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50 M10038 Scotts Hook & Cleaver Inc. RSH101303

1422G

2018-03-22 04C02 Livestock

Humane

Handling

Finalized On 3/22/2018 at approximately 0830 hour, while

verifying humane slaughter regulatory

requirements, I observed some livestock handling

practices of concern.  I witnessed establishment

personnel bring an injured beef heifer, which had

passed ante-mortem inspection, to the stun

restraint box holding pen (the pen animals are

held in before bringing them onto the slaughter

floor for stunning).  Immediately after bringing the

injured heifer to the stun box holding pen,

establishment personnel brought another beef

animal into the stun box holding pen.  By this

time the injured heifer had laid down.

Establishment personnel let the injured heifer rest

for 5 to 10 minutes, but it remained lying down. 

Establishment personnel then removed the other

beef animal from the stun box holding pen, so

they could work on getting the recumbent beef

heifer on its feet.  To accomplish this personnel

prodded this heifer with a battery powered

electric prod three times, in the rump area.  The

heifer tried to rise, but was unable to stand. 

Establishment personnel then repositioned the

heifer by rolling her slightly to get the heifers legs

underneath her.  The heifer then tried again to

stand after a light hand slap on the rump from an

employee.  The heifer creeped forward, but still

could not stand.  At this point, I condemned the

heifer as non-ambulatory.  In all this animal

handling, there appeared to be a general lack of

careful consideration of the circumstances before

establishment personnel proceeded with moving

this heifer to the stunning area or when

establishment personnel proceeded to get the

heifer to stand (for example by ensuring extra

good footing).
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Code TaskName Status MOI Agenda

80 M17776 Trenton Halal Packing Company BBE251002

5507G

2018-02-07 04C02 Livestock

Humane

Handling

Open During the 30-day verification visit for the

Humane Handling NOIE at Trenton Halal, 

 and I observed an egregious

noncompliance, the details and determinations of

which describes in the following

statement; During the 30-day Verification Visit

for their humane handling NOIE, I, 

observed the following egregious

humane handling noncompliance. At

approximately 9:15 am, while observing animal

handling in the pens, I observed an employee pick

a goat up off the ground by its fur along the back

of its lumbar spine and throw it into the pen

behind him. The goat landed on its side and slid

into another goat already in the pen. I

immediately stopped the employees from sorting

additional animals. placed US

Reject/Retain tag #B36924979 on the

chute/hanging area. The plant has a documented

animal handling plan, but their recent

noncompliance history and lack of

implementation does not qualify it as being

robust.

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

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

85 M17980 Pilgrim's Pride Corporation ZBB261201

1531G

2018-01-31 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1215 hours after giving relief

breaks, I was notified by 

 that he observed several loose birds

around the live hang dock.  I followed up with his

concerns and at approximately 1244 hours while

performing a Good Commercial Practices (GCP)

task in the Live Hang Area, I observed the

following situation which resulted in

mistreatment of poultry:  There were five (5) loose

birds on the cage unloading system that were

wedged between the cages as they were coming

down to the cage unloader.  One of the bird’s legs

was jammed in between a cage and the unloading

conveyor system and another bird had its wing

stuck as the cages continued to be loaded and

moving forward.  I immediately notified 

 and 

 of my observations.  I

notified that I wanted all cage loading

by the forklift operator to be stopped until the

birds were safely removed, otherwise the birds

were at risk of being crushed.   After I had the

cage loading stopped, all the loose birds were

removed.  Once they were removed cage loading

was allowed to proceed.  While watching the

unloading process at the live hang belt, I observed

a few birds that were getting hung up on the

transfer belt at the cage dumper.  It was also

observed that there was one (1) dead bird (cause

of death undetermined).  The birds were getting

hung up at the junction of two transfer belts.  I

also showed my observations.  She

had an employee try to remove the one dead bird,

but he was unsuccessful.  While observing,  I

notified and showed an area maintenance

technician of the problem at the junction of the

two transfer belts.     This MOI serves to remind

the establishment that the PPIA (Poultry Products

Inspection Act) and Agency regulation require that

poultry are handled in a manner that is consistent

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

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

with Good Commercial Practices.  I notified 

 that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended. 

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

85 M17980 Pilgrim's Pride Corporation ZBB430403

2307G

2018-03-07 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0507 hours while observing

operations in the Kill Room, I observed that there

was not very many birds on the kill line so I

proceeded to the Live Hang area and observed the

following situation which resulted in

mistreatment of poultry:  There were too

numerous to count of dead on arrival (DOA) birds

piled behind the live hangers.  The DOA sorting

process was not being addressed and there were

several live birds that were piled under and

between the DOA birds.  Some of the live birds

were being stepped on so the live hangers could

have access to the line to hang.  Since shift change

had just occurred there was no supervisor in the

immediate area at the time of my observation.  I

immediately asked 

 for the live hanging process to be

stopped until all DOAs could be properly sorted

and disposed of in the DOA bin and the live birds

buried in the pile could be removed and placed on

the live hang belt.  After the live hang operation

was stopped for several minutes, I showed 

 my

observations.  She immediately called for 

.  All the

live hangers began clearing the area and disposing

of the DOAs and the getting the live birds from off

the floor.   At approximately 0520 hours, I allowed

the live hang process to resume.  Concerns with

the DOA process and handling it in a timely

manner to prevent live birds from being buried

was previously discussed with establishment

management during the weekly meeting

documented on MOI # ZBB4015023527G dated

2/27/2018. This MOI serves to remind the

establishment that the Poultry Products

Inspection Act (PPIA) and Agency regulations

require that poultry are handled in a manner that

is consistent with Good Commercial Practices. 

The establishment was notified that this MOI will

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 6

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Code TaskName Status MOI Agenda

be forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

(b) (6)
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Task

Code TaskName Status MOI Agenda

25 M17D Smithfield Packaged Meats Corp. WLJ09220

12715G

2018-01-15 04C02 Livestock

Humane

Handling

Finalized I, , am documenting this MOI in 

 absence. Below are observations

of late in the shift starting

on 1/13/2018 of the describe incident. HATS

Category VIII Stunning Effectiveness On

01/14/2018 at 0255 hours (late in the shift

starting on 01/13/2018) while performing the

humane handling verification task in the barns, I

observed the following: I was walking past the

cripple pens.  

and a barn employee were performing captive

bolt stunning on a hog in the north cripple pen.

 From where I was standing, I could not see the

hog.  I heard a captive bolt shot followed by a

quick vocalization from the hog.  I peered over the

wall and observed the hog "dog sitting" (sitting on

its hind quarters and standing on its

forequarters) and breathing with chest

movement.  The employees instantly noticed the

hog was still sensible.  An additional, loaded

captive bolt gun was within reach and was used to

take a second shot which rendered the hog

insensible immediately.  I followed the

unconscious hog all the way through the process

until the stick pen, and it remained unconscious.  

I informed that I

would be documenting this incident. On

01/05/2018, a noncompliance report,

WLJ2217012905N/1, was issued for an ineffective

stun with a captive bolt gun.  9CFR 313.15(a)(1)

requires that an animal be rendered immediately

unconscious through the application of a captive

bolt device with a minimum of excitement and

discomfort.  On 1/16/17, I, ,

verified that the incident was noted on the

Fatigue Pen Monitoring Form for second shift

1/13/18.

(b) (6)

(b) (6)

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

25 M17D Smithfield Packaged Meats Corp. WLJ34070

42102G

2018-04-02 04C02 Livestock

Humane

Handling

Finalized HATS Category VI - Electric Prod/Alternative

Object Use This MOI is to document a

conversation between myself and 

 regarding an observation I

had in the west push gate system on

03/31/2018 at 0906 hours. While observing

humane handling activities in the room, I

observed concerning behavior from two company

employees.  In the west alleyway, it

appeared that a group of hogs was backed up

against the push gate as the push gate was in the

middle of the alleyway but was not moving

forward.  Two employees were standing outside

the alleyway, just in front of the push gate.  I

observed these two employees using their rattle

paddles excessively.  Both were repeatedly picking

up the rattle paddles over their head and coming

down very quickly with excessive force.  There

was vocalizing from the group of hogs in the west

alleyway while they were using the

paddles.  I could not see any of the hogs as they

were hidden behind the alleyway wall, so I cannot

definitively say that the employees were striking

the hogs. I spoke to and told him that

I was concerned about my observations.  I told

him that I couldn’t see if they were striking the

hogs.  If they were, the rattle paddles were being

used excessively.  I also told him that he should

ensure his employees are not using rattle paddles

with that much force on the hogs.  I said that

there is a regulation that requires hogs to be

moved with “minimal excitement”, and such

rattle paddle use on a hog would be a violation of

that regulation.  As a corrective action, 

said in the future he could “back up” the push

gate if a group of hogs is stopping the gate’s

forward progress, which would create more room

to help the group of hogs disperse.

(b) (6)

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

Code TaskName Status MOI Agenda

80 M19290 Working H Meats, LLC NAW45110

30808G

2018-03-08 04C02 Livestock

Humane

Handling

Open Today, March 8, 2018, at approximately 1020

hours, I verbally notified Mr. Grant Hardesty,

Establishment Manager, of my decision to

suspend slaughter at Establishment 19290.  I

advised Mr. Hardesty that I would be contacting

, and the Raleigh

District Office about my decision.  I based my

decision to suspend inspection at the

establishment on the following: At

approximately 0945 hours, an Angus bull,

weighing 1800 pounds according to the owner,

was loaded into the knock box.  Mr. Grant

Hardesty attempted to stun the bull using a .22

Magnum rifle.  The bull remained calm and

standing.  The establishment did not have a larger

caliber rifle available.  Another plant employee,

who lives nearby, went to her home and returned

with a .223 rifle.  Mr. Hardesty attempted to stun

the bull a second time, and I confirmed with

establishment employees that the second shot

produced immediate unconsciousness with the

animal dropping to the floor and the tongue

hanging out.  Mr. Hardesty chose to give a

security knock with the .223 rifle.  On

examination of the skinned head, there were two

bullet holes in the skull.  I then examined the skin

to determine if all three rifle shots made contact

with the bull.  I found three bullet holes through

the skin, indicating that all three rifle shots did

make contact with the bull.  At this point (1020

hours), I notified the establishment that I was

taking a regulatory control action and slaughter

was suspended.  I further advised the

establishment that I was contacting the Frontline

Supervisor and the Raleigh District Office to

discuss the suspension.  After speaking with the

Raleigh District office, a tag was placed on the

knock box at approximately 1040 hours, US Reject

Tag #B43223417. Establishment 19290 does not

operate under a robust systematic approach to

(b) (6)
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Code TaskName Status MOI Agenda

humane handling.  Establishment 19290 had a

recent humane handling NR for an ineffective stun

in a sow on February 23, 2018.
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50 M20855 Chenoa Locker, Inc. SSH111102

5216G

2018-02-16 04C02 Livestock

Humane

Handling

Finalized Discussed with owner about methods of Humane

Handling of animals that may become wedged in

the runways during slaughter and the use of

"Safety Shots" after the animal has been

successfully stunned. Disposition of Cattle that

Become Entrapped in Livestock Handling Areas

after Receiving Ante-mortem InspectionPublished

05/26/2009 12:46 PM   |     Updated

08/14/2017 06:23 AM What happens to a bovine

animal that, after it has received ante-mortem

inspection, becomes entrapped (e.g., stuck/

wedged/ trapped) in the livestock handling areas

(including pens, drive alleys, chutes, and

restrainers), and the establishment cannot

humanely extract it from its entrapment?

