed and

 about the bird that had

been presented to me. I showed and

 the bird. I reminded them that the

PPIA and Agency regulations require that live

poultry be handled in a manner that is consistent

with good commercial practices and that they not

die from causes other than slaughter. I referred

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

which they have, and I recommended that they

review it for FSIS recommendations concerning

treatment of live poultry before slaughter. I

notified them that this MOI will be forwarded to

the District Office and the District Veterinary

Medical Specialist (DVMS) in case additional

follow-up is recommended.

(b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 349

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB34110

72229G

29JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized On 7/25/19 at approximately 0815 hours the

inspector on line #2 stand #1 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red. The neck of the

bird had no cut mark on it and was fully intact,

indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed , and 

about the bird that had

been presented to me. I showed and

 bird. After informing the plant

about the cadaver bird I went to where the birds

are slaughtered on Line #2 and observed the birds

going through the kill machine, past the backup

killer, and just before they entered the scalder. I

observed these areas for 10 minutes each and

during that time I did not see any birds go past

that were not properly slaughtered. I also

observed these areas on Line #1 and with

the same result. I also reminded and

 that the PPIA and Agency regulations

require that live poultry be handled in a manner

that is consistent with good commercial practices

and that they not die from causes other than

slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 350

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB23060

75731G

31JUL2019 04C05 Poultry Good

Commercial

Practices

Finalized On 7/30/19 at approximately 1230 hours the

inspector on line #2 stand #3 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red. The neck of the

bird had no cut mark on it and was fully intact,

indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed , and

 about

the bird that had been presented to me. I showed

 and  the bird. After informing

the plant about the cadaver bird I went to where

the birds are slaughtered on Line #2 and observed

the birds going through the kill machine, past the

backup killer, and just before they entered the

scalder. I observed these areas for 10 minutes

each and during that time I did not see any birds

go past that were not properly slaughtered. I also

observed these areas on Line #1 and with

the same result. I did observe more birds get past

the kill blades than usual because the birds were

of varying size, but the backup killer properly

slaughtered all the birds. I mentioned this to plant

management in the weekly meeting.   I also

reminded and  that the PPIA

and Agency regulations require that live poultry

be handled in a manner that is consistent with

good commercial practices and that they not die

from causes other than slaughter. I referred them

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

they have, and I recommended that they review it

for FSIS recommendations concerning treatment

of live poultry before slaughter. I notified them

that this MOI will be forwarded to the District

Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (4) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 351

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB36050

84819G

19AUG2019 04C05 Poultry Good

Commercial

Practices

Finalized On 8/16/19 at approximately 0850 hours the

inspector on stand #3 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red. The neck of the

bird had no cut mark on it and was fully intact,

indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed , and 

, about the bird

that had been presented to me. I showed 

 and the bird. After informing the

plant about the cadaver bird I went to where the

birds are slaughtered on and observed the

birds going through the kill machine, past the

backup killer, and just before they entered the

scalder. I observed these areas for approximately

10 minutes total until processing stopped for

lunch. During that time, I did not see any birds go

past that were not properly slaughtered. I did

observe that the head puller just before the

scalder on had had one full bird carcass

stuck in it causing it to operate less effectively

then when there are no obstructions present. I

found and notified him of the

obstruction to the head puller that I observed. At

approximately 0915 hours the inspector on line

#1 stand #2 presented me a second cadaver bird.

The bird had its head and neck attached which

was bright red. The bird had an approximately

1/4-1/2 inch break in the skin on the right side of

the neck just caudal to the head that did not

penetrate any of the deeper tissue past the skin.

All of this indicated that, like the first bird, this

bird was not bleed out thoroughly in accordance

with 9 CFR 381.65(b). I showed and 

this bird as well. I also reminded 

and that the PPIA and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and that they not die from causes other

(b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4) (b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 352

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

than slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 353

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB41060

80122G

22AUG2019 04C05 Poultry Good

Commercial

Practices

Finalized On 8/21/19 at approximately 0855 hours the

inspector on line #1 stand #1 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red. The neck of the

bird had no cut mark on it and was fully intact,

indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed , and 

, about the bird

that had been presented to me. I showed

 and the bird. Later in the day at

1125 hours while walking through the live bird

loading area with  , we inspected the

outside DOA bin from Lines #2 and #3 and saw a

live bird in the DOA bin. The bird was bright and

alert and when it was picked up by the plant

employee it flapped its wings. We informed 

, about the bird. 

removed the bird from the DOA bin and then

humanly euthanized the bird by cervical

dislocation. I also reminded 

and that the PPIA and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and that they not die from causes other

than slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 354

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB22060

82426G

26AUG2019 04C05 Poultry Good

Commercial

Practices

Finalized On 8/26/19 at approximately 0625 hours the

inspector on stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was red to purple in color. The

neck of the bird had no cut mark on it and was

fully intact, indicating that the bird was not bleed

out thoroughly in accordance with 9 CFR

381.65(b). I informed 

and , about

the bird that had been presented to me. I showed

 and the bird. After informing

the plant about the cadaver bird I went to where

the birds are slaughtered on and observed

the birds going through the kill machine, past the

backup killer, and just before they entered the

scalder. I observed these areas for approximately

10 minutes total. During that time, I did not see

any birds go past that were not properly

slaughtered. I also reminded and 

r that the PPIA and Agency regulations

require that live poultry be handled in a manner

that is consistent with good commercial practices

and that they not die from causes other than

slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (4) (b) (4) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 355

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB56040

85926G

26AUG2019 04C05 Poultry Good

Commercial

Practices

Finalized On 8/23/19 at approximately 0700 hours the

inspector on stand #3 and stand #4

presented me one cadaver bird each. The birds

had their heads and necks attached which were

red to purple in color. The bird from stand #3 had

an approximately 1/4-inch break in the skin and

the bird from stand #4 had an approximately

1⁄2-inch break in the skin. On both birds the break

in the skin was in approximately the same

location, on the back side of the neck, just caudal

to the head and neither penetrated any of the

deeper tissue past the skin to properly cut the

underlying structures including the vessels. All of

this indicated that these birds were not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed and 

, about the

birds that had been presented to me. I showed

the birds. After informing the plant

about the cadaver bird I went to where the birds

are slaughtered on and observed the birds

going through the kill machine, past the backup

killer, and just before they entered the scalder. I

observed these areas for approximately 15

minutes total. I also observed these areas on line

#2 and line #1. During that time, I did not see any

birds go past that were not properly slaughtered I

reminded that the PPIA

and Agency regulations require that live poultry

be handled in a manner that is consistent with

good commercial practices and that they not die

from causes other than slaughter. I referred them

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

they have, and I recommended that they review it

for FSIS recommendations concerning treatment

of live poultry before slaughter. I notified them

that this MOI will be forwarded to the District

Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.

(b) (4) (b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 356

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB09120

95703G

03SEP2019 04C05 Poultry Good

Commercial

Practices

Finalized On 9/3/19 at approximately 1120 hours the

inspector on line #1 stand #1 presented me a

cadaver bird. The bird had its head and neck

attached which was  bright red to purple in color.

The neck of the bird had no cut mark on it and

was fully intact, indicating that the bird was not

bleed out thoroughly in accordance with 9 CFR

381.65(b). I informed 

 about the bird that had been

presented to me. I showed  and 

the bird. also informed 

. After

informing the plant about the cadaver bird and

giving breaks I went to where the birds are

slaughtered on Line #1 at 1215 hours and

observed the birds going through the kill machine,

past the backup killer, and just before they

entered the scalder. I observed these areas for

approximately 10 minutes total. During that time,

I did not see any birds go past that were not

properly slaughtered. I also reminded 

 and that the PPIA and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and that they not die from causes other

than slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 357

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB13090

95305G

05SEP2019 04C05 Poultry Good

Commercial

Practices

Finalized On 9/5/19 at approximately 0834 hours while at

the loading area I observed a live bird in the

outside DOA bin from Lines #2 I could

only see the back end of the bird because its head

was buried under a DOA bird. I could see the bird

breathing heavily. I removed the DOA off of the

head of the live bird and its breathing steadied

somewhat after its head was freed. The birds body

was covered in red denaturing agent that had

been placed on all the birds in the bin by an

establishment employee. I when and informed

, of my

findings. Shortly after ,

and , meet me at the

DOA bin. The bird was bright, and alert and it

flapped its wings when picked up by .

 After removed the bird from the

DOA bin he then humanly euthanized the bird by

cervical dislocation. I reminded that

the PPIA and Agency regulations require that live

poultry be handled in a manner that is consistent

with good commercial practices. I referred him to

Federal Register Notice Vol. 70, No. 187, which he

has, and I recommended that he review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified him that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 358

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB55110

94507G

07SEP2019 04C05 Poultry Good

Commercial

Practices

Finalized On 9/7/19 at approximately 1035 hours the

inspector on line #1 stand #1 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red to purple in color.

The neck of the bird had no cut mark on it and

was fully intact, indicating that the bird was not

bleed out thoroughly in accordance with 9 CFR

381.65(b). I informed 

, about the bird that had been

presented to me. I showed the bird.

After informing the plant about the cadaver bird I

went to where the birds are slaughtered on Line

#1 and observed the birds going through the kill

machine, past the backup killer, and just before

they entered the scalder. I observed these areas

for approximately 15 minutes total. During that

time, I did not see any birds go past that were not

properly slaughtered. I also reminded 

and that the PPIA and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and that they not die from causes other

than slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 359

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB30111

02207G

07OCT2019 04C05 Poultry Good

Commercial

Practices

Finalized On 10/7/19 at approximately 0845 hours the

inspector on line #2 stand #4 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red to purple in color.