Slaughter establishments need to design and

provide adequate livestock facilities and employ

personnel trained in the humane handling of

livestock. This obligation includes the need to

carefully plan how they will handle livestock

whose physical features, size, or conformation

(e.g., longhorn cattle; wide-bodied or short-legged

cattle) suggest that special handling will be

necessary. It should be a rare occurrence that

livestock become stuck in a chute or other area if

the establishment has assessed how it will handle

such animals to facilitate their movement. The

Agency has several concerns with this situation

and possible Agency actions follow: First, the

Agency is concerned with the humane handling of

the cattle that become entrapped and would

question why such animals would become

entrapped (e.g., stuck, wedged) in the

establishment's facilities. Under 9 CFR 313.1 and

313.2, the establishment is to provide and

maintain adequate facilities for the handling of all

cattle that are accepted for slaughter by the

establishment.Thus, should the Agency determine

that there are facility deficiencies or mishandling

practices, under 9 CFR 313.1 and 313.2,
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noncompliance exists, and appropriate action will

follow. Second, in the rare and isolated instance

that an animal does get entrapped, and it cannot

be freed in a humane manner, the Agency will

expect the establishment to notify IPP to observe

the humane stunning and removal of the animal.

Otherwise, if inspection personnel find dead

animals in alleyways, chutes, or pens, these

animals will be considered to have died other

than by slaughter and will be US Condemned. 

Third, IPP examination of these entrapped cattle

will determine what action will be taken: Cattle

that are entrapped and found sitting or lying

down and cannot rise and ambulate will be

condemned as non-ambulatory disabled cattle.

The PHV makes the disposition on

non-ambulatory disabled cattle. They will be

tagged as US Condemned and properly disposed

of. However, the establishment may choose to not

wait for a PHV disposition and proceed to

euthanize the anima. IPP will condemn this

carcass.Cattle that are entrapped and still

standing will need to be evaluated to determine

whether they are non-ambulatory disabled. The

PHV makes the disposition on non-ambulatory

disabled cattle. If he/she determines that the

animal is non-ambulatory disabled, then it will be

tagged as US Condemned and properly disposed

of. However, the establishment may choose to not

wait for a PHV disposition and proceed to

euthanize the animal. IPP will then condemn this

carcass. Ambulatory cattle that are driven to a

restrainer with a center track conveyor belt

(which suspends the animal on the conveyor belt

once it moves into the restrainer) and, when

entering the restrainer become entrapped

because of incorrect positioning (e.g., all four legs

on one side of the belt or the front legs are

suspended and the animals weight is on its chest

and rear legs), are to be humanely euthanized so
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that they are not injured as they continue through

the restrainer. These cattle do not need to be US

Condemned and may be slaughtered for human

consumption. Finally, establishments should be

aware of incoming cattle that may require special

handling and slaughter methods if the cattle are

to avoid becoming entrapped in the facilities. For

example, cattle may need to be stunned before

they pass through the chutes or drive alleys, in a

place other than in the restrainer or knock-box.

Additionally, the Agency is aware that some cattle

breeds (e.g., Longhorns, Watusis) are prevented

from moving through slaughter facilities by the

size of their horns and are typically stunned in

outside pens and then moved inside for

processing. (This type of situation should be

discussed with IPP before implementation.) As

long as these animals can be handled and

slaughtered in a humane manner, the new rule on

non-ambulatory disabled cattle has no affect on

this practice. Also, some establishments may

choose to reject cattle for slaughter and then ship

them to another destination.FSIS Directive

6100.1 Ante-Mortem Livestock

Inspection - Revision 1 Facilitator Guide for

Situation-Based Humane Handling

Training Module Two – Stunning and

Post-Stunning Situations Facilitator

Handout – Page 2 Situation-Based Humane

Training11-14-11   Step 4 - Read each situation

and lead inspection personnel to an

understanding of a supportable decision.   Note:

this training is not intended to cover all possible

“what if” situations. It is more important to stress

the thought process from the objectives. It should

take approximately 45 minutes to discuss the

situations. Allow 15 minutes to complete the

exam at the end. Situations 1) Inspectors at the

cattle head inspection station notice that some

heads have 2 or 3 “knock holes”. They notify
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offline IPP of the multiple knock holes. The offline

inspector immediately proceeds to the stunning

area and observes that establishment personnel

consistently produce insensibility with one shot of

the captive bolt gun. The establishment has a

good history of properly stunning animals and

sometimes the employee doing the knocking

administers additional “security” knocks to ensure

animals remain insensible.   Does this scenario

represent noncompliance? No, there is no

noncompliance as described if the establishment

is consistently producing immediate

unconsciousness with a single blow. The

establishment may be using additional “security”

or “safety” knocks to ensure animals do not

return to sensibility. Note: make sure participants

understand that “security knocks” are sometimes

used especially on large bulls and that the knocks

may be administered on the forehead or behind

the poll to the back of the head. The key point is

that the first shot consistently renders the animals

insensible. Additional knocks are used to ensure

there is no return to sensibility.   Is it an

egregious situation? Not applicable What action

should be taken by inspection personnel? None
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50 M20856 Eureka Locker, Inc. GGG58080

51701G

2018-05-01 04C02 Livestock

Humane

Handling

Finalized The below email was sent asking about off-hour

animal drop-off: Some of our slaughter

establishments have their pens available for drop

off overnight. FSIS would like us to be aware of

these situations and be observant that animals

dropped off during the non-inspection hours are

treated the same as the animals dropped off when

we are on site inspecting.  Observing overnight

drop offs are referred to as ‘odd hour inspections’.

As a current practice, FSIS would like a minimum

of one (1) Odd Hour Inspection per month at cull

cattle/veal establishments and one (1) Odd Hour

Inspection per quarter at all other establishments.

So, we need some information:  Do the

establishments have cull or veal animals and do

they allow overnight or weekend drop offs?  

Establishment Cull or Veal? (Never, rarely, or

commonly) Overnight drop-offs? Comments 

Chenoa Locker, Inc       Forrest Meats       

Eureka Locker       Meat Science Laboratory, Univ.

of Il
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50 M2130 Cooper Foods HEF182101

1004G

2018-01-04 04C05 Poultry Good

Commercial

Practices

Finalized On January 2rd at approximately 11:45 PM, I,

, while performing

antemortem inspection outside in the cooling

sheds, observed a topmost rear trailer cage that

was missing the door on the front of the cage,

leaving an open space for turkeys to fall through.

There was at least one live turkey visibly within

the open cage. I also observed two live turkeys

that were loose within close proximity to the

trailer. The topmost trailer cages are not

reachable without the aid of steps or a ladder, and

pose a significant distance for a turkey to fall onto

the concrete floor of the cooling sheds, which

may result in injury to live turkeys.  I informed

the employees in the live hang area of the open

trailer cage and the loose turkeys, and spoke with

, who said that the loose turkeys

will be caught according to the relevant handling

policy, and that maintenance will be attaching a

temporary cage door to the open trailer cage until

the turkeys are stunned.

(b) (6) (b) (6)
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50 M2130 Cooper Foods HEF530004

1304G

2018-04-04 04C05 Poultry Good

Commercial

Practices

Finalized At 4:15 AM on 4/03/2018 while returning from

checking the trailers in the cooling shed, I was

passing through the live hang area where stunned

turkeys are shackled on a conveyor belt

(approximately 3-4 feet in height from the floor),

and observed an employee push a stun failure

(fully conscious turkey) off of the belt, causing the

turkey to fall on the concrete floor on the

opposite side of the belt from the employee,

where another conscious turkey was also sitting

on the floor. The potential for injury of conscious

turkeys to occur as a direct result of this handling

method is not insignificant. I spoke with 

about what I observed, and she said she

would speak with the employees in the live hang

area. An SOP for proper handling of conscious

birds was to have been newly implemented in

December 2017. This same improper handling

method has been observed and documented

previously in the following MOIs: (11/01/2017)

MOI # HEF1804111001G (11/20/2017) MOI#

HEF5520114920G (11/28/2017) MOI#

HEF5820111429G (12/14/2017) MOI#

HEF3203122815G

50 M2130 Cooper Foods HEF550305

0515G

2018-05-15 04C05 Poultry Good

Commercial

Practices

Finalized On May 15th 2018 at approximately 3:45 AM

while performing antemortem inspection in the

cooling sheds, I, , observed a

trailer with a set of cages that was unsecured by

the metal bar that normally prevents the cage

doors from swinging outwards. Live turkeys were

visible within all five cages that were affected, and

at least one live turkey had fallen from the cages

onto the concrete floor of the cooling shed. The

upper trailer cages are not reachable without the

aid of steps or a ladder, and pose a significant

distance for turkeys to fall, which may result in

injury to live turkeys. I informed employees in the

live hang area of the unsecured cages and the

loose turkey.

(b) (6)

(b) (6)
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35 M2316 Whisnant Meat Packing LLC FSF270703

2807G

2018-03-07 04C02 Livestock

Humane

Handling

Finalized On 2-28-18, eighty one head of market hogs had

been in a holding pen on Est. 2316 premises since

2-14-18 and were being fed ground corn once a

day.  At 12:15 pm on 2-28-18, they were fed 100

lbs of ground corn in three open plastic tubs. This

computes to 1.2 lbs of feed/head/day.  In a

weekly meeting with the establishment on

2-29-18, addressed this and other

humane handling concerns (trailer/pen densities,

bedding, sorting boards, ramps).  Documented

support that the amount fed is a daily

maintenance amount, was requested at that

time.  The next day the 81 hogs were fed 150 lbs

of ground corn and on 3-2-18 forty of the

eighty-one were slaughtered (averaging 220 lbs

dressed – eviscerated, head removed, and

skinned).  The remaining 41 hogs were fed 100 lbs

of ground corn daily over the weekend.       On

3-5-18 plant manager Brett Powell offered an

e-mail reply from Temple Grandin that the

amount of feed was adequate but no actual

amount was stated in the document.   This is not

adequate support that 1.2 lbs of ground corn

provides a daily maintenance for that size hog.    