The neck of the bird had no cut mark on it and

was fully intact, indicating that the bird was not

bleed out thoroughly in accordance with 9 CFR

381.65(b). I informed ,

and , about

the bird that had been presented to me. I showed

the bird. After informing

the plant about the cadaver bird I went to where

the birds are slaughtered on Line #2 at

approximately 0900 hours and observed the birds

going through the kill machine, past the backup

killer, and just before they entered the scalder. I

observed these areas for approximately 10

minutes total. During that time, I did not see any

birds go past that were not properly slaughtered. I

also reminded that the

PPIA and Agency regulations require that live

poultry be handled in a manner that is consistent

with good commercial practices and that they not

die from causes other than slaughter. I referred

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

which they have, and I recommended that they

review it for FSIS recommendations concerning

treatment of live poultry before slaughter. I

notified them that this MOI will be forwarded to

the District Office and the District Veterinary

Medical Specialist (DVMS) in case additional

follow-up is recommended.

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 360

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB54061

04710G

10OCT2019 04C05 Poultry Good

Commercial

Practices

Finalized On 10/10/19 at approximately 0700 hours the

inspector on stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red to purple in color.

The neck of the bird had no cut mark on it and

was fully intact, indicating that the bird was not

bleed out thoroughly in accordance with 9 CFR

381.65(b). I informed

about the bird that had been

presented to me. I showed the bird.

After informing the plant about the cadaver bird I

went to where the birds are slaughtered on Line

 and observed the birds going through the kill

machine, past the backup killer, and just before

they entered the scalder. I observed these areas

for approximately 10 minutes total. During that

time, I did not see any birds go past that were not

properly slaughtered. I also reminded 

that the PPIA and Agency regulations require that

live poultry be handled in a manner that is

consistent with good commercial practices and

that they not die from causes other than

slaughter. I referred him to Federal Register

Notice Vol. 70, No. 187, which he has, and I

recommended that he review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified him that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (4) (b) (6) (b) (6) (b) (6) (b) (4) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 361

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB42111

04911G

11OCT2019 04C05 Poultry Good

Commercial

Practices

Finalized On 10/11/19 at approximately 0730 hours the

inspector on line #2 stand #1 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red to purple in color.

The neck of the bird had no cut mark on it and

was fully intact, indicating that the bird was not

bleed out thoroughly in accordance with 9 CFR

381.65(b). I informed 

 and about

the bird that had been presented to me. I showed

 the bird. After informing

the plant about the cadaver bird I went to where

the birds are slaughtered on Line #2 and observed

the birds going through the kill machine, past the

backup killer, and just before they entered the

scalder. I observed these areas for approximately

10 minutes total. During that time, I did not see

any birds go past that were not properly

slaughtered. I also reminded and 

 that the PPIA and Agency regulations

require that live poultry be handled in a manner

that is consistent with good commercial practices

and that they not die from causes other than

slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 362

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB01111

01514G

14OCT2019 04C05 Poultry Good

Commercial

Practices

Finalized On 10/14/19 at approximately 0730 hours the

inspector on line #1 stand #1 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red in color. The neck

of the bird had no cut mark on it and was fully

intact, indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed 

and about the bird that

had been presented to me. I showed 

and the bird. After informing the plant

about the cadaver bird I went to where the birds

are slaughtered on Line #1 and observed the birds

going through the kill machine, past the backup

killer, and just before they entered the scalder. I

observed these areas for approximately 10

minutes total. During that time, I did not see any

birds go past that were not properly slaughtered. I

also reminded and that the

PPIA and Agency regulations require that live

poultry be handled in a manner that is consistent

with good commercial practices and that they not

die from causes other than slaughter. I referred

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

which they have, and I recommended that they

review it for FSIS recommendations concerning

treatment of live poultry before slaughter. I

notified them that this MOI will be forwarded to

the District Office and the District Veterinary

Medical Specialist (DVMS) in case additional

follow-up is recommended.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 363

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB42101

02016G

16OCT2019 04C05 Poultry Good

Commercial

Practices

Finalized On 10/16/19 at approximately 0830 hours the

inspector on line #2 stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red to purple in color.

The neck of the bird had no cut mark on it and

was fully intact, indicating that the bird was not

bleed out thoroughly in accordance with 9 CFR

381.65(b). I informed 

 about the bird that had been presented to

me. I showed all the parties mentioned above the

bird. After informing the plant about the cadaver

bird I went to where the birds are slaughtered on

Line #2 and observed the birds going through the

kill machine, past the backup killer, and just

before they entered the scalder. I observed these

areas for approximately 10 minutes total. During

that time, I did not see any birds go past that

were not properly slaughtered. I also reminded

the above-mentioned parties that the PPIA and

Agency regulations require that live poultry be

handled in a manner that is consistent with good

commercial practices and that they not die from

causes other than slaughter. I referred them to

Federal Register Notice Vol. 70, No. 187, which

they have, and I recommended that he review it

for FSIS recommendations concerning treatment

of live poultry before slaughter. I notified them

that this MOI will be forwarded to the District

Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 364

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB03121

14905G

05NOV2019 04C05 Poultry Good

Commercial

Practices

Open On 11/5/19 at approximately 0745 hours the

inspector on line #2 stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red in color. The neck

of the bird had no cut mark on it and was fully

intact, indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed 

, about the bird that had been

presented to me. I showed 

and the bird. After informing the plant

about the cadaver bird I went to where the birds

are slaughtered on Line #2 and observed the birds

going through the kill machine, past the backup

killer, and just before they entered the scalder. I

observed these areas for approximately 10

minutes each. During that time, I did not see any

birds go past that were not properly slaughtered. I

also reminded and 

 that the PPIA and Agency regulations

require that live poultry be handled in a manner

that is consistent with good commercial practices

and that they not die from causes other than

slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 365

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB03121

10320G

20NOV2019 04C05 Poultry Good

Commercial

Practices

Finalized On 11/18/19 at approximately 1220 hours the

inspector on line #2 stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was dark purple to bright red in

color. The neck of the bird had no cut mark on it

and was fully intact, indicating that the bird was

not bleed out thoroughly in accordance with 9

CFR 381.65(b). I informed 

 about the bird that had

been presented to me. I showed 

 the bird. After informing the

plant about the cadaver bird I went to where the

birds are slaughtered on Line #2 and observed the

birds going through the kill machine, past the

backup killer, and just before they entered the

scalder. I observed these areas for approximately

10 minutes each. During that time, I did not see

any birds go past that were not properly

slaughtered. I also reminded 

 and that the PPIA and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and that they not die from causes other

than slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 366

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB06121

13320G

20NOV2019 04C05 Poultry Good

Commercial

Practices

Finalized On 11/20/19 at approximately 1110 hours the

inspector on line stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was red to purple in color and

engorged with blood. The bird had an

approximately 1⁄2-inch break in the skin. The break

in the skin was located at the dorsal aspect of the

base of the neck and had not penetrated any of

the deeper tissue past the skin to properly cut the

underlying structures, including the vessels. All of

this indicated that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed , and

 about the bird

that had been presented to me. I showed 

 and the bird. After informing

the plant about the cadaver bird, I went to where

the birds are slaughtered on and observed

the birds going through the kill machine, past the

backup killer, and just before they enter the

scalder. I observed these areas for approximately

10 minutes total. During that time, I did not see

any birds go past that were not properly

slaughtered. I reminded and 

that the PPIA and Agency regulations require that

live poultry be handled in a manner that is

consistent with good commercial practices and

that they not die from causes other than

slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4) (b) (6) (b) (6) (b) (4)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 367

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB13101

10421G

21NOV2019 04C05 Poultry Good

Commercial

Practices

Finalized On 11/21/19 at approximately 0615 hours the

inspector on line #2 stand #3 presented me a

cadaver bird. The bird had its head and neck

attached which was dark purple to bright red in

color. The neck of the bird had no cut mark on it

and was fully intact, indicating that the bird was

not bleed out thoroughly in accordance with 9

CFR 381.65(b). I informed 

 and ,

about the bird that had been presented to me. I

showed and the bird. After

informing the plant about the cadaver bird I went

to where the birds are slaughtered on Line #2 and

observed the birds going through the kill machine,

past the backup killer, and just before they

entered the scalder. I observed these areas for

approximately 10 minutes total. During that time,

I did not see any birds go past that were not

properly slaughtered. Later in the day at

approximately 1200 hours the inspector on line

#2 stand #1 presented me another cadaver bird.

This bird also had its head and neck attached

which was dark purple to red in color. The neck of

the bird had no cut mark on it and was fully

intact, indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed ,

, about the bird that had been

presented to me. I showed 

and the bird. After informing the plant

about the cadaver bird I went to where the birds

are slaughtered on Line #2 and observed the birds

going through the kill machine, past the backup

killer, and just before they entered the scalder. I

observed these areas for approximately 10

minutes total. During that time, I did not see any

birds go past that were not properly slaughtered.  