The establishment needs to be aware of, and feed,

a maintenance amount for market hogs. Feed

containers that cannot turn over and result in

spilled feed should also be considered.  The longer

the hogs are on the premises, the more important

these issues become for the humane treatment of

the animals.

(b) (6)
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50 M244I Tyson Fresh Meats, Inc GEH10190

25022G

2018-02-22 04C02 Livestock

Humane

Handling

Finalized At the end of shift, the humane handling liaison

said that the south was not functioning

and they would be sending hogs back outside. The

liaison spoke with the four remaining employees

about the situation and requested that they open

the alley gates to give the hogs more room to

maneuver. The gates between pens 4 and 5 were

opened and hogs were sent back down the ramp

to the section between pens 4 and 5 in the drive

alley. Another group of hogs was sent back from

inside and bunched up at the gate between pen 3

and 4. The team members were continue to guide

more hogs outside as the team member in the

middle exited the drive alley and started to get

the hogs into the door for the north This

caused the hogs to move in a circle.  In the middle

of that circle, a hog went down and was

determined to have split out its back legs. The

downer hog was moved out of the alley and

captive bolt stunned. The situation may have

been preventable. The management of space and

the stress levels in the hogs is a very important

issue. It is understandable that the team

members may want to move the hogs faster,

because they want to go home. It is never

appropriate to increase speed at the expense of

humane handling.

(b) (4) (b) (4)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 20

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25 M244P Tyson Fresh Meats, Inc FJJ340901

2019G

2018-01-19 04C02 Livestock

Humane

Handling

Finalized At approximately 1500 hrs, when the outdoor

temperature was 6 degrees Fahrenheit, feeling

like 10 below zero according to the Weather

Channel app, a truck (Kenworth, BL 1994) was

seen in the unloading dock with less than 90% of

it's slats covered. The same thing had happened

the day before and I made the establishment

aware of the situation both times, speaking to

,

and .  The producers

were notified by the establishment, and the truck

drivers were both made aware of the violation of

the Transport Quality Assurance requirement

which this establishment adopts and

requires 90-95% closure of slats when it is below

10 degrees Fahrenheit.

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 21

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Code TaskName Status MOI Agenda

25 M244W Tyson Fresh Meats, Inc. BTD480102

2008G

2018-02-08 04C02 Livestock

Humane

Handling

Finalized At about 16:55 hours on Monday 02/05/18, I

 was performing

ante-mortem inspection at Establishment

#244W.  I observed the team members who drive

for kill putting hogs in the West drive alley and

filling the spaces between gates with hogs and

leaving little extra room in these spaces.  The

team members used noise by banging their rattle

cans on walls and gates to get a group of hogs on

one side of a gate to move North towards the CO2

room. The hogs on the other side of the gate (to

the South) also moved away from the noise and

piled up on the closed gate to the South of the

group, with four or so hogs completely on top of

other hogs, feet and all.  The was a lot of

struggling and squealing going on in the Southern

group of hogs. 

later told me he had, as a preventive

measure, instructed his animal handlers to move

smaller groups of 30 or so hogs at a time. At

about 20:34 hours on Wednesday 02/07/18, I

observed a team member moving hogs in pen #6. 

A group of 60 to 80 hogs had been moved West of

the center gate and the gate was closed.  When

the team member tried to move some of these

hogs to the West drive alley, he was banging his

rattle can on the wall and then climbed over the

wall and about half of the hogs moved West and

about half moved East towards the closed

mid-gate.  The hogs piled up against the closed

gate with a marked degree of struggling and

squealing and there were six or more hogs which

had partially jumped up with their front feet on

the backs of other hogs. Animals are to be moved

with a minimum of excitement and discomfort to

the animals according to 9 CFR 313.2. 

Furthermore, 9 CFR 313.5(a)(2) explains "delivery

of calm animals to the anesthesia chamber is

essential since the induction, or early phase, of

anesthesia is less violent with docile animals." 

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 22

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FSIS & Plant weekly meeting notes bear

testament to similar issues being discussed in the

past. 01/26/18 B-shift: "hogs should be moved at

a walking pace" and "Hog pile-ups should be a

clue to stop rattling and allow pile-up to settle."

11/30/17 A-shift: "Saturday hogs were observed

piling on top of each other..." 11/30/17 B-shift:

"Hog drivers need to move hogs with minimal

excitement." 08/31/17 B-shift: "[team members]

...trying to move too many [hogs] at one time

causing the hogs to pile and squeal..." 05/04/17

B-shift: "Hogs piling up in the drive alley."
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 23

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25 M244W Tyson Fresh Meats, Inc. BTD331204

4106G

2018-04-06 04C02 Livestock

Humane

Handling

Finalized At about 22:30 hours on Thursday 04/05/18, I

 was performing

ante-mortem inspection at Establishment #244W.

I observed the procurement team members who

drive hogs from the scale through the tattoo area

to the pens.  The team members used noise by

banging their rattle cans on walls and gates and a

black flag as a visible aid to get a group of hogs on

one side of a gate to move north towards the

tattoo chutes. The hogs resisted moving through

the chutes and circled and piled near the last

closed gate before the chutes.  One hog climbed

over the others and jumped through the closed

gate to get away from the noise and scrambling.

The animal slid to the ground but got up and

moved away without any signs of injury.  The

struggling and squealing continued for a few

moments longer until a few hogs at a time moved

through the tattoo chutes. Animals are to be

moved with a minimum of excitement and

discomfort to the animals according to 9 CFR

313.2.  Furthermore, implements employed to

drive animals are to be used as little as possible to

minimize excitement and injury.  FSIS & Plant

weekly meeting notes bear testament to similar

issues being discussed in the past. 1. 02/07/18

B-shift: "hogs piled up against the closed gate

with a marked degree of struggling and squealing

and there were six or more hogs which had

partially jumped up with their front feet on the

backs of other hogs 2. 01/26/18 B-shift: "hogs

should be moved at a walking pace" and "Hog

pile-ups should be a clue to stop rattling and

allow pile-up to settle." 3. 11/30/17 A-shift:

"Saturday hogs were observed piling on top of

each other..." 4. 11/30/17 B-shift: "Hog drivers

need to move hogs with minimal excitement." 5.

08/31/17 B-shift: "[team members] ...trying to

move too many [hogs] at one time causing the

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 24

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Code TaskName Status MOI Agenda

hogs to pile and squeal..." 6. 05/04/17 B-shift:

"Hogs piling up in the drive alley."
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 25

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Code TaskName Status MOI Agenda

25 M244W Tyson Fresh Meats, Inc. BTD140705

1315G

2018-05-15 04C02 Livestock

Humane

Handling

Finalized On May 14, 2018 in the barn at Establishment

244W at approximately 10:00 I, 

, observed the following incident:  I was

near the west drive alley observing prod usage

(HATS Category VI), when I saw a production

supervisor heading quickly toward the CO2

stunning area; I followed him to the loading area

of the South   It was immediately apparent

that the situation was chaotic and not likely to be

quickly resolved, so I started my stopwatch.   At

that point, there were 3 hogs down over the

gondola threshold and facing into gondola. 

Another supervisor was standing near the gondola

entrance holding the outer door up with his

hands.  Soon thereafter, the post that is used to

ensure the outer gate doesn’t close by accident

was wedged into place to hold the door open. 

One hog was captive bolt euthanized and

removed from the area, and alert/ambulatory

hogs were directed out of the gondola with flags. 

After 5min 15sec there were two hogs down and

slowly paddling over the threshold, and, within

the gondola, I could see one alert hog with its

head up laying over another hog, and two gasping

and recumbent on the gondola floor.  Team

members used flags to try to rouse the hogs, but

it was 9min 15sec before one of the hogs over the

threshold stumbled its front end out of 

and it was promptly euthanized via captive bolt.  

The other hog moved enough that it was entirely

in the .  The gate closed with three hogs in

the , alive but recumbent and laboriously

breathing.  

), two 

 and and two

 and ) were all

present by this point. I stopped my watch at

10min 15sec when the gate closed, and I do not

know how long the incident was in progress

before I came upon it. Per 9CFR313.5 (b)(3),

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

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

(b) (6)

(b) (4) (b) (4) (b) (4) (b) (4)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 26

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regarding CO2 stunning:  “gas concentration shall

be maintained uniform so that the degree of

anesthesia in exposed animals will be constant.” It

is inappropriate for hogs to have prolonged

exposure to uneven or sublethal concentration of

CO2 near the entrance of the This

vulnerability of hogs becoming non-ambulatory

near the entrance to the was identified and

has been brought up multiple times since the

 were installed in 2015.

(b) (4) (b) (4) (b) (4)
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Code TaskName Status MOI Agenda

25 M248B Butterfield Foods Company GXN19160

23523G

2018-02-23 04C05 Poultry Good

Commercial

Practices

Finalized On 2/21/18, I performed ante-mortem inspection

on truck 12 for Lot 3 at approximately 1120

hours.  I observed that approximately 50% of the

hens on the truck were dead and the carcasses

were frozen solid.  The dead, frozen birds were

focused on the bottom half of the truck (bottom

four rows of cages).  Evaluation of the rest of the

live birds noted no overt signs of disease, but

many of the birds were not well feathered and on

the thinner side.  As the live birds on the upper

half of the truck appeared cold, but healthy, I

ante-mortem passed the lot.  The establishment

appeared to being doing a good job ensuring the

frozen birds were not entering the facility, to

prevent adulterated product; this was achieved by

hangers sorting out DOAs from live birds during

the hanging process and directing the DOAs to the

white, inedible barrels below and hanging live

birds for slaughter.  However, the concern is with

the number of birds frozen upon arrival at the

facility and while being held at the facility prior to

slaughter. This issue was discussed with Mr.