I also reminded and 

that the PPIA and Agency regulations

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 368

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

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 referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 369

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB42071

13526G

26NOV2019 04C05 Poultry Good

Commercial

Practices

Open On 11/26/19 at approximately 0745 hours the

inspector on line #2 stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was dark purple to bright red in

color. The neck of the bird had no cut mark on it

and was fully intact, indicating that the bird was

not bleed out thoroughly in accordance with 9

CFR 381.65(b). I informed 

, about

the bird that had been presented to me. I showed

 and the bird. After

informing the plant about the cadaver bird I went

to where the birds are slaughtered on Line #2 and

observed the birds going through the kill machine,

past the backup killer, and just before they

entered the scalder. I observed these areas for

approximately 10 minutes total. During that time,

I did not see any birds go past that were not

properly slaughtered. I also reminded 

and that the PPIA and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and that they not die from causes other

than slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 370

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB16111

20804G

04DEC2019 04C05 Poultry Good

Commercial

Practices

Open On 12/3/19 at approximately 1315 hours the

inspector on line #2 stand #1 presented me a

cadaver bird. The bird had its head and neck

attached which was dark purple to bright red in

color. The neck of the bird had no cut mark on it

and was fully intact, indicating that the bird was

not bleed out thoroughly in accordance with 9

CFR 381.65(b). I informed 

, Team Lead,

about the bird that had been presented to me. I

showed and the bird. After

informing the plant about the cadaver bird I went

to where the birds are slaughtered on Line #2 and

observed the birds just before they entered the

scalder. I observed this area for approximately 5

minutes total. During that time, I did not see any

birds go past that were not properly slaughtered. I

also reminded and that the

PPIA and Agency regulations require that live

poultry be handled in a manner that is consistent

with good commercial practices and that they not

die from causes other than slaughter. I referred

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

which they have, and I recommended that they

review it for FSIS recommendations concerning

treatment of live poultry before slaughter. I

notified them that this MOI will be forwarded to

the District Office and the District Veterinary

Medical Specialist (DVMS) in case additional

follow-up is recommended.

(b) (6) (b) (6)(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 371

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB16121

23513G

13DEC2019 04C05 Poultry Good

Commercial

Practices

Open On 12/9/19 at approximately 0930 hours the

inspector on stand #4 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red to purple in color

and engorged with blood. The back of the neck

had a small 1⁄4 inch break in the skin that did not

penetrate any of the deeper structures including

the vessels. All of this indicated that the bird was

not bleed out thoroughly in accordance with 9

CFR 381.65(b). I informed 

, about the bird that had

been presented to me. I showed 

 and the bird. I was presented

the bird after the start of lunch when the

establishment was not hanging birds, so I was not

able to observe the kill process at that time. I also

reminded 

that the PPIA and Agency regulations require that

live poultry be handled in a manner that is

consistent with good commercial practices and

that they not die from causes other than

slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

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

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 372

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB03081

22427G

27DEC2019 04C05 Poultry Good

Commercial

Practices

Open On 12/27/19 at approximately 0755 hours the

inspector on stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was purple to bright red in color.

On the back of the neck approximately, 1⁄2 inch

below the head, there was an

approximately 1⁄2 cut or tear to the outer skin

layers that did not penetrate past the deepest

layer of the skin and did not affect any of the

underlying vessels. The rest of the neck of the bird

had no cut mark on it and was fully intact,

indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed 

, about the bird that had been

presented to me. I showed 

and the bird. After informing the plant

about the cadaver bird I went to where the birds

are slaughtered on and observed the birds

going through the kill machine, past the backup

killer, and just before they enter the scalder. I

observed this area for approximately 20 minutes

total. During that time, I did not see any birds go

past that were not properly slaughtered. I also

reminded 

that the PPIA and Agency regulations require that

live poultry be handled in a manner that is

consistent with good commercial practices and

that they not die from causes other than

slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

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

(b) (6)

(b) (6) (b) (6) (b) (4) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 373

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB43071

22127G

27DEC2019 04C05 Poultry Good

Commercial

Practices

Open On 12/20/19 at approximately 0900 hours the

inspector on line #1 stand #3 presented me a

cadaver bird. The bird had its head and neck

attached which was purple to bright red in color.

The right side of mouth had a very tiny,

approximately 1/8 inch, cut or tear that did not

penetrate past the skin and did not affect any of

the underlying vessels. The rest of the neck of the

bird had no cut mark on it and was fully intact,

indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed 

, about

the bird that had been presented to me. I showed

 the bird. After

informing the plant about the cadaver bird I went

to where the birds are slaughtered on Line #1 and

observed the birds going through the kill machine,

past the backup killer, and just before they enter

the scalder. I observed this area for approximately

10 minutes total. During that time, I did not see

any birds go past that were not properly

slaughtered. I also reminded

and that the PPIA and Agency

regulations require that live poultry be handled in

a manner that is consistent with good commercial

practices and that they not die from causes other

than slaughter. I referred them to Federal Register

Notice Vol. 70, No. 187, which they have, and I

recommended that they review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified them that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 374

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB44161

23928G

28DEC2019 04C05 Poultry Good

Commercial

Practices

Open On 12/28/19 at approximately 0740 hours the

inspector on line #2 stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was purple to bright red in color.

The neck of the bird had no cut mark on it and

was fully intact, indicating that the bird was not

bleed out thoroughly in accordance with 9 CFR

381.65(b). I informed 

, about the bird that had been

presented to me. I showed ,

 the bird. After informing

the plant about the cadaver bird I went to where

the birds are slaughtered on Line #2 and observed

the birds going through the kill machine, past the

backup killer, and just before they enter the

scalder. I observed these areas for approximately

10 minutes total. During that time, I did not see

any birds go past that were not properly

slaughtered. I also reminded .

 that the PPIA

and Agency regulations require that live poultry

be handled in a manner that is consistent with

good commercial practices and that they not die

from causes other than slaughter. I referred them

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

they have, and I recommended that they review it

for FSIS recommendations concerning treatment

of live poultry before slaughter. I notified them

that this MOI will be forwarded to the District

Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 375

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB17120

15414G

14JAN2020 04C05 Poultry Good

Commercial

Practices

Open On 1/13/20 at approximately 1330 hours the

inspector on stand #3 presented me a

cadaver bird. The bird had its head and neck

attached which was purple to bright red in color.

The body of the bird, starting at approximately 3

inches below the base of the neck, was cut in half

and mutilated. None of the areas of mutilation

were near the neck and the entire neck of the bird

had no cut mark on it and was fully intact,

indicating that the bird was not bleed out

thoroughly in accordance with 9 CFR 381.65(b). I

informed 

 about the bird that had

been presented to me. I showed 

 the bird. I then went back

down to the floor to condemn the bird and at

approximately 1340 hours the same inspector on

 stand #3 presented me with another

cadaver bird. The bird had its head and neck

attached which was dark purple to bright red in

color. The neck of the bird had no cut mark on it

and was fully intact, indicating that the bird was

not bleed out thoroughly in accordance with 9

CFR 381.65(b). I informed 

about

the bird that had been presented to me. I showed

 the bird. As it

was the end of the shift I was not able to observe

the birds earlier in the process.  I also reminded

 that the PPIA and

Agency regulations require that live poultry be

handled in a manner that is consistent with good

commercial practices and that they not die from

causes other than slaughter. I referred them to

Federal Register Notice Vol. 70, No. 187, which

they have, and I recommended that they review it

for FSIS recommendations concerning treatment

of live poultry before slaughter. I notified them

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

(b) (6)

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

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 376

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

that this MOI will be forwarded to the District

Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.

P9197 Perdue Foods, LLC. UAB56090

24205G

05FEB2020 04C05 Poultry Good

Commercial

Practices

Open On 2/4/20 at approximately 1210 hours the

inspector on line #1 stand #2 presented me a

cadaver bird. The bird had its head and neck

attached which was bright red to purple in color.

The neck of the bird had no cut mark on it and

was fully intact, indicating that the bird was not

bleed out thoroughly in accordance with 9 CFR

381.65(b). I informed 

 about the bird that had been

presented to me. I showed 

and the bird. After informing the plant

about the cadaver bird I went to where the birds

are slaughtered on Line #1 and observed the birds

going through the kill machine, past the backup

killer, and just before they entered the scalder. I

observed these areas for approximately 10

minutes total. During that time, I did not see any

birds go past that were not properly slaughtered. I

also reminded that the PPIA and

Agency regulations require that live poultry be

handled in a manner that is consistent with good

commercial practices and that they not die from

causes other than slaughter. I referred him to

Federal Register Notice Vol. 70, No. 187, which he

has, and I recommended that he review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified him that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 377

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P9197 Perdue Foods, LLC. UAB56090

21610G

10FEB2020 04C05 Poultry Good

Commercial

Practices

Open On 2/10/20 at approximately 0930 hours (right

before the lunch break) the inspector on line #2

stand #2 presented me a cadaver bird. The bird

had its head and neck attached which was bright

red to purple in color. The neck of the bird had no

cut mark on it and was fully intact, indicating that

the bird was not bleed out thoroughly in

accordance with 9 CFR 381.65(b). I informed

 about the bird that had been

presented to me. I showed the bird.

After informing the plant about the cadaver bird I

went to where the birds are slaughtered on Line

#2 (once the live hang area started production

after lunch at approximately 0950 hours)

and observed the birds going through the kill

machine, past the backup killer, and just before

they entered the scalder. I observed these areas

for approximately 10 minutes total. During that

time, I did not see any birds go past that were not

properly slaughtered. I also reminded

that the PPIA and Agency regulations require that

live poultry be handled in a manner that is

consistent with good commercial practices and

that they not die from causes other than

slaughter. I referred him to Federal Register

Notice Vol. 70, No. 187, which he has, and I

recommended that he review it for FSIS

recommendations concerning treatment of live

poultry before slaughter. I notified him that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended.

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 378

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA431604

5723G

23APR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1648 hours while providing a

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

the head intact which was red to purple in color

and had not received a cut to the neck. 

 was notified 

of the observation of a bird dying other than by

slaughter. At approximately 1704 hours, after

completing the inspection breaks,

 stated that the cause of

the uncut bird was failure to perform duties by

the back-up kill personnel who will received

disciplinary action.  I performed Good Commercial

Practice verification by observing 200 carcasses

enter the scalder and 200 carcasses at the kill

blade.  There were no live birds observed entering

the scalder and the back-up kill performed a cut

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

is recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully Allen

harim Foods, LLC P935 Harbeson, DE. 19951

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 379

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA090805

4829G

29MAY2019 04C05 Poultry Good

Commercial

Practices

Finalized From:                  . 

Date:                   05/29/2019. 

Subject:                             Poultry Good

Commercial Practice/ MOI Meeting Date.  

05/29/22019 Meeting Time    : 8.00 am 

Establishment: P 935 – Allen Harim Foods, LLC 

Comments:        MOI.               To: 

               CC: .   This

memorandum of interview serves as written

notification of occurrence of one Cadaver found

on USDA line inspection stations 4 today May

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

three station four informed me that she observed

a cadaver carcass on her stations and hanged it

for Veterinary disposition. I observed the cadavers

on the station with head intact and no cut on the

neck. The facial area was cherry red and swollen;

skin around the neck was purple in color while the

rest of the body of the carcass was bright red in

color. A supervisor was present at that

time, (

notified him and showed him the cadaver birds.

He assured me to take proper measures to

prevent recurrence.  The agency regulations do

require that poultry must be slaughtered in

accordance with good commercial practices in

manner that will result in thorough bleeding of

carcass and ensure that breathing was stopped

prior to scalding, so that birds do not drown or die

other than slaughter. It is the agency expectation

that all Good Commercial Practices be correctly

and effectively implemented. The copy of this

Memorandum will be forwarded to Front Line

Supervisor (FLS) in case additional follow up is

recommended. A copy will be placed in the

official USDA file. Please feel free to contact me

with any question or concern. Sincerely. 

 CC: Dr. 

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 380

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA171206

1003G

03JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0952 hours while performing

ante-mortem and Good Commercial Practice

verification I observed a damaged cage on trailer

number 71, located in the cooling shed.  The

flooring to the cage had collapsed, birds were

piled on top of one another and the birds on the

bottom were dead. I observed one live bird in a

pile of DOAs covering the approximate 3-foot X

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

belt for medium birds.  The pile of DOAs was deep

(approximately 2 feet) enough that the birds on

the top of the pile were touching the DOA belt

blocking DOAs from exiting the belt. 

 and

 were notified of birds dying

other than by slaughter and being handled in a

way that could result in excitement, discomfort or

injury while being handled in connection with

slaughter. had trailer #71 moved from

the cooling shed to live receiving immediately and

the damaged cage was removed from service after

the affected live birds were placed into

production.  No verbal preventive measure was

provided in response to the live bird being

observed in the DOAs. It is recommended that

establishment management review the Federal

Register on “Treatment of Live Poultry before

Slaughter”, published September 2015 for FSIS

recommendations concerning treatment of live

poultry prior to slaughter.  was

notified that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. Respectfully,   

 Allen Harim Foods, LLC. P-935 

Harbeson, DE. 19951

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 381

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA571406

4403G

03JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1504 hours while performing

ante-mortem and Good Commercial Practice

verification I observed the dumper operator move

the cage, that had just dumped, back from the

dumper.  One live bird remained in the area

where the cage had been.  The dumper operator

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

attempt to move the bird onto the conveyor belt

approximately 2 feet below.  The bird remained in

place and the dumper operator kicked the bird a

second time onto the conveyor belt below. 

 was notified of the bird

being handled in a way that could result in

excitement, discomfort or injury in connection

with slaughter.  replaced the dumper

operator with another employee. It is

recommended that establishment management

review the Federal Register on “Treatment of Live

Poultry before Slaughter”, published September

2015 for FSIS recommendations concerning

treatment of live poultry prior to slaughter

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, Allen

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 382

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA271606

4305G

05JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1355 hours, I was notified that

the inspector on station 2 had hung back 1

bird for Veterinarian disposition.  Upon arrival I

observed the bird had head intact which were red

to purple in color and had not received a cut to

the neck.  

was notified of the observation of a bird dying

other than by slaughter.  At approximately 1407

hours I performed Good Commercial Practice

verification by observing 200 carcasses enter the

scalder, and 200 carcasses at the kill blade.  There

were no live birds observed entering the scalder

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

of all birds not cut by the kill blade. 

stated that the responsible establishment

employee would receive disciplinary action. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter

was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, 

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

19951

(b) (4) (b) (6) (b) (6)(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 383

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA050906

2818G

18JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized From:                  

Date:                   06/18/2019. 

Subject:                             Poultry Good

Commercial Practice/ MOI Meeting Date.  

06/18/22019 Meeting Time    : 8.15 am 

Establishment: P 935 – Allen Harim Foods, LLC 

Comments:        MOI.               To: 

               CC: .   This

memorandum of interview serves as written

notification of occurrence of one Cadaver found

on USDA line 1 inspection stations 4 today June

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

line one station four informed me that she

observed a cadaver carcass on her stations and

hanged it for Veterinary disposition. I observed

the cadavers on the station with head intact and

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

and swollen; skin around the neck was purple in

color while the rest of the body of the carcass was

bright red in color. 

was   notified and showed him the

cadaver birds. He observed and  assured me to

take proper measures to prevent recurrence.  

The agency regulations do require that poultry

must be slaughtered in accordance with good

commercial practices in manner that will result in

thorough bleeding of carcass and ensure that

breathing was stopped prior to scalding, so that

birds do not drown or die other than slaughter. It

is the agency expectation that all Good

Commercial Practices be correctly and effectively

implemented. The copy of this Memorandum

will be forwarded to Front Line Supervisor (FLS) in

case additional follow up is recommended. A copy

will be placed in the official USDA file. Please feel

free to contact me with any question or concern. 

Sincerely. 

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 384

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA271806

5420G

20JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1712 hours, I was notified that

the inspector on station 2 had hung back 1

bird for Veterinarian disposition.  Upon arrival I

observed the bird had head intact which were red

to purple in color and had not received a cut to

the neck.  

was notified of the observation of a bird dying

other than by slaughter.  At approximately 1732

hours I performed Good Commercial Practice

verification by observing 200 carcasses enter the

scalder, and 200 carcasses at the kill blade.  There

were no live birds observed entering the scalder

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

of all birds not cut by the kill blade. 

stated that the responsible establishment

employee would receive disciplinary action. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, Allen

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

P935 Allen Harim Foods, LLC. YXA281006

3022G

22JUN2019 04C05 Poultry Good

Commercial

Practices

Finalized Ante-mortem check performed on lot 1at about

5.00am. No concerns. Verified GCP which was in

compliance with regulations. Dumper and belts in

good condition, Birds were housed properly,

humanely handled; Birds appeared to be in good

health. DOA’s removed and denatured properly,

Stunning and Killing was effective, no loose bird in

live hang, live haul and holding sheds.

(b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 385

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA191508

4715G

15AUG2019 04C05 Poultry Good

Commercial

Practices

Finalized Ante-mortem check performed on lot 1.at about

10.50am No concerns. Verified GCP which was in

compliance with regulations. Dumper and belts in

good condition, Birds were housed properly,

humanely handled; Birds appeared to be in good

health. DOA’s removed and denatured properly,

Stunning and Killing was effective, no loose bird in

live hang, live haul and holding sheds. Weekly

Establishment Meeting MOI Food Safety

and                            Date: August 15, 2019,

                                          

                           Inspection Service            To:

Michael Pierce. Plant Manager. Allen Harim

Foods LLC Harbeson, DE 1400 Independence

                     From:    

                                                                     

FSIS.USDA. Harbeson.DE

                                                                     Avenue,

SW.                                               Washington, D.C.

20250 Attendees:   .

 FLS Hurlock Circuit. Open

NRs – 24 MOIs:       5 7/3/19: Establishment

stated, they are Waiting for the budgetary

arrangements to carry out roof work in

installment. 7/10/19. The establishment has a

plan to replace the roof in two phases. The

painting of roof will be carried out as needed in

problem areas. Any update on the budgetary

numbers.               7/17/19. No updates on

budgetary numbers. New maintenance manager

resumed the co will be answering the roofing

questions stated by .  07/24/2019.

 assured he will be taking care of

problem areas of roof in meantime, till the

budgetary arrangements are completed. 7/31/19.

stated the replacement of the roof

will be carried out in two phases.  The USDA will

be notified. He further added it might be

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

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 386

EstNbr EstName MOINbr Date

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completed in fall. 08/07/19. Same as above. 

08/15/19.   2.                7/17/19. This issue is

being discussed since March. 2019 and still is to

be completed despite repeated assurances to be

completed next week as is evident since the

discussion started. Today it is Again Left to be

discussed in next weekly meeting with the new

maintenance manager, as the previous manager

left the company, and no one was available to

take care of the issue.                 7.24.2019. Still

waiting for the completion.  The 

 assured that this issue

will be completed by 08/19/2019. 07/31/19. Will

be completed by the date.  08/07/19.  As above. 

08/14/19.

                                                                                     

                            3.           7/31/19. Roaches were

observed again on the walls in the paw area.

Inspector on station 1, line 1 station 3 also

observed roaches on the frame stands

asked that he wants to see

the pest control company management

representative.  08/07/19. stated that the

pest control company employees will be coming

twice a week. One day they will be treating

outside of the building and one day in plant and

USDA offices.  08/15/19. The hanging vents on

Line 2 need to be addressed.  stated

that he will address this issue.  stated

that the establishment needs to make the

appropriate adjustments to the machinery when

running small birds on the medium bird lines in

order to comply with presentation.  7/3/19:  This

continues to be an issue on line 1 and line 2. 

7/10/19.  It is Still being observed, any progress in

the adjustments. 7/17/19. It is better before, but

hocks and paws are observed every other few

birds. The Machines needs to be adjusted. 