Juan Cervantes (Plant Manager) at approximately

1130 hours 2/21/18, as I observed approximately

half a trailer of frozen DOA birds presented for

ante-mortem inspection.  I asked Mr. Cervantes

where Lot 3 birds were from and when they

arrived at the establishment; he stated they were

transported approximately 2 hours and arrived

the day before at approximately 1300 hours (on

2/20/18).  The slaughter of Lot 3 started on

2/21/18, at approximately 1150 hours and ended

at approximately 1630 hours.  Thus, the birds

from Lot 3 were held on establishment premise

for approximately 22 to 28 hours prior to being

slaughtered; the temperature on the morning of

2/21/18 was in the single digits, (approximately

2F) and had risen to the teens (approximately 18

degrees) in the afternoon (Fahrenheit). A weather

archive of average high/low temperatures in for
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 28

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Code TaskName Status MOI Agenda

these dates in Butterfield, MN, can be found at

www.accuweather.com At approximately 1230

hours, I observed the rest of Lot 3 trucks in the

holding shed (Trucks 13, 19, and 15; a total of 4

trucks for Lot 3). While being held at the

establishment prior to slaughter, the trailers of

birds were kept paneled in a 3-sided

non-temperature controlled building. Trucks 13,

19, and 15 were all completely paneled with

every fourth panel pulled up at the top

approximately 8 inches to allow for ventilation.

 At this time I could not visualize any of the birds. 

As the trucks entered the hanging room, I

observed each one as it was unpaneled.  Although

these trucks did not exhibit the excessive

percentage of dead, frozen birds as truck 12, there

were consistently dead, frozen birds in the bottom

1 to 2 rows of each battery on every truck in this

lot.  Evaluation of the health status of the live

birds on these trucks was consistent with truck

12, and passed for slaughter.  I observed excessive

DOA carcasses piled up in the hang room

throughout the live hang process of Lot 3 and did

not observe any live birds in the inedible white

barrels/floor. All DOAs were denatured and

rendered per regulatory requirements. The issue

was further discussed with Mr. Cervantes at

approximately 1600 hours on 2/21/18.  He asked

what the health status of the birds were on

inspection, and I reported a high number of

condemn rates due to septicemia/toxemia

(approximately 7.5% due to all condemnable

conditions except contamination and plant

rejects, calculated on 2/22/18).  I also pointed out

that the cages are slatted, as I observed the

majority of egg white/yolk and fecal/urinary

excrement accumulating on the bottom caged

birds which also contributes to the freezing

process.  I discussed that the birds were on the

thinner side and not well feathered, but I was also
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 29

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Code TaskName Status MOI Agenda

concerned that they had been in very cold

temperatures on site for over 24 hours prior to

slaughter.  It was discussed that multiple factors

may have contributed to these birds in particular

being more affected by the cold, but the

percentage of DOAs in Lot 3 was concerning.  Mr.

Cervantes stated that they are going to aim for

loading trucks with birds or more to help

maintain heat of the lot during cold conditions, as

he had noted from his records that trucks with

fewer birds than that had increased DOA

percentages.  Mr. Cervantes had recorded the

total number of birds on truck 12 from Lot 3 from

the daily kill schedule which was determined to

be approximately birds.  He also stated they

were going to monitor each truck when they

arrive on premise to assess the status of the birds

going forward.  )

discussed in the weekly meeting on 2/22/18 that

the trucking company was also contacted by plant

management to discuss the issue regarding Lot 3

DOA numbers slaughtered on 2/21/18.    After

reviewing the daily totals on 2/22/18, the

establishment reported 9,750 DOA birds out of a

total count of birds (approximately

DOA rate).

(b) (6) (b) (4) (b) (4) (b) (4) (b) (4)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 30

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Code TaskName Status MOI Agenda

25 M248B Butterfield Foods Company GXN31070

32309G

2018-03-09 04C05 Poultry Good

Commercial

Practices

Finalized On March 8, 2018 at approximately 11:53 AM,

while performing a Good Commercial Practices

Verification Task I observed that the plant was

experiencing a higher than normal amount of

Dead on Arrival (DOAs) birds in the first load of

Lot #2 (Truck #22).  I requested 

accompany me to examine the truck and provide

his impression of the condition of the birds on the

trailer.  Approximately 20 dead chickens were

observed on the exterior two lower level cages of

the trailer and on palpation approximately 12

were “hard” and “non-flexible”.   

made the observation that here was what

appeared to be a larger than “normal” quantity of

eggs and waste on the bed of the truck indicating

a possible longer amount of time in transit than

usual accentuating the effects of the cold

weather.  While the plant staff went on beak and

the truck was waiting to be unloaded, I

requested  , and 

, come to the

unloading dock with me to examine the condition

of the birds on the truck. Gross examination of

these birds revealed no remarkable pathology

indicating a flock disease. However, many birds

had large unfeathered areas.  The unfeathered

areas revealed deeply reddened skin tissue

suggestive of prolonged exposure to extreme

temperatures.  Many appeared to be dead, as

they were not noticeably moving or breathing.

 Post-mortem pathology observed in live

slaughtered birds from this lot was unremarkable.

Cold weather protective panels on livestock

haulers were in place during transport and

holding until the birds were prepared for

unloading. The plant ensured all dead birds were

properly disposed of and the load was finished

with no further incident. The plant subsequently

reported that of the birds in lot #2, 330

were DOA.  The DOA numbers from previously

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

(b) (6)

(b) (4)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 31

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Code TaskName Status MOI Agenda

unloaded trucks delivered prior to the unloading

of Truck #22 ranged from 32 to 82 DOA per load. 

The establishment indicates they will fully employ

humane methods of handling and slaughtering

consistent with Good Commercial Practices in a

way that minimizes injury to poultry.  Poultry are

to be handled in a manner that prevents needless

injury and suffering.  Employing humane methods

of handling and slaughtering that are consistent

with Good Commercial Practices increases the

likelihood of producing unadulterated product. 

Similar GCP observations were made by 

 on 2/23/2018 in an MOI,

Subject: Poultry Good Commercial

Practices / GXN5608022123I. We will discuss this

situation during the weekly meeting on March 9,

2018 with establishment management to

determine any additional corrective actions

and/or preventive measures could be adopted in

the future to minimize the possibility of a similar

(or worse) incident happening in the future,

especially when birds are held overnight in

extreme weather conditions.

(b) (6)
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25 M248B Butterfield Foods Company GXN21130

32023G

2018-03-23 04C05 Poultry Good

Commercial

Practices

Finalized On 3/23/18, at 1010 hours while performing

routine poultry good commercial practices

verification task by monitoring shackled birds in

the immediate vicinity to the entrance of the

scald tank, I observed the following: I observed a

live, conscious shacked bird with no neck cut

enter the scald tank; I verified consciousness as I

observed it blinking and it reacted to physical

stimuli by trying to avoid contact with my hand

by arching its neck and body as I attempted to

reach for its head.   Approximately one minute

later, I collected the cadaver after it emerged from

the scald tank/pickers and was placed in a

condemn barrel by the sorters.  I immediately

notified the

 informing him that I observed this

cadaver enter the scald tank alive.  He stated that

his monitors must have missed one.  I continued

to monitor the shackled birds immediately prior

to the scald tank until approximately 1015 hours

and did not observe any more live birds.  I then

went to the neck cutter/stun area and observed

an increase in un-stunned, vocalizing birds prior to

the neck cutter (at a rate of approximately 1 bird

every 10 seconds with a line sped of

approximately birds per minute).  I observed

the two establishment neck cutter monitors

actively trying to pull down necks multiple birds

to assure adequate neck cuts and reroute

un-stunned birds on the axillary blade. I also

observed the monitor identify and cut the necks

of three birds with a straight knife on the bleed

chain that missed the primary and axillary neck

cutter blades entirely. At approximately 1025

hours, I identified another cadaver on the shackle

line after the scald tank/pickers that did not have

a neck cut which was the second cadaver

identified.  I immediately notified the 

, showing him both

cadavers and informing him that there is an

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

(b) (4)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 33

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increase in un-stunned birds prior to the neck

cutter.  I observed check out the

situation and adjust the electric plate height. 

After this adjustment, I observed the shackled

birds immediately after the electric stun plate and

neck cutter.  The majority of the birds were

adequately stunned with better positioning into

the neck cutter apparatus, and I did not observe

any other birds that were conscious or without

neck cuts after the neck cutter step.  

informed me also that he spoke to his monitors to

take action sooner and notify him if they are

unable to keep up with the conditions in the neck

cutter room.   Employing humane methods of

handling and slaughtering that are consistent with

good commercial practices increase the likelihood

of producing unadulterated product. Poultry must

be slaughtered in accordance with good

commercial practices in a manner that will result

in thorough bleeding of the carcass and ensure

that breathing has stopped prior to scalding.

Stunning of poultry, when performed, is also

expected to be done in a consistent and effective

manner.

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 34

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Code TaskName Status MOI Agenda

25 M248B Butterfield Foods Company GXN32170

42612G

2018-04-12 04C05 Poultry Good

Commercial

Practices

Finalized On 4/12/18, at approximately 0918 hours, I

observed the following while performing routine

Poultry Good Commercial Practices verification

task in the New York Room/Pinning Room, which

is located after the feather picker machine: I

observed a bright pink to red, de-feathered bird

carcass on the shackle line immediately exiting

the picker that was also showing generalized

muscle fasciculation; no other birds on the line at

this time exhibited these signs.  I immediately

pulled this particular bird off the line to examine

it.   I observed no neck cut with the bird exhibiting

no sign of bleed out as it was engorged, red to

pink, and involuntarily twitching in my hand; this

bird was determined to have entered the scald

tank alive and died other than by slaughter.  At

this time, the company was going to break and

there were no more birds at the neck cutter or the

scald tank area; there were no other cadavers

seen in the condemn barrels in the pinning room

at that time. I immediately called for the

, and showed

him the cadaver with no neck cut.  I informed him

that the bird entered the scald tank alive.  Poultry

slaughter in accordance with GCPs requires that

birds need to be slaughtered in a manner that

results in thorough bleeding and ensures that

breathing has stopped prior to entering the scald

tank. came to talk to me at

approximately 0955 hours and stated that he

checked the stunner and the neck cutter when

slaughter resumed and there were no issues

noted.  I observe the bleed chain from the neck

cutter to the scald tank at approximately 1005

hours and did not observe any issues at that time. 

He also stated that he discussed the incident with

his neck cutter monitors and that the monitors

were changed out with a new rotation after

break.   On 4/13/18, at approximately 0850

hours, informed

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

me that they had officially wrote up the employee

stationed at the neck cutter at the time of the

incident for failing to appropriately monitor the

birds for un-cut necks. An MOI was also issued on

3/23/18 for observing two live birds without neck

cuts entering the scald tank.
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 36

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25 M248B Butterfield Foods Company GXN53170

42318G

2018-04-18 04C05 Poultry Good

Commercial

Practices

Finalized On 4/18/18, at approximately 1153 hours, I

observed the following while performing routine

Poultry Good Commercial Practices verification

task in the New York Room/Pinning Room, which

is located after the feather picker machine: I

observed a bright pink to red, de-feathered bird

carcass on the shackle line immediately exiting

the picker; no other birds on the line at this time

exhibited these signs.  I immediately pulled this

particular bird off the line to examine it. I

observed no neck cut with the bird exhibiting no

sign of bleed out, as it was engorged (especially of

the head and neck) and was red to pink in color.