7/24/19. It continues on line two I observed while

giving breaks on the line. 7/31/19. This continues

(b) (6) (b) (6) (b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 387

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to be issue on all lines. Ride around paws were

also observed. The bird is hanging on to the

shackle which already had paws which are not

kicked off. The supervisor was notified by

. 8/07/19. We discussed and

pointed out the issue and our concern. On

08/08/19 it was very bad on line 2 and have to

stop line multiple time. 8/15/19. 7/31/19. The

Supervisors and Assistant supervisor when

approached in certain department on some of the

occasions they say this is not their department or

they don’t have time to address the issue. Some

of the employee say they don’t work for them. 

8/07/19. Some of the usda inspector are also

complaining that when they call for supervisor or

assistant supervisors they are not available to

address the minor issues. 8/15/19. The

management ensured that they will be placing

managers and supervisors in each area by names

responsible to address all the issues on spot.   7:

The ground behind the parked trailers is low and

having standing water in it, serves as breeding

place for insects and source of water for rodents

and other vermin’s, and some disease producing

spoilage organisms. As Above. 7/24/19. If any

steps are being taken to resolve the issue. 

7/31/19. Any update. Or when this issue will be

addressed. In last meeting 

assured to observe the area. 08/07/19. 

 had a plan to remove all the trailers, trash

from the area and keep it clean. Some of the

trailers were removed and remaining will be

removed and clean the area. 8.15/19.    8 - In

Evisceration between Line 1 and 2 the floors are

starting to get pot holes. Line 1 station 3, I noticed

a large puddle of bloody standing water.

Sanitation has cleaned the wall on the Leg-Cut up

side, however the issue with the cracks still exist. 

08/07/19.  Still is same. Needs to be corrected

and fixed. 08/15/19. 9: - On 07/30/19 While

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 388

EstNbr EstName MOINbr Date

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Code TaskName Status MOI Agenda

doing a SSOP walk through I observed various

safety issues mainly in Offline/ Injection and

Marination areas there was standing water

puddles as the Jacks were riding through the

water was being splashed. I asked one of the

associates if they could remove the water from

standing which they did. Also, the Jacks drivers

were riding and moving fast. May be a safety

issue. 07/31/2019. stated that this

issue will be addresses. New jacks are being

brought in and the employees and management

will be trained and coached.   08/07/19. Some

improvement was noticed. No standing water was

observed but jack drivers are riding the jacks. The

management stated to address the issue and

riders will be coached and disciplined. 10: - The

management structure and extension lists are not

being updated. This issue has been discussed

previously. 08/07/19. Got above structure, but

neat copy will be appreciated. 08/15/19.   Plant

management is working on consumer complaint.

Report is being compiled by as

discussed with 

08/14/19. The report was handed over to 

 for her review. A electronic copy

will be submitted to me today. New Issue: On

August 13, 2019 we observed the exit door in the

maintenance shop would not close. Also, we

observed four empty water bottles and old gloves

outside on the ground On Tuesday 08/13/19

while walking through the Live hang area we

observed that the door that leads to outside

Electrical room # 7 doesn't close at all also back in

that area was standing water. On today at 0402

hours 08/14/19 

looked me and  showed me the  Live hang break

room the entire room had been CLEAN including

the walls, floors and the racks that hold their

belongings was also removed and cleaned. The

whole area looked different. ESTABLISHMENT

(b) (6)(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 389

EstNbr EstName MOINbr Date

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Code TaskName Status MOI Agenda

MICROBIAL DATA: 7/3/19:  TEST RESULTS

REVIEWED TIME FRAME Post Chill

Salmonella/Campylobacter– Medium Birds 

Salmonella 7/10/18 – 07/30/19 Campylobacter

12/17/18 – 7/30/19/ Post Chill

Salmonella/Campylobacter – Small Birds 

Salmonella 7/12/18 – 07/30/19 Campylobacter

12/26/18 – 07/30/19 Parts

Salmonella/Campylobacter Salmonella

6/12/18 – 07/30/19 Campylobacter

6/25/18 – 07/30/19 E. coli at Rehang and Post

Chill – Medium Birds 6/8/19 – 6/24/19 E.

coli at Rehang and Post Chill – Small Birds 

6/8/19 – 6/24/19 Tote Swabs 

6/17/19 – 6/28/19 Reuse Water Tank

Salmonella/E. coli 6/12/19 – 6/19/19 

Concerns: The Campylobacter is positive

07/25/19,7/1/19,7/16/19, and 7/21/19.

 Salmonella sp is positive7/18-7/25/19 

Establishment Response:  USDA MICROBIAL

DATA: 6/25/19:  Carcass Rinse – Campylobacter

Positive 6/26/19:  Parts (Drumsticks) – Not

analyzed due to temperature too high 6/27/19: 

Follow-up Parts (Drumsticks) - Negative Copies of

the results were provided to establishment

management as per Directive 5010.1.
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 390

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA371208

5928G

28AUG2019 04C05 Poultry Good

Commercial

Practices

Finalized Ante-mortem check performed on lot 1. at about

11.35am. No concerns. Verified GCP which was in

compliance with regulations. Dumper and belts in

good condition, Birds were housed properly,

humanely handled; Birds appeared to be in good

health. DOA’s removed and denatured properly,

Stunning and Killing was effective, no loose bird in

live hang, live haul and holding sheds. From:        

         Date:                  

08/28/2019 Subject:                             Poultry

Good Commercial Practice/ MOI Meeting Date.  

08/28/2019 Meeting Time    : 12.15 pm 

Establishment: P 935 – Allen Harim Foods, LLC 

Comments:        MOI. (Good Commercial Practice) 

              To: . 

              CC .   This

memorandum of interview serves as written

notification of occurrence of one Cadaver found

on USDA inspection stations 3line today

August 28, 2019.    At approximately 12.15 pm.

while walking through between the line two and

three observed one cadaver carcass on the station

three with head intact and no cut on the neck

which was hanged by FI   for Veterinary

disposition. The facial area was cherry red and

swollen; skin around the neck was purple in color

while the rest of the body of the carcass was

bright red in color. The 

was notified and showed him the carcass.  

The agency regulations do require that poultry

must be slaughtered in accordance to good

commercial practices in manner that will result in

thorough bleeding of carcass and ensure that

breathing was stopped prior to scalding, so that

birds do not drown or die other than slaughter. It

is the agency expectation that all Good

Commercial Practices be correctly and effectively

implemented. The copy of this Memorandum

will be forwarded to Front Line Supervisor (FLS) in

case additional follow up is recommended. A copy

(b) (6)(b) (6) (b) (4) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 391

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

will be placed in the official USDA file. Please feel

free to contact me with any question or concern. 

Sincerely. CC: 

P935 Allen Harim Foods, LLC. YXA041509

0924G

24SEP2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1539 hours while verifying Good

Commercial Practice I observed a live bird in the

DOA bin.  The only portion of the bird's body

visible was the back and the bird was covered

with denaturant.  

 was notified of birds being handled in a

way that could result in excitement, discomfort,

injury or death while being handled in connection

with slaughter.  stated that the

employee responsible would receive disciplinary

action and the bird was euthanized. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2015 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, Allen

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 392

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA431609

1327G

27SEP2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1650 hours while performing

Good Commercial Practice I observed an

establishment employee who was dumping birds

onto the medium bird belt take an approximate

5-foot-long metal bar and jab at a bird

approximately 8 times that was lodged in the

cage while the cage was still in the dump

position.  The cage was then placed back on the

dumper in the upright position and moved to the

exit side of the dumper, making room for the next

cage to be dumped.  The employee then moved

the next cage into position to be dumped, walked

over to the previous cage, removed the bird and

placed it onto the medium bird belt to be

transferred into live hang. 

 was notified of a

bird being handled in a way that could result in

excitement, discomfort, or injury while being

handled in connection with slaughter.  

stated that the employee responsible would

receive disciplinary action and a retraining of all

personnel would be completed. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2015 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, Allen 

Harim Foods, LLC. P-935

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 393

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA421610

1922G

22OCT2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1758 hours, I was notified that

the inspector on station 3 had hung back 1

bird for Veterinarian disposition.  Upon arrival I

observed the bird had head intact which were red

to purple in color and had not received a cut to

the neck.  

was notified of the observation of a bird dying

other than by slaughter.  At approximately 1816

hours I performed Good Commercial Practice

verification by observing 200 carcasses enter the

scalder, and 200 carcasses at the kill blade.  There

were no live birds observed entering the scalder

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

of all birds not cut by the kill blade.  

stated that the kill blade had been adjusted due

to the change in the size of the birds. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, 

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

19951

(b) (4) (b) (6) (b) (6)(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 394

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA400810

1825G

25OCT2019 04C05 Poultry Good

Commercial

Practices

Open Ante-mortem check performed on lot 1at 5.45am.

No concerns. Verified GCP which followed

regulations. Dumper and belts in good condition,

Birds were housed properly, humanely handled;

Birds appeared to be in good health. DOA’s

removed and denatured properly, Stunning

and Killing was effective, no loose bird in live

hang, live haul and holding sheds. From:        

         Date:                  

10/22/2019 Subject:                             Poultry

Good Commercial Practice/ MOI Meeting Date.  

10/22/2019 Meeting Time    : 7.00 am 

Establishment: P 935 – Allen Harim Foods, LLC 

Comments:        MOI. (Good Commercial Practice) 

              To: . 