This bird was determined to have entered the

scald tank alive and died other than by slaughter. 

At this time, there were no other birds entering

the scald tank and no supervisor in the area as it

was just before lunch break. There were no other

cadavers observed in the condemn barrels in the

pinning room. I immediately tried to locate a

supervisor but none was present in the hanging

area, stun/neck cutter room, or pinning room.  I

went onto the evisceration floor and spoke to

) and

asked her to call a supervisor for the neck cutting

area.  She informed me that the leadmen and the

supervisor were not here (either at lunch or

gone).  I then asked for her to call the evisceration

supervisor, but he was also at lunch.  I asked for

her to contact the next supervisor in charge and

she called . I showed

them both the cadaver with no neck cut that I

pulled off the line immediately after the picker

machine and told them I would be following up

with a supervisor who is more in charge of that

area when they get back from lunch.  At

approximately 1310 hours, I spoke to 

) and showed him the

cadaver, stating this was the second cadaver

found within a week, identified just prior to

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

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 37

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company break and/or lunch.  I told him these are

isolated incidents with no loss of overall process

control.  However, my concern was that there

may be a trend in poor monitoring of neck cuts in

poultry carcasses just prior to breaks, and that

there was no immediate supervision in this area,

as it was very hard for me to even locate an

applicable supervisor at the time of

identification.   informed me that he

spoke to during lunch at around 1230

hours, who briefed him on the situation. He

followed up with all the monitors in that area and

the , reiterating that

all birds need to be monitored for adequate neck

cuts, especially before break time or lunch. He

stated that the leadman usually leaves after the

last bird goes through the neck cutter step.  After

our conversation, the cadaver was placed in an

inedible bin. An MOI (#GXN3217042612G) was

issued on 4/12/18 for observing a cadaver exit the

picking machine with no neck cut right before

company break.  In addition, an MOI

(#GXN2113032023G) was issued on 3/23/18 for

observing two live birds without neck cuts

entering the scald tank. Poultry slaughter in

accordance with GCPs requires that birds need to

be slaughtered in a manner that results in

thorough bleeding and ensures that breathing has

stopped prior to entering the scald tank.

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 38

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25 M248B Butterfield Foods Company GXN34160

41327G

2018-04-27 04C05 Poultry Good

Commercial

Practices

Finalized At approx. 1802 hrs. on 4/26/18, following the

completion of eviscerating operations, I went to

the pinning room and unloading area to gather

information on approx. how many birds would be

carried over to the next day's production.  When I

entered the unloading (live hang) area I observed

that there were two establishment hourly

employees whom were gathering live fowl from

the hoist pit area.  As I observed the employees

gathering the birds from the hoist pit, one of the

establishment hourly employees, who had

approx. 6 live birds in one had, took one of these

birds, grabbed it by the head with his other hand,

and began to spin the neck of the bird until the

neck was broken.  As the employee was

doing this the bird was vocalizing excessively and

violently flapping its wings.  Before I could stop

him, he had done this to two other live birds.  I

was finally able to get him to stop what he was

doing, and relay to the other employee in the area

that what he was doing was not allowed.  I then

watched as the employee began to shackle the

live birds and use a knife to make a decapitation

cut on the remaining live birds.  I then returned to

the USDA office, and informed 

 of my observations.  

 than accompanied me to

 office, where he was

informed of my observations.  We

, and myself) then went

to the unloading area at approx. 1808 hrs. where I

showed each of them several (6-8) carcasses in an

inedible barrel which had no decapitation cut

made, and evidence (hemmoraging in

cranium/ cervical area(s) not expelled from the

carcass) consistent with being killed by hand.  

then consulted with each of the employees

and informed and myself that

he would be correlating with the supervisor of the

employees right away in the morning.  

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

(b) (6)

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

(b) (6) (b) (6)
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was then informed of the requirements of part

381.65(b) which clearly outline required handling

practices for fowl at official establishments,

specifically "Poultry must be slaughtered in

accordance with good commercial practices in a

manner that will result in thorough bleeding of

the carcasses..."

Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 41

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Animals slipped during unloading. Also, 

 has seen gaps in the trailer/chute which can

be a humane handling issue. Animals need to be

provided adequate footing to prevent slips and

falls. Animal owners who come to unload animals

are also responsible for humane handling. It is

very important to step in if you see humane

handling issues with owners. : There was

a metal plate would cover up the gap and

wouldn’t startle an animal. It has not been

cleaned as often as it has been, which means that

sometimes owners don’t use it. : we

will look at this. Trend of vulnerabilities for an

inappropriate trailer being used. This is not the

first time an inappropriate trailer was used and an

animal escaped. This is a very big concern. If

vehicles and ramps are not properly positioned to

unload animals, this may lead to regulatory

control action being taken. : We

have purchased a removable gate to be used in

these situations. We can bolt the trailer to keep

animals from excaping with this temporary gate. 

MN law does forbid animals from being removed

from a slaughter establishment without a specific

permit. This definitely applies if all animals were

destined for FSIS slaughter. Please inform USDA

personnel if this occurs and we will notify the

proper authorities. If a future humane handling

incident occurs when slaughter is ongoing, we

would put a retain tag on the knock box while we

contact the district office. Again, if an animal were

to escape during unloading, this could lead to

regulatory control actions up to and including

suspension (depending on circumstances). 

Nonambulatory animals are not eligible for the

marks of inspection. MN law also forbids these

animals for custom slaughter. Additionally once

an establishment offers an animal for

ante-mortem inspection, the establishment

cannot change the animal status to “intended for

(b) (6)

(b) (6) (b) (6) (b) (6)
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custom exemption. This is not related to

yesterday’s discussion, but it is important for the

establishment to know. Establishment response:

We will look at the end of the chute and the

establishment to see what can be modified.

Perhaps the plates can have better traction. We

will also unload with two people. We will look at

Temple Grandin’s book on humane handling.

90 M27257 Central KY Custom Meats, Inc. KIF330805

4407G

2018-05-07 04C02 Livestock

Humane

Handling

Finalized While IPP  was performing

Antemortem inspection at approximately 7:35

AM on the USDA hogs this morning I observed

that the custom hog did not have available water

to drink in pen 4.  I advised and that

then needed available water at all times.  This was

a custom hog so an NR was not issued.  This MOI

is the means of informing plant management that

agency policy was not being followed regarding

Human Handling.

05 M27389 Pitman Farms NCO19150

33915G

2018-03-15 04C05 Poultry Good

Commercial

Practices

Open This MOI is being issued by .On

03/13/18 at approximately 0634, while

performing a routine tour of the receiving area, I

observed two chickens on the ground under one

of the trailers. Upon closer inspection I discovered

an open cage on one of the modules of trailer

(Lic. # 4LJ5260). There was a total of nine chickens

out of their cage running around on top of the

trailer and in between the modules.  At 0643

 and three other employee’s arrived

and recovered the chickens by 0705.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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25 M32130 Dakota Provisions LLC JEB350804

2111G

2018-04-11 04C05 Poultry Good

Commercial

Practices

Finalized Est. 32130, Dakota Provisions, 04/11/18, 0545

hours.  Meeting Attendance:  

 and

 On 04/11/18 at

approximately 0450 hours, while performing

ante-mortem inspection, I observed a turkey that

had his left wing caught between the framework

and the fiberglass floor above him.  The bird was

discovered in trailer #27, back cage, middle tier

under the trailer shed outside.  The cages are

designed with 3 compartments/levels per coop

and the floors are comprised of green fiberglass

material held to the cage framework with rivets.  I

immediately notified , 

and , of the

injured bird.  used two bars to leverage

between the floor and framework which took

pressure off the wing and allowed the wing to be

dislodged.  Evaluation of the turkey wing revealed

excessive bruising approximately 6 inches in width

and a laceration that was bleeding.  I placed a US

Reject Tag No. B42252448 on the cage so it could

be evaluated and repaired.  The fiberglass floors

need to be installed appropriately to prevent

injury.  This was previously discussed in three

other instances which were documented in MOI

JEB 5009052618I on 5/18/17, MOI

JEB2207055216L written on 5/16/17 and MOI

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

discussed in the establishment weekly meeting on

5/11/17. A discussion was held with 

 of my observations and concern

for animal welfare at approximately 0545 hours. 

Allen stated that today production personnel

would mark cages needing repair with a repair

card.  They have arranged for a crew to work on

those cages needing repair on Saturday, 4/14/18. 

   The establishment must employ humane

methods of handling and slaughtering consistent

with Good Commercial Practices in a way that

(b) (6)

(b) (6)

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

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 44

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minimizes injury to poultry.  Poultry are to be

handled in a manner that prevents needless injury

and suffering.  Employing humane methods of

handling and slaughtering that are consistent with

good commercial practices increase the likelihood

of producing unadulterated product.

80 M33831 Ayrshire Farm Management, LLC PVD37060

23906G

2018-02-06 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 8:10 hours, I, 

met with 

to discuss the execution of Good

Commercial Practices at the establishment. 

Earlier, while performing the Poultry GCP

verification task, I had observed that, after being

stunned and then given the kill cut, some of the

very small chickens being slaughtered were not

remaining inside of the cones being used for this

process.  When necessary, these birds were being

pulled through the cones and reinserted but twice

I observed birds fall through the cones and into

the blood trough.  These two birds were picked up

out of the trough and then also reinserted into the

cones for full bleed out.  I informed 

of my observations and then noted the apparent

need for better accommodations for the smaller

birds during the slaughter process; especially as

the demand for these birds increases.  

stated that he would order smaller

cones to accommodate these birds and then said

that he expected these cones to arrive in time for

next week's slaughter. This meeting was then

adjourned. 

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

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

(b) (6)
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80 M33940 Fauquier's Finest Custom Meat

Processing, Inc.