              CC: .   This

memorandum of interview serves as written

notification of occurrence of One Cadaver found

on USDA inspection stations four today

October 22, 2019.    At approximately 6.55 pm.

while going for breaks on station four

observed one cadaver carcass with head intact

and no cut on the neck. Showed the carcass to 

which was hanged by FI   for

Veterinary disposition. The facial area was cherry

red and swollen; skin around the neck was purple

in color while the rest of the body of the carcass

was bright red in color. The 

 was notified and showed

him the carcass.  The agency regulations do

require that poultry must be slaughtered in

accordance to good commercial practices in

manner that will result in thorough bleeding of

carcass and ensure that breathing was stopped

prior to scalding, so that birds do not drown or die

other than slaughter. It is the agency expectation

that all Good Commercial Practices be correctly

and effectively implemented. The copy of this

Memorandum will be forwarded to DVMS Raleigh

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

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 395

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

district and Front-Line Supervisor (FLS) in case

additional follow up is recommended. A copy will

be placed in the official USDA file. Please feel free

to contact me with any question or concern. 

Sincerely. 

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 396

EstNbr EstName MOINbr Date

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P935 Allen Harim Foods, LLC. YXA341910

2431G

31OCT2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1804 hours while providing

inspection breaks on line 2, station 1 I observed a

cadaver with head intact.  The head and neck of

the carcass was red to purple in color and had not

received a cut to the neck.  

 was notified of

the cadaver and stated that he would take a

picture of the cadaver and send to Live Hang

Management.  At approximately 1832 hours I

performed Good Commercial Practice (GCP)

verification by observing 200 carcasses enter the

scalder and 200 carcasses at the kill blade.  There

were no live birds observed entering the scalder

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

of all birds not cut by the kill blade.  

 was notified of the

observation of a bird dying other than by

slaughter.  During the GCP verification I observe 1

live bird jammed in the corner of the

stainless-steel DOA table at the end of the DOA

belt by approximately 50 DOAs.  

 was notified of the

observation of a bird being handled in a way that

could result in excitement, discomfort, or injury

while being handled in connection with slaughter.

It is recommended that establishment

management review the Federal Register on

“Treatment of Live Poultry before Slaughter”,

published September 2015 for FSIS

recommendations concerning treatment of live

poultry prior to slaughter.  was

notified that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. Respectfully,   

 Allen Harim Foods, LLC. P-935 

Harbeson, DE. 19951

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)(b) (5) (b) (6)
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EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA261311

5101G

01NOV2019 04C05 Poultry Good

Commercial

Practices

Open Ante-mortem check performed on lot 1.at about

5.30am.  No concerns. Verified GCP which

followed regulations. Dumper and belts in good

condition, Birds were housed properly, humanely

handled; Birds appeared to be in good

health. DOA’s removed and denatured properly,

Stunning and Killing was effective, no loose bird in

live hang, live haul and holding sheds.
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 398

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA300811

1005G

05NOV2019 04C05 Poultry Good

Commercial

Practices

Open From:                  . 

Date:                   11/05/2019 

Subject:                             Poultry Good

Commercial Practice/ MOI Meeting Date.  

11/05/2019 Meeting Time    : 7.05 am 

Establishment: P 935 – Allen Harim Foods, LLC 

Comments:        MOI. (Good Commercial Practice) 

              To: . 

              CC: .   This

memorandum of interview serves as written

notification of occurrence of one Cadaver found

on USDA inspection stations two today

November 05- 2019.    At approximately 7.00

am. on station two

called me for Cadaver disposition which was

hanged by her for veterinary disposition.

Observed cadaver carcass with head intact and no

cut on the neck. The facial area was cherry red

and swollen; skin around the neck was purple in

color while the rest of the body of the carcass was

bright red in color. The 

 was notified, and they did observe the

cadaver carcass assured me that he

will be writing up the employee responsible and

make sure to correct and coach to avoid the

reoccurrence. The DOA’s are not being removed

properly yesterday and were piled up. Saw two

birds among those birds one of them was alert

and other was suffocated but not died. The bird

was also not denatured. 

was informed immediately, and he

took the corrective action. 

was notified, and he assured

me to take the action to prevent the

reoccurrence. The agency regulations do require

that poultry must be slaughtered in accordance to

good commercial practices in manner that will

result in thorough bleeding of carcass and ensure

that breathing was stopped prior to scalding, so

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 399

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

that birds do not drown or die other than

slaughter. It is the agency expectation that all

Good Commercial Practices be correctly and

effectively implemented. The copy of this

Memorandum will be forwarded to DVMS Raleigh

district and Front-Line Supervisor (FLS) in case

additional follow up is recommended. A copy will

be placed in the official USDA file. Please feel

free to contact me with any question or concern. 

Sincerely. CC

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 400

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Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA472111

4005G

05NOV2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1600 hours, 

was notified that the inspector on line 3, station 3

had hung back 1 bird for Veterinarian disposition.

Upon arrival he observed the bird had head intact

which was red to purple in color and had not

received a cut to the neck.  At approximately

1700 hours, was notified that

the inspector on station 2 hung back 2

birds for Veterinarian disposition. Upon arrival he

observed the birds had heads intact which was

red to purple in color and had not received a cut

to the necks.  

 was notified of the observations.  

took pictures and notified 

 of the birds that had not received

cuts to the neck.  At approximately 1910 hours, I

was notified that the inspectors on station

3 and station 4 had hung back birds for

Veterinarian disposition.  Upon arrival 

station 3 had 1 bird and station 4 had 2

birds with head intact which was red to purple in

color and had not received a cut to the neck.  

 was notified of

the observation of birds dying other than by

slaughter.  At approximately 1918 hours I

performed Good Commercial Practice verification

by observing 200 carcasses enter the scalder, and

200 carcasses at the kill blade. There were no live

birds observed entering the scalder and the

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

birds not cut by the kill blade. I requested a

preventive measure from 

 who stated that the back-up kill

personnel will need to be retrained. At

approximately 2011 hours I was notified that the

inspector on station 3 had hung back a bird

for Veterinarian disposition.  Upon arrival I

observed a bird with head intact which was red to

purple in color and had not received a cut to the

neck. was

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4) (b) (4) (b) (4) (b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4) (b) (6) (b) (4)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 401

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

notified of the observation of birds dying other

than by slaughter.  I performed Good Commercial

Practice verification by observing 200 carcasses

enter the scalder, and 200 carcasses at the kill

blade. There were no live birds observed entering

the scalder and the back-up kill performed a cut

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

At approximately 2233 hours I was notified that

the inspector on station 4 had hung back

birds for Veterinarian disposition.  

 observed 3 birds with head intact which

was red to purple in color and had not received a

cut to the neck. While was verifying

the cadavers on station 4, at approximately

2237 hours, I took regulatory control by

application of U.S. Retain Tag# B21230480 to

dumping station.  and .

were notified of the continued

observation of birds dying other than by

slaughter.  A corrective action was requested as

the establishment personnel continued to be at

the back-up kill position.  stated

that a more experienced person would be placed

at the back-up position for the remainder of the

shift. At approximately 2248 I performed Good

Commercial Practice verification by observing 200

carcasses enter the scalder, and 200 carcasses at

the kill blade. There were no live birds observed

entering the scalder and the back-up kill

performed a cut to the neck of all birds not cut by

the kill blade.  Regulatory control was

relinquished.   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 and 

 were notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

(b) (4) (b) (6) (b) (6) (b) (6) (b) (4) (b) (4) (b) (4 (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 402

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

additional follow-up is recommended.   

Respectfully, 

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

19951

P935 Allen Harim Foods, LLC. YXA160911

5212G

12NOV2019 04C05 Poultry Good

Commercial

Practices

Open

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 403

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA192311

1213G

13NOV2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2150 hours, I was notified that

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

birds for Veterinarian disposition. Upon arrival to

line 2 I observed two cadavers at station 3 and

two cadavers at station 2.  All four of these birds

had heads intact which were red to purple in

color.  Upon further investigation the following

was observed at Line 2, station 2: two birds with

red to purple necks and heads. The necks had a

cut to the skin which traveled from the right side

of the neck around to the back of the neck. Both

carotid arteries were fully intact on both birds.

Petechia was observed in the breast muscle of

both birds.  One bird had blood engorged viscera,

but the other bird had no viscera present. Upon

further investigation the following was observed

at Line 2, station 3:  two birds with red to purple

necks and heads.  The neck of one bird had a cut

to the skin of the back of the neck and both

carotid arteries fully intact. The second bird had a

cut to the skin of the neck on the left side, the left

carotid artery had been nicked and the right

carotid artery was fully intact.  Both birds had

pooled blood in the thoracic cavity, no viscera and

petechia observed in the breast muscle.   At

approximately 2210 hours, I performed Good

Commercial Practice verification by observing 300

carcasses enter the scalder, and 200 carcasses at

the kill blade. There were no live birds observed

entering the scalder and the back-up kill

performed a cut to the neck of all birds not cut by

the kill blade or that had received cuts to only one

side of the neck.  At the time of my arrival at the

kill blade I observed 

who was adjusting the blade.  Upon

completion of the adjustments I notified 

of the observation of birds dying other

than by slaughter.  and I traveled to

Line 2 where he observed the four cadavers with

heads intact.  There was no further observation of

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

birds dying other than by slaughter. 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. 

and were notified that

this MOI will be forwarded to the District Office

and the District Veterinary Medical Specialist

(DVMS) in case additional follow-up is

recommended.   Respectfully, 

 Allen Harim Foods, LLC.

P-935 Harbeson, DE. 19951

P935 Allen Harim Foods, LLC. YXA081511

5015G

15NOV2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1513 hours while performing

Good Commercial Practice verification I observed

a pile of DOAs on the table at the end of the

medium bird DOA belt.  Upon investigation I

observed 1 live bird in the middle of the

approximate 50 DOAs.  

 were notified of the observation of a

bird being handled in a way that could result in

discomfort, injury or death while being handled in

connection with slaughter.  stated

that the personnel that was to keep the DOAs

cleaned up will be replaced and 

will be monitoring the floor for the remainder of

the shift. 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 and .

were notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended.   