DAG16150

15309G

2018-01-09 04C02 Livestock

Humane

Handling

Finalized The following incident occurred at establishment

M33940 (Fauquier’s Finest Custom Meat

Processing) at 12:45pm on January 9, 2018: The

slaughter floor personnel brought the last hog of

the day into the chute.  It was a large hog, in the

1000-1200 lb. range.  As per their protocol, they

applied the squeeze chute to immobilize it, then

applied the electrical stunner to the brain at the

voltage recommended for a 1200-lb. hog (580 V)

until it went limp and dropped to the ground.  At

this point, the animal was unconscious.  As per

their protocol for swine, slaughter employee

applied a secondary (“security”) knock, in this

case with the .22 rifle due to the size of the

animal, and because of the size of the animal,

applied a second rifle shot.  Still following

protocol, the slaughter employee stuck the

animal, at which time it began paddling in a circle,

but remained recumbent.  Once it had circled

about 120 degrees, it came to a stop, at which

point the slaughter employee applied the full cut

severing both carotid arteries. It was at this point

that the animal came to its feet and began

staggering.  It eventually fell into sternal

recumbency.  The slaughter employee applied

two more shots with the .22 rifle.  In each case,

the animal vocalized, paddled a bit, but did not

get up.  At this point, since the animal was still

breathing intermittently, they elected to have

their co-worker shoot it with his .357, which he

did (twice).  Shortly after this, the animal was fully

unresponsive (clinically dead) and they were able

to process it. The animal regained consciousness

after the initial stunning event; therefore, this

constitutes an egregious noncompliance with 9

CFR 313.30(a)(1).  applied U.S.

Rejected tag #B41301176 to the knock box at

2:35pm and informed both slaughter floor

personnel of the regulatory control action (Plant

Manager Michael Rodrigues was informed by

(b) (6)
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phone). The establishment does not currently

have a robust systematic approach to the humane

handling of livestock.
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 47

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25 M3W Swift Pork Company GJC052105

2910G

2018-05-10 04C02 Livestock

Humane

Handling

Finalized At approximately 7:20pm, 

met with ; and at

approximately 8:50pm, met with 

 and .  The following

concerns and observations were pointed out and

discussed. 1. noted that stressed hogs

are regularly brought into the area between the

two chutes leading to the She noted that

on occasion, these hogs are not immediately

stunned and are left sitting in the area.  

 stated that the employees are supposed

to stun the hogs ASAP.  She pointed out to 

 a hog that was sitting in the area when

she walked by, probably about 10 minutes

earlier.  Employees were not moving towards

stunning the animal immediately.  These hogs do

not have access to water, and while this area is

not a typical holding pen, FSIS expects animals

that are held be provided access to water. 

Compliance with 9 CFR 313.2(e) is questionable in

this area.  agreed to provide these

animals with water.  The establishment will

provide a pan of water in the area for now, and

follow up with running a line and water nipples

into this area for the future. 2.  noted

that in the central area between the 

chutes, hogs that are brought into that area

occasionally get up and wander around.  She

observed that there are areas in this place that

could lead to injury of hogs.  For example, she

observed a hog wander to the corner behind

 #1.  The hog, if startled, could

jump through the bars and fall and injure itself. 

The establishment will look at this area more

closely.  A cursory look through the

establishment's written Systematic Approach to

Humane Handling does not appear to specifically

address this area.

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

(b) (6)

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

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

(b) (6) (b) (6) (b) (4) (b) (4) (b) (4) (b) (4)
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90 M40041 Marksbury Farm Foods, LLC NRW10130

25615G

2018-02-15 04C02 Livestock

Humane

Handling

Open On 02/15/2018 at 1100 at Marksbury Farm

Foods, LLC on the slaughter floor, 

heard activity at the knock box. She

proceeded to the stair of the knock box and

observed the stunner use a captive bolt gun to

administer a stun to a beef.  After the stun was

administered the beef retained ability to stand

and displayed conscious eye movement. Another

stun was immediately applied; 

observed the beef continued to retain the ability

to stand and display conscious eye movement.  

Another stun was immediately applied rendering

the beef unable to stand and insensible. 

 applied U.S. Rejected tag #B28142221 to

the knock box and notified 

.

90 M40041 Marksbury Farm Foods, LLC NRW33120

35814G

2018-03-14 04C02 Livestock

Humane

Handling

Open On  3/14/2018  1230 hours  at Marksbury Farms

Foods( M40041)on the livestock slaughter  floor

 while observing activity at  the knock  box, 

 observed a market lamb roll out of

the knock box after being stunned. When it hit

the floor landed on its belly, head was raised and

displayed conscious eye movement. Immediate

corrective action was applied however the stun

proved to be ineffective since the lamb was able

to rise on its front limbs and still had conscious

eye movement .An additional stun was applied

and proved effective. applied

USDA Rejected Tag #B41495755 to the knock box

and notified Plant Manager Leonard Harrison.

(b) (6)

(b) (6)

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

(b) (6)
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90 M44779 Faulkner Meats VMV20060

51509G

2018-05-09 04C02 Livestock

Humane

Handling

Open May 8, 2018 Today at approximately 1330 while

performing the Livestock Humane Handling task

at Faulkner Meats, Taylorsville, KY the following

observation was made by the SVMO. A small

holding pen of 20+ mature sheep was observed to

be without water. There did not appear to be

sufficient space in the pen for all animals to lie

down, either. Granted, the animals had not been

declared for Federal Inspection. However,

according to Directive 5930.1 Rev 4, the HMSA

(Humane Methods of Slaughter Act) requires that

livestock be humanely handled in connection with

slaughter, (21 U.S.C. 610(b)). The animals should

have access to water and if held overnight the

ability to lie down. A MOI dated May 1, 2018 was

presented to the establishment for a similar

incident involving the lack of water access.

80 M44791 Doublebrook Farm LLC VUF44070

43006G

2018-04-06 04C02 Livestock

Humane

Handling

Finalized When checking the livestock outside I noticed

that the water containers were not filled with

water.  said that the swine had knocked

the water over and so it was spilled.  I asked him

to refill the container.

(b) (6)
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60 M45029 Vermont Packinghouse LLC FUU20110

12823G

2018-01-23 04C02 Livestock

Humane

Handling

Finalized HAT Category VIII – Stunning   On 1/22/2018, at

approximately 10:00am, while on break in the

observation room above the slaughter floor, the

stunning employee informed he had

double stunned a couple of lambs that morning

because although they went down, he was unsure

as to whether or not they were unconscious or

not when he was dragging them in. 

immediately went to observe stunning activities

following break. At approximately 10:20am that

same morning, observed the

following: The employee stunned a lamb. The

lamb’s head went down, but the lamb remained

standing, and started to shake its head back and

forth. The employee immediately grabbed the

backup captive bolt and attempted to re-stun the

lamb. The lamb fell to the ground, but when the

employee went to grab the lamb’s back leg, the

lamb stood up and ran to the back corner of the

weigh-in chute area where the animal had been

restrained. The animal was observed by 

to have blood running out of one of the stun

holes, and both eyes were open and blinking. The

animal also demonstrated the following

movements: standing, running, walking, and

rhythmic breathing. The employee reloaded the

captive bolt and re-caught the animal. The

employee stunned the animal. There was a delay

of approximately 2-3 minutes between the second

and third stunning attempt. The third stunning

attempt was successful and the animal remained

unconscious throughout the bleeding process.

Immediately (CSI) took a regulatory control action

to the weigh-in chute area where the lambs are

stunned. Regulatory tag#B43049629

(b) (6)(b) (6) (b) (6) (b) (6)
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60 M45134 Birdsboro Kosher Farms Corp. FKJ071505

1007G

2018-05-07 04C05 Poultry Good

Commercial

Practices

Open On 05/07/2018 at approximately1545 hours, I

was walking through the ante-mortem area and

looked inside the DOA barrel and found a

slaughtered bird that wasn’t completely dead and

still breathing and moving. I stopped the line and

informed Mr. Urieta, Plant Manager and 

. The bird was

removed from the DOA barrel and put in the area

specified for that situation until it completely died

and stopped breathing, and then was moved to

DOA barrel.  It is not consistent with Good

Commercial Practices to have breathing birds in a

barrel specified for dead birds. 

(b) (6)

(b) (6)
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25 M45856 Prime Pork LLC ODB43120

41520G

2018-04-20 04C02 Livestock

Humane

Handling

Finalized On April 17, 2018, while performing routine

Veterinary inspection at 1415 hours on the

harvest floor, I was presented with a carcass

(MPD65229431) for Veterinary disposition. This

carcass had tattoo 70XX on the dorsal mid line. In

addition, there were six additional tattoos one

each on the shoulders, the flank, and the hams.  I

made an inquiry with 

as to the placing of the tattoos and

if they were applied while the hog was still alive. I

was informed that this was a "sub" (Slow or

crippled) and that the tattoos were applied while

the hog was still alive. I advised him that this may

be excessive. On April 18, 2018, while performing

ante-mortem with 

 I described my findings from the previous

day and again asked if the hog was alive when the

tattoos were applied. Again I was informed that

these tattoos were applied immediately after

moving the hog to the "sub pen" and before the

hog being stunned. I let know that

this was an excessive number of tattoos to be

applied. The "subs" are already at a higher level

of stress and care should be taken not to increase

their stress and excitement. On April 19, 2018,

 advised me that the procedure for

handling the "subs" was modified to have the

additional tattoos applied after the hog had been

stunned.

25 M45856 Prime Pork LLC ODB54110

42824G

2018-04-24 04C02 Livestock

Humane

Handling

Finalized While performing Ante-mortem inspection with

 at pen

0954 hours I discovered the following issue. While

inspecting the hogs in pen 22, there was a hog

with his head under the gate in a manner that the

corner of the gate appeared to be penetrating the

left eye at the medial canthus gently

opened the gate and on inspection both the eye

and the icitating membrane were intact. This

gate does pose a potential hazard.

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

(b) (6) (b) (6) (b) (6) (b) (6)
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90 M46185 Detweiler Meats N More WPP09100

34121G

2018-03-21 04C02 Livestock

Humane

Handling

Finalized At 7:15 this morning I witnessed 

 attempt to stun a hog with a captive

bolt. He shot twice with this not effectively

stunning the hog.  After two attempts the hog was

still not effictly stunned. left

the slaughter floor to retrieve a rifle in which he

shot the hog and at that time the hog was

effectively stunned.. I placed a tag on the knock

box and called and then I called

District Office. This establishment is Detweiler

Meats M 46185.

80 M56 PILGRIMS PRIDE CORPORATION MBJ01130

32726G

2018-03-26 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1007 hr. I, 

 performed a Good Commercial Practice

check in the Live Hang Department, along with 

 We observed a live bird breathing in the

outside dumper. I went to the Pinning Room to

find . We

returned to the dumper where 

observed the live bird. He then took the bird to

the live hang line. and I returned to

the USDA office and informed 

 of our findings. This incident is not in

keeping with Good Commercial Practices,

especially those practices related to handling of

live poultry. This MOI serves as a written notice

that future oversight of this nature may result in

the taking of additional administrative actions.

Please submit documentation of corrective and

preventive measures relating to this incident. 

 cc: 

 Raleigh District ,

, Raleigh District 

 

(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)
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35 M5842 Tyson Foods, Inc. NPF37210

12902G

2018-01-02 04C05 Poultry Good

Commercial

Practices

Finalized On 01/02/2018 at approximately 2130 hours 

 was notified by the online inspector

on Evisceration Line #1 stand #2 that he had

identified and hung back for disposition a carcass

with the head still attached and no identifiable

neck cut notified me of the

finding and upon inspection I noted that the

carcass was cherry red to purple in color with no

neck cut and no evidence of exsanguination. I

confirmed that the carcass was a cadaver and

showed it to 

and . At

this time one additional carcass that was cherry

red to purple in color with the head attached and

no evidence of exsanquination was observed in

the condemn barrel at the Line #1 rehang area. 

Poultry carcasses which show evidence of having

died other than by slaughter reflect poor

commercial practices. 9 CFR 381.65(b) states that

"poultry must be slaughtered in accordance with

good commercial practices in a manner that will

result in thorough bleeding of the carcasses and

ensure that breathing has stopped prior to

scalding".

(b) (6)

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

(b) (6)
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35 M5842 Tyson Foods, Inc. NPF40190

15705G

2018-01-05 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1840 hours as I was walking

through the live hang area I observed movement

inside a condemn barrel located next to the end

of Kill Line #1. The condemn barrel was almost

completely filled with dead chicken carcasses. I

notified 

and observed as he uncovered a live, bright alert

chicken underneath approximately 6 carcasses.

The live chicken was removed from the condemn

barrel and placed on the kill line for slaughter. At

1900 hours I discussed my findings with

.  We discussed

the unlikely possibility of a live hang

employee inadvertently placing an alert live

chicken into the condemn barrel.  

suggested that the live bird could have jumped or

been inadvertently pushed into the barrel because

of the proximity of the barrel to the kill line. He

stated that as a preventative the condemn barrels

would be moved further away from the kill lines

to reduce the chance of a live bird jumping/falling

into the condemn barrels. A live bird being

covered by dead chicken carcasses has a high risk

of smothering. Death caused by smothering

reflects poor commercial practices and is

noncompliant with 9 CFR 381.65(b).

(b) (6) (b) (6) (b) (6)
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35 M5842 Tyson Foods, Inc. NPF58130

43025G

2018-04-25 04C05 Poultry Good

Commercial

Practices

Finalized As described to me by on 4-23-2018:

"April 23, 2018 at approximately 1313 hours, at

the start of second shift as I entered the

evisceration department I noticed that the

evisceration line 1 was running empty. The live

hang line one was stopped and maintenance

personnel were making repairs on it at the rehang

area. I proceeded to the live hang area and

observed that birds were still hanging on the kill

line 1.   The birds between the stunner and the kill

blade had a purplish color and were not moving

and not breathing; I did not see a cut on the bird’s

necks. The birds showed evidence of dying other

than normal slaughter process.  Multiple birds

that were hanging on the kill line prior to the

stunner machines had swollen reddish purple

heads and there was drool coming from their

beaks. They were also vocalizing and flapping

their wings excessively. I stood in front of the

stunner machine for a few minutes and I did not

see anyone attempting to retrieve these birds

from the line. At approximately 1320 hours I

walked out of the area to inform the SPHV of my

observations. When I came back to the area the

birds that were hanging prior to the blade had

been removed (approximately 11 birds). 

 was in the area

at this time and I described my previous findings

to him.  I also showed him two of the birds that

were left hanging near the neck cutter. I informed

him that the other birds were in the same

conditions as these birds prior to being removed." 

On April 24, 2018 I held a discussion with night

shift Assistant Plant Manager Brad Massengale

concerning the above issues.  Mr. Massengale

stated that he had interviewed employees in the

area in order to gather information about the

events.  I expressed to Mr. Massengale my

concerns about birds dying other than by

slaughter and the condition of live birds that

(b) (6) (b) (6)
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remain hanging on the kill line during extended

down time.  He stated that he intends to correlate

with plant management personnel in order to

develop a program to address live birds that

remain on the kill lines during extended down

time to ensure that poultry good commercial

practices are maintained.

05 M6012 U. C. Davis Meat Laboratory BKO25170

20214G

2018-02-14 04C02 Livestock

Humane

Handling

Finalized I asked on 2/14/18 at approximately

1120 hours after our regular weekly meeting (Est.

6012, U.C. Davis Meat Laboratory, located at 1

Shields Avenue, Davis, CA  95616) if the animals

(Market and Roaster hogs) that were harvested

today had access to water during their brief stay

in the ante-mortem pens alley way prior to the

lead up chute. I was performing post-mortem

duties inside of Harvest Room and could not go

outside to verified that the animals had access to

water.  He explained that there is no access to

water in the alley way and would be difficult to

place water in area because animals (Cattle, Hogs

for example) could knock off the water containers

or similar units. Policy considers the alley way a

holding pen and per 9 CFR 313.2(e) "Animals shall

have access to water in all holding pens and,....". I

returned to first assignment of my work day and

informed of the discussion

and decided to write the Memorandum of

Interview (MOI) in regards to this issue.  I

informed via text message of the

impending MOI. 

 Badge Cc:  

 file @ Est. 6012, 

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
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05 M6137 Foster Farms BXL331603

0202G

2018-03-02 04C05 Poultry Good

Commercial

Practices

Finalized Establishment P6137 – Plant 2, Foster Farms, 

March 12, 2018 In attendance :  

 

This MOI is intended to document the discussion I

had with 

about the Poultry Good Commercial Practices

incident that occurred in Plant 2 - Line on

Thursday, March 1, 2018. At Approximately

1450 hours on March 1, 2018 I noticed a carcass

hanging on the rack adjacent to the pre-sorter

station in line of plant number 2 that had the

characteristic appearance of a cadaver.  As I

approached the pre-sorter station,  I noticed a

number of carcasses inside the condemn barrel

placed near the pre sorter station that also have

the characteristics appearance of a “Cadaver”.  I

verified that 5 out of 8 carcasses in the condemn

barrel were Cadavers with the head intact and no

visible cuts along the neck. In addition 1 out of

the 8 carcasses had a cut on the neck area that

had only penetrated the subcutaneous tissue of

the neck. I called the attention of 

 and showed her what I saw and she

immediately called 

  I showed the cadavers

from the barrel.  After a few minutes,  the sorter

on the pre-sorter station pulled another cadaver

with the head intact and without any neck cut as

well.  informed

me that they are addressing the problem as this

was a result of moving kill line employees from

plant 1 to plant 2.  I also informed 

 through the phone what

my observations were. I reminded 

 that the PPIA and Agency Regulations do

require that live poultry be handles in a manner

that is consistent with good commercial practices,

and that they not die from other causes other

than slaughter.  Please review Federal Register

Notice Vol. 70, No 187, published September

(b) (6)

(b) (6)

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

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

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

(b) ( (b) 
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2005 (Docket No. 04-037N) for FSIS

recommendations concerning treatment of live

poultry before slaughter.  was

informed that this MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. 

 - Livingston Circuit Establishment P6137 

FSIS- USDA

(b) (6)

(b) (6)
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05 M6137 Foster Farms BXL340504

2724G

2018-04-24 04C05 Poultry Good

Commercial

Practices

Finalized This MOI is intended to document the discussion I

had with 

about the Poultry Good

Commercial Practices incident that occurred on

Monday, April 23, 2018. On 4/23/2018 at

approximately 2320 hours while performing the

Poultry Good Commercial Practice in plant 1, 

 observed that the auto-kill machine for line

2 was not functioning correctly and groups of

birds (approximately 3-6 birds at a time) were

going through the machine without cuts or not

adequately cut to bleed out. The backup

cutter was struggling to keep up with the amount

of miss-cuts and I observed one bird go through

without a cut. I went to the pre-sorter station for

line 2 and observed one cadaver removed from

the line and hanging on the rack for further

disposition. I later learned this was already the

third cadaver that was found on the line. I

informed of the

problem with the auto-kill machine. 

 response to me was that he would go

investigate the issue. I discussed the issue with

 and

was informed that the pre-sorter for line 2

notified for each

cadaver found but there was no communication

with   to address the issue until I

had brought it to his attention. At approximately

0710 hours I observed that three more cadavers

were pulled from the line at the pre-sorter

stations. When I went to discuss my findings with

, he informed me that one

cadaver from line 1 was pulled but he was

unaware that another two cadavers were pulled

off line 2 at a later time. was

called down to evisceration and he was not aware

more cadavers were occurring. “I reminded 

 that the PPIA and Agency

Regulations do require that live poultry be

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

(b) (6)

(b) (6)

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

(b) (6)
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handles in a manner that is consistent with good

commercial practices, and that they not die from

other causes other than slaughter.  Please review

Federal Register Notice Vol. 70, No 187, published

September 2005 (Docket No. 04-037N) for FSIS

recommendations concerning treatment of live

poultry before slaughter.”  “I informed 

 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)
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80 M6541 Gunnoe Sausage Company, Inc. SLD540904

0818G

2018-04-18 04C02 Livestock

Humane

Handling

Finalized Held a meeting with plant manager, Craig

Gunnoe, regarding the use of an electric prod in

driving the animals and the set-up of the holding

pen directly prior to the knock box. While

observing humane handling and stunning today,

the employee responsible for movement held just

an electric prod and used it exclusively to move

sows into the knock box. The employee was

approached and notified that a rattle paddle is to

be used unless the sows are being more difficult

and an electric prod is required to get them to

move. The employee proceeded to switch to only

a rattle paddle and had a lot of difficulty moving

the sows (at this time only four were left in the

building). The employee needs to be more

judicious in the use of the electric prod and was

notified of this fact. During the meeting with Mr.

Gunnoe, we discussed not only the use of the

electric prod but the limitations in the design of

the facility to help with movement of sows from

the holding pen in the building directly into the

knock box. We discussed ideas such as blocking

vision on the narrow alley towards the box (slowly

limit the sow's vision on one side and then both

sides in the box), boarding off one side of the pen

diagonally to create more of a funnel effect, when

having trouble moving just 3-4 sows that are left

(too much room is available for them to turn

around and avoid the box) either run them back

out to the pens to let them calm down, or

routinely move additional animals into the

building to limit the space available so the alley is

the only option. We also discussed running two

animals towards the knock box and letting one

completely enter before removing the second.
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80 M6590 Randolph Packing Co., Inc. YBB261204

4812G

2018-04-12 04C02 Livestock

Humane

Handling

Finalized Attendees: ; Mr.