Respectfully 

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

19951

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 405

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA132212

2109G

09DEC2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2208 hours while performing

Good Commercial Practice verification I observed

a pile of DOAs on the table at the end of the

medium bird DOA belt.  Upon investigation I

observed 2 live birds in the middle of the

approximate 50 DOAs.  

were notified of the observation of birds

being handled in a way that could result in

discomfort, injury or death while being handled in

connection with slaughter.   stated

that the personnel responsible will receive

disciplinary action. It is recommended that

establishment management review the Federal

Register on "Treatment of Live Poultry before

Slaughter", published September 2005 for FSIS

recommendations concerning treatment of live

poultry prior to slaughter were

notified that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.   Respectfully ,

 Allen Harim Foods, LLC. P-935 

Harbeson, DE. 19951

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 406

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA591512

4621G

21DEC2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1523 hours while performing

Good Commercial Practice verification I observed

two (2) live birds in the DOA bin with

approximately 25 DOAs.  

were notified of the observation of

birds being handled in a way that could result in

discomfort, injury or death while being handled in

connection with slaughter  stated that

the DOAs will be placed on the stainless-steel

table to ensure none are alive prior to being

placed into the DOA bin. At approximately 1550

hours, I was notified that the inspector on line 2,

station 3 had hung back one (1) bird for

Veterinarian disposition. Upon arrival to line 2 I

observed a cadaver with head intact which was

red to purple in color and no cut to the neck.  

Upon further investigation, I observed two (2)

additional cadavers in a stainless-steel bin which

had been removed from production by

establishment personnel.   

was notified of birds dying other than

by slaughter.  stated that the kill line

would be slowed to ensure that all birds are cut

by the kill blade and the back-up kill personnel. 

It is recommended that establishment

management review the Federal Register on

"Treatment of Live Poultry before Slaughter",

published September 2005 for FSIS

recommendations concerning treatment of live

poultry prior to slaughter. were

notified that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.   Respectfully, 

 Allen Harim Foods, LLC.

P-935 Harbeson, DE. 19951

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 407

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA541712

0023G

23DEC2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1600 hours, I was notified that

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

bird for Veterinarian disposition. Upon arrival to

line 1 I observed a cadaver with head intact which

was red to purple in color, no cut to the neck,

petechia in the breast muscle and blood engorged

viscera.   Upon further investigation 1 cadaver

was observed in a stainless-steel bin next to the

hot rehang belt.  This cadaver was observed to

have a red to purple neck and head, a cut to the

skin of the neck which traveled from the right side

of the neck around to the back of the neck and

both carotid arteries fully intact.   I was then

notified that the inspector at line 2, station 2 had

hung back 1 bird for Veterinarian disposition. 

Upon arrival at line 2 I observed a cadaver with

head intact which was red to purple in color, no

cut to the neck, petechia in the breast muscle and

no viscera.   At approximately 1622 hours

 was notified

of the observation of birds dying other than by

slaughter.  The establishment 30-minute break

had just begun.  stated that he

would provide a corrective action after the break. 

  At approximately 1832 hours, I performed

Good Commercial Practice verification by

observing 200 carcasses enter the scalder, and

200 carcasses at the kill blade. There were no live

birds observed entering the scalder and the

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

birds not cut by the kill blade or that had received

cuts to only one side of the neck. 

stated that the corrective action taken

was to adjust the kill blade and the guide bar that

ensures that the bird’s feet are seated in the

shackles.   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

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 408

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

poultry prior to slaughter. and 

were notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended.   

Respectfully, 

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

19951

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 409

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA282101

5106G

06JAN2020 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1507 hours while performing

Antemortem/GCP verification I observed 2 very

small live birds, one under each stunner.  These

birds are so small that they were falling out of the

shackles of the kill line.  There is no cover over the

drain under the kill line of the medium birds so I

investigated and observed 3 very small birds dead

inside the drain that contained approximately 3

inches of water.  

was notified of the open drain and the

possibility of birds dying other than by slaughter. 

 immediately contacted the

Maintenance Supervisor.  Upon my completion of

GCP verification stated that

maintenance will be cutting pieces of drain cover

and installing them.  At approximately 1620 hours

during the company break I returned to the kill

line area and observed another very small bird on

the floor at the entrance end of the medium bird

stunner and maintenance was measuring the

drain to cut the drain covers.  At approximately

1814 hours

informed me that the drain cover was in

place which was verified at approximately 1823

hours after providing inspection breaks.  It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter. 

 were notified that

this MOI will be forwarded to the District Office

and the District Veterinary Medical Specialist

(DVMS) in case additional follow-up is

recommended.   Respectfully, 

 Allen Harim Foods, LLC.

P-935 Harbeson, DE. 19951

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 410

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA091901

5807G

07JAN2020 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2125 hours while performing

Antemortem/GCP verification I observed a live

bird buried upside down and denatured in the

DOA bin that was approximately 3/4 full of DOAs. 

 was notified

of the observation of birds being handled in a way

that could result in discomfort, injury or death

while be handled in connection with slaughter. 

 stated that the responsible

establishment personnel would be removed from

handling DOAs. It is recommended that

establishment management review the Federal

Register on "Treatment of Live Poultry before

Slaughter", published September 2005 for FSIS

recommendations concerning treatment of live

poultry prior to slaughter was

notified that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. Respectfully, ,

 Allen Harim Foods, LLC. P-935 

Harbeson, DE. 19951

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 411

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA521201

0308G

08JAN2020 04C05 Poultry Good

Commercial

Practices

Open Ante-mortem check performed on lot 1.at about

5.45am  No concerns. Verified GCP which

followed regulations. Dumper and belts in good

condition, Birds were housed properly, humanely

handled; Birds appeared to be in good

health. DOA’s removed and denatured properly,

Stunning and Killing was effective, no loose bird in

live hang, live haul and holding sheds. From:        

         . Date:                  

01/08/2020 Subject:                             Poultry

Good Commercial Practice/ MOI Meeting Date.  

01/08/2020 Meeting Time    : 1.40 

Establishment: P 935 – Allen Harim Foods, LLC 

Comments:        MOI. (Good Commercial Practice) 

              To: . 

              CC .   This memorandum

of interview serves as written notification of

occurrence of one Cadaver found on USDA 

inspection stations 2 today January 08.2020   At

approximately 1345 hours. Inspector on

station two called me for Cadaver disposition

which was hanged by her for veterinary

disposition. Observed cadaver carcass with head

intact and no cut on the neck. The facial area was

cherry red and swollen; skin around the neck was

purple in color while the rest of the body of the

carcass was bright red in color. The 

was notified, and he did

observe the cadaver carcass. assured

me that he will be writing up the employee

responsible and make sure to correct and coach

to avoid the reoccurrence.   The agency

regulations do require that poultry must be

slaughtered in accordance to good commercial

practices in manner that will result in thorough

bleeding of carcass and ensure that breathing was

stopped prior to scalding, so that birds do not

drown or die other than slaughter. It is the agency

expectation that all Good Commercial Practices

be correctly and effectively implemented. The

(b) (6)(b) (6) (b) (6) (b) (4) (b) (4) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 412

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

copy of this Memorandum will be forwarded to

DVMS Raleigh district and Front-Line Supervisor

(FLS) in case additional follow up is

recommended. A copy will be placed in the

official USDA file. Please feel free to contact me

with any question or concern. Sincerely. 

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 413

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA592201

4417G

17JAN2020 04C05 Poultry Good

Commercial

Practices

Open At approximately 2200 hours while traveling

through Live Receiving area I observed, through

the door to live hang, a pile of DOAs on the

medium bird DOA belt.  Upon further

investigation, the pile of DOAs on the belt was so

high that the DOAs were falling to the floor. 

There was also a pile of DOAs on the

stainless-steel table at the end of the DOA belt. 

This pile of DOAs was so high that the they were

touching the DOA belt which is approximately

2 1⁄2 to 3 feet above the stainless-steel table

were observed to be

removing the DOAs from the belt and

stainless-steel table.  I began looking through the

DOAs to ensure there were no live birds in the pile

and found none.  I then noticed that there was a

pile of DOAs on the small bird stainless-steel DOA

table.  Upon investigation I observed 2 live birds

buried in the approximate 30 DOAs on the table.  I

then noticed an approximate 1 1⁄2 to 2 feet pile of

fecal, feathers and DOAs on the floor at the end of

the small bird live hang belt.  Upon investigation I

observed 2 live birds buried in the fecal and

feathers.  

was notified of the observation of birds being

handled in a way that could result in discomfort,

injury or death while being handled in connection

with slaughter.  explained that the

DOA belt had been broken since Tuesday,

1/14/20 and maintenance had told him that the

part to repair the belt had been ordered.

were notified of

the above-mentioned observations.  

stated that in the future, when there is a large

number of DOAs, Live Hang management will

notify other management in the establishment so

that additional personnel can be placed in live

(b) (6)

(b) (6)

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

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 414

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

hang to control the process.  The broken DOA belt

was repaired on Thursday, 1/16/20. It is

recommended that establishment management

review the Federal Register on “Treatment of Live

Poultry before Slaughter”, published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, 

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

19951

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 415

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA152201

4724G

24JAN2020 04C05 Poultry Good

Commercial

Practices

Open At approximately 2053 hours, while providing

inspection breaks, I was notified that the

inspector on station 2 had hung back 1 bird

for Veterinarian disposition. Upon arrival to

I observed a cadaver with head intact which was

red to purple in color, no cut to the neck, petechia

in the breast muscle and blood engorged viscera.  

At approximately 2125 hours, I performed Good

Commercial Practice verification by observing 200

carcasses enter the scalder, and 200 carcasses at

the kill blade. There were no live birds observed

entering the scalder and the back-up kill

performed a cut to the neck of all birds not cut by

the kill blade or that had received cuts to only one

side of the neck. 

were notified of the observation of birds

dying other than by slaughter.  stated

that a bird had been caught in the kill blade

causing the following birds not to receive a cut to

the neck.  The bird was removed from the kill

blade and there was no further observation of

birds dying other than by slaughter for the

remainder of the shift. It is recommended that

establishment management review the Federal

Register on "Treatment of Live Poultry before

Slaughter", published September 2005 for FSIS

recommendations concerning treatment of live

poultry prior to slaughter. was

notified that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended.   Respectfully, 

 Allen Harim Foods, LLC.

P-935 Harbeson, DE. 19951

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

(b) (6)

(b) (6) (b) (6)(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 416

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA462001

4528G

28JAN2020 04C05 Poultry Good

Commercial

Practices

Open At approximately 1444 hours, I was notified that

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

birds for Veterinarian disposition. Upon arrival to

 I observed 1 cadaver that had received a cut

through the head.  The neck was red to purple in

color, no cut to the neck, petechia in the breast

muscle and blood engorged viscera. I observed a

second cadaver that had received a cut to the skin

of the neck and both carotid arteries intact.  The

head and neck were red to purple in color,

petechia in the breast muscle and blood engorged

viscera

and 

were notified of birds dying other than by

slaughter.  stated that the

responsible employee would receive instruction

and retraining. At approximately 1533 hours, I

was notified that the inspector on station 2

had hung back a bird for Veterinarian disposition. 

Upon arrival to I observed a cadaver with

the skin of the neck mutilated and both carotid

arteries intact.  The head and neck were red to

purple in color, petechia in the breast muscle and

blood engorged viscera. At approximately 1539

hours, I performed Good Commercial Practice

(GCP) verification by observing carcasses enter the

scalder, and observed, on the small bird kill line, a

breathing live bird with no cut to the neck, eyes

blinking moving toward the scalder.  

 was notified, the kill

line stopped, and the back-up kill personnel cut

the neck of the live bird.  

 was notified of the live bird, he

stated that the responsible personnel would

receive disciplinary action and the kill line was

turned back on. I resumed GCP verification by

observing 300 hundred carcasses enter the scalder

and 200 carcasses at the kill blade. There were no

live birds observed entering the scalder and the

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

(b) (4) (b) (4) (b) (6) (b) (6)(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (4)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 417

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

birds not cut by the kill blade. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter. 

was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended.   

Respectfully, 

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

19951

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 418

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA072201

5530G

30JAN2020 04C05 Poultry Good

Commercial

Practices

Open At approximately 1420 hours, on 1/29/20, I was

notified that the inspectors on station 2

and station 3 each had hung back 1 bird for

Veterinarian disposition. Upon arrival to 

station 3 I observed 1 cadaver that had received a

cut through the head (beak area).  The neck was

red to purple in color, no cut to the neck, petechia

in the breast muscle and blood engorged viscera. I

observed, on station 2 the second cadaver

that had not received a cut to the neck. The head

and neck were red to purple in color, petechia in

the breast muscle and blood engorged viscera. 

 was

notified of birds dying other than by slaughter. 

stated that the responsible employee

was replaced by another back-up kill personnel. 

At approximately 1818 hours, I was notified that

the inspector on station 2 had hung back a

bird for Veterinarian disposition.  Upon arrival to

 I observed a cadaver with a cut to the skin

of the neck and both carotid arteries intact.  The

head and neck were red to purple in color,

petechia in the breast muscle and blood engorged

viscera. was notified of a

bird dying other than by slaughter.  

stated that the kill blade was adjusted. At

approximately 2137 hours, I was notified that the

inspector on station 3 had hug back a bird

for Veterinarian disposition.  Upon arrival to 

I observed a cadaver with a cut to the skin of

the neck and both carotid arteries intact.  The

head and neck were red to purple in color,

petechia in the breast muscle and blood engorged

viscera. was notified of a

bird dying other than by slaughter.  I performed

Good Commercial Practice (GCP) verification by

observing 200 hundred carcasses enter the scalder

and 200 carcasses at the kill blade. There were no

live birds observed entering the scalder and the

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

(b) (4) (b) (4) (b) (4) (b) (6) (b) (6) (b) (6) (b) (4) (b) (4) (b) (6) (b) (6) (b) (4) (b) (4) (b) (4) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 419

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

birds not cut by the kill blade. At approximately

2155 hours, I was notified that the inspector on

station 4 had hug back a bird for

Veterinarian disposition.  Upon arrival to I

observed a cadaver with no cut to the neck, the

head and neck were red to purple in color,

petechia in the breast muscle and blood engorged

viscera. was notified of a

bird dying other than by slaughter.  At

approximately 2228 hours, I was notified that the

inspector on station 4 had hug back a bird

for Veterinarian disposition.  Upon arrival to

I observed a cadaver with no cut to the neck,

the head and neck were red to purple in color,

petechia in the breast muscle and blood engorged

viscera. was notified of a

bird dying other than by slaughter.  I performed

Good Commercial Practice (GCP) verification by

observing 300 hundred carcasses enter the scalder

and 200 carcasses at the kill blade. There were no

live birds observed entering the scalder and the

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

birds not cut by the kill blade

 was notified of a bird dying other than by

slaughter.  stated that the kill blade

had been adjusted as high as possible.  When the

kill blade machine was relocated, the way it was

installed was not allowing the kill blade to be

adjusted high enough to cut the necks of the

smaller birds.  assured me that

appropriate adjustments would be made the kill

blade machine that would allow for the proper

adjustment to the blade and that the blade would

be replaced.  also stated that the

back-up kill personnel would receive re-training. 

On 1/30/20 I verified that the kill machine had

been adjusted and there were no reports of birds

dying other than by slaughter. It is

recommended that establishment management

review the Federal Register on "Treatment of Live

(b) (4) (b) (4) (b) (6) (b) (4) (b) (4) (b) (4) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 420

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

Poultry before Slaughter", published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter

was notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended.   

Respectfully, 

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

19951

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 421

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA530902

4018G

18FEB2020 04C05 Poultry Good

Commercial

Practices

Open From:                  . 

Date:                   02/18/2020 

Subject:                             Poultry Good

Commercial Practice/ MOI Meeting Date.  

02/18/2020 Meeting Time    : 10.20 am. 

Establishment: P 935 – Allen Harim Foods, LLC 

Comments:        MOI. (Good Commercial Practice) 

              To: . 

              CC .   This

memorandum of interview serves as written

notification of occurrence of one Cadaver found

on USDA station 3.   At approximately

1015 hours. Inspector on station three

called me for Cadaver disposition which was

hanged by her for veterinary disposition.

   Observed cadaver carcasses with head intact

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

red and swollen; skin around the neck was purple

in color while the rest of the body of the carcass

was bright red in color. The 

was notified, and he did

observe the cadaver carcasses. 

 assured me that he will be

writing up the employee responsible and make

sure to correct and coach to avoid reoccurrence. 

  I performed Good Commercial Practice (GCP)

verification by observing 200 hundred carcasses

enter the scalder and 200 carcasses at the kill

blade. There were no live birds observed entering

the scalder and the back-up kill performed a cut

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

The agency regulations do require that poultry

must be slaughtered in accordance to good

commercial practices in manner that will result in

thorough bleeding of carcass and ensure that

breathing was stopped prior to scalding, so that

birds do not drown or die other than slaughter. It

is the agency expectation that all Good

Commercial Practices be correctly and effectively

implemented. The copy of this Memorandum

(b) (6) (b) (4) (b) (4) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 422

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

will be forwarded to DVMS Raleigh district and

Front-Line Supervisor (FLS) in case additional

follow up is recommended. A copy will be placed

in the official USDA file. Please feel free to

contact me with any question or concern. 

Sincerely. 

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 423

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

P935 Allen Harim Foods, LLC. YXA412102

4220G

20FEB2020 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1730 hours, while traveling to

line 3 to provide inspection breaks, I observed 2

cadavers hug back for Veterinarian disposition on

station 2 and 1 cadaver on station 4.  One

cadaver, on station 2, with no cut to the neck, the

head and neck was red to purple in color,

petechia in the breast muscle and blood engorged

viscera.  The second cadaver, on station 2, had a

cut to the skin of the neck and the 2 carotid

arteries were fully intact.   The cadaver at station

4 had no cut to the neck, the head and neck was

red to purple in color, petechia in the breast

muscle and blood engorged viscera.   

 was notified of a

bird dying other than by slaughter. At

approximately 1743, while providing inspection

breaks, I was notified of a cadaver hug back for

Veterinarian disposition on station 4.  After

breaks were completed, I observed the cadaver to

have no cut to the neck, the head and neck was

red to purple in color, petechia in the breast

muscle and blood engorged viscera.  I performed

Good Commercial Practice (GCP) verification by

observing 200 hundred carcasses enter the scalder

and 200 carcasses at the kill blade. There were no

live birds observed entering the scalder and the

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

birds not cut by the kill blade.  

 was notified of birds

dying other than by slaughter

stated that a more experience back-up kill person

was placed on the line. It is recommended that

establishment management review the Federal

Register on "Treatment of Live Poultry before

Slaughter", published September 2005 for FSIS

recommendations concerning treatment of live

poultry prior to slaughter.  was

notified that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

(b) (6) (b) (6) (b) (4) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 424

EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

recommended.   Respectfully, 

 Allen Harim Foods, LLC.

P-935 Harbeson, DE. 19951

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