Craig Hamlet, Vice President M6590 Meeting

Time and Date: Approximately 11:30am on April

12, 2018 Location: Veterinarian USDA office of

M6590 in Asheboro, NC I notified Mr. Hamlet of

the following situation: On the morning of April

12, 2018 at approximately 9:00am, 

and I observed a concerning

incident in the alleyway to the knocking box at

M-6590. A Holstein dairy cow was refusing to go

into the knock box from the alleyway. When we

began observing the incident, the plant employee

was using his boot to inappropriately push the

cow into the knock box area. He and other

employees also used the cattle electric “hot shot”

prod about 10-12 times over the course of about

4 minutes.  The animal kept backing up and still

refused to enter. No breaks were taken in the

attempts to coerce the animal into the knock box.

Mr. Hamlet agreed that the above situation was

not acceptable and that he would have a meeting

with the barn manager to address the situation.

He also stated that he would monitor the

employee for conformance to the establishment’s

standards.  I agreed that it is appropriate to

address the issue immediately. The information

provided in this MOI includes all of the topics

discussed during the meeting.

(b) (6)

(b) (6)
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25 M717 Smithfield Fresh Meats Corp. TAE080702

4007G

2018-02-07 04C02 Livestock

Humane

Handling

Finalized While was performing the

Livestock Humane Handling task on 02/05/2018

at Est. 717 in Denison, IA., she observed the

following: While observing an establishment

employee driving hogs to a pen, there was one

hog that repeatedly would sit down, get back up

and take a few steps, then sit back down and

move with its front legs and drag its back legs. She

informed the employee to not put that hog in the

pen. The employee left that hog in the alley and

proceeded to move the rest of the group into the

pen. The employee then came back and using a

rattle paddle to move the hog, drove it back

approximately 30 feet to where the skid loader

was waiting. At that point, another employee

attempted to load the hog into the skid loader

bucket but did not get the hog loaded completely

before the employee driving the skid loader lifted

the bucket. Another establishment employee and

 instructed the skid loader driver to

stop because the hind legs of the hog were

hanging over the edge of the bucket. The

employee then proceeded to lower the bucket

and the hind legs of the hog curled underneath.

 and the establishment employee

again told her to stop, which she did, preventing

the hog’s hind legs from becoming stuck. After a

discussion with and ,

the following is a summary of the conversation I

had with and ,

procurement and humane handling management

at Est. 717: There are a couple of concerns that

were raised from this incident – how the hog was

identified and moved as a

non-ambulatory/disabled animal, and how it was

loaded into the bucket. For the most part the

employees are very conscious and follow both

your voluntary segregation program and properly

identify, protect, and transport

non-ambulatory/disabled animals. From the

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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description it sounds like this hog was attempting

to walk and went down repeatedly and then was

still moving somewhat. From what I was told the

hog was not vocalizing, but its inability to fully

walk to the pen should have resulted in its

identification as a non-ambulatory/disabled

animal. At that point, the employees typically

bring the skid loader to the disabled hog; I’m not

sure what was different in this situation that

caused them to drive the hog back to the skid

loader, but it should have been brought to the

hog. I know we have had conversations before

about making sure the hog is fully in the bucket

before raising it and you have addressed it with

your employees. In this instance the hog didn’t

vocalize and wasn’t injured, but in the future, the

hogs should be completely loaded into the bucket

before it is lifted. These concerns do not rise to

the level of non-compliance; therefore this

discussion will be documented in an MOI. 

Establishment management immediately held a

meeting with the employees involved after

notification from of the incident.

After my discussion with them they planned to

have a meeting with all employees in the barns to

ensure that they were aware of FSIS’ concerns and

how to correct these issues in the future and

stated that they would continue to monitor to

ensure compliance.

(b) (6)
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15 M717CR Smithfield Fresh Meats Corp. RZG091601

5010G

2018-01-10 04C02 Livestock

Humane

Handling

Finalized At 1300 hours on January 10, 2018, I, USDA 

, met with 

 and 

 to discuss humane

handling concerns. Concerns are: - Creating

excitement when moving hogs from holding pens

to kill alley and stunning alleys. - Placing more

hogs in holding areas then is stated in the

establishment's animal welfare program. We

discussed signs of excitement in hogs when being

handled.  National Pork Board Transport Quality

Assurance Handbook, "Pig Behavior,

Handling & Fitness" was used as a reference.  This

falls under 9CFR 313.2(a). stated that

she will monitor the kill and stunning alley areas

and talk to the supervisors responsible for the

employees in that area.  There were no other

concerns or questions.

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

(b) (6) (b) (6)
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90 M7356 Harmon Brothers Meats, Inc. IJK5810040

813G

2018-04-13 04C02 Livestock

Humane

Handling

Open April 13, 2018 HATS Category  VIII-Stunning

Effectiveness:  At approximately 1045 EDT while

performing the Livestock Humane Handling task

at Harmon Bros. Meats, Warsaw, KY a stunning

failure was observed on the kill floor. A market

hog was placed in the knock box; plant personnel

shot the hog with a rifle and vocalization was

heard; plant personnel attempted a second shot

with the rifle, again vocalization was heard. I

looked in the knock box and observed the hog

standing-conscious righting reflex. After a period

of time a third shot was attempted with the rifle;

the hog went into a sternal position. Plant

personnel retrieved the captive bolt device; the

side of the knock box rose and the hog was

observed to have conscious eye tracking and a

conscious righting reflex—it attempted to crawl

out of the knock box. Plant personnel lowered the

side of the knock box to prevent the hog from

escaping and in doing so lowered the side onto

the hog’s neck causing it to vocalize. The fourth

attempt to stun the hog was made with the

captive bolt device and it did render the hog

insensible. U. S. Rejected tag # B19860162 was

placed on the knock box. Plant manager Roy

Palmer was informed of this observation and the

regulatory control action.
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90 M7356 Harmon Brothers Meats, Inc. IJK3711052

311G

2018-05-11 04C02 Livestock

Humane

Handling

Finalized At 1028 Hours on 11 May 2018, 

and I observed a hog in the end  hog pen with a

large bloody abscess on left rear knee. The hog

was lying down, and another hog was eating the

abscess. I immediately informed a plant employee

that the injured hog needed to be separated

immediately from the others. There were a total

of 19 hogs in the pen. The establishment

employee moved the injured hog to a holding

area, and discussed this incident

with Karen Allen, Vice Manager, and the Plant

Manager, Roy Palmer. These animals had not

been declared for FSIS  inspection. The plant has

stated that they were not doing anymore USDA

inspected hogs today. Based upon the fact that

the affected animals were not declared for

federally inspected slaughter, the guidance of FSIS

Directive 5930.1, Revision 4, and as such this MOI

was issued per that Directive’s guidance.

(b) (6) (b) (6)
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80 M7470 Mountaire Farms Inc. - NC Division YRA341204

1613G

2018-04-13 04C05 Poultry Good

Commercial

Practices

Finalized On 04/12/2018, at approximately 1337 hours

evisceration line station 3 Food inspector ask for

me to look at a bird that was pulled and hung

back on the station’s USDA/VET shackle for

disposition.  I observed that the bird had a swollen

head: the skin on the head and neck area was

dark purple in color and around the upper breast

area the skin was a light reddish color. These are

indications of bird dying from causes other than

slaughter. No viscera was presented. I informed

the that I did not

see any cut along the neck/head that would allow

the bird to bleed out properly. took the

bird and stated the bird will be shown to the kill

floor supervisor and condemned. At

approximately 1344 hours I informed

about the bird and MOI would be issued. 

stated that he had seen the bird and did

notice a small nick on the back of the head.  The

PPIA (21 U.S.C.  453(g)(5)) as well as the Agency ‘s

regulation (9 CFR 381.90) require that live poultry

be handled in a manner that is consistent with

good commercial practice (GCP),  and that they

not die from causes other than  slaughter.

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

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15 M751 Pitman Farms Inc. (Moroni Turkey

Processing)

MMK2912

035614G

2018-03-14 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview to Discuss Birds

Held in Shackles during a Line Breakdown 

Norbest Turkey / Est# P01049 Meeting Time:

Tuesday, March 13, 2018 between 1402 and

1540 Attendees: USDA                         

     Establishment          

                              

     

                                  

                                   

 This memorandum

was necessitated by observations and discussions

made while performing a Good Commercial

Practices task during a prolonged mechanical

breakdown on March 13, 2018. On March 13, a

chiller malfunction caused the evisceration line to

be stopped from 1402 to approximately1540. 

During that time, I visited with the five different

supervisors listed above and asked each of them

what their protocol was in regard to the live birds

remaining in shackles in the hanging bay.  All

stated the birds are monitored for signs of

discomfort and would then be either killed or

removed from the line if signs of discomfort

developed.  After approximately one hour of

downtime, and removed the birds

in the hanging bay from the shackles which were

within reach.  I observed a couple which had

already died but did not observe the actual

removal of the rest as I was not in the area at that

time.  The shackle line travels up and around the

ceiling before descending again to enter the stun

and kill area so not all shackles were within

reach.  After they removed the birds which were

within reach, I counted approximately 45 birds

remaining in shackles around the ceiling and

descending toward the entry to the stun and kill

area.  After the chiller was repaired and the line

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

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6)
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was restarted, I was in the rehang area to observe

the approximately 45 birds which had remained

in the shackles.  When they presented in the

rehang area, I counted eight dead birds on line

within the group.  Seven were rehung to enter

evisceration and were condemned by USDA

inspectors in the evisceration department as

cadavers.  The establishment protocol

concerning birds remaining in shackles during a

breakdown of the line is documented in SOP #332

Line Breakdown. According to the SOP, birds in

shackles are assessed for signs of discomfort.  For

birds hanging in elevated shackles where it is not

possible to reach them, they will be left to hang if

comfortable “but at the first signs of discomfort

they will be bled.”  To reach the birds, “they will

be accessed by the proper personnel with a lift.” 

Lastly, “All animals will be treated in the most

humane and sanitary manner possible.”  During

the incident of March 13, no attempt was made

to access the elevated birds with a lift.   They

remained in the shackles for the duration of the

breakdown and yielded seven which had died

prior to stunning and bleeding. This

memorandum serves to document what was

discussed and also provide the Denver district

office with information concerning the operations

being conducted at this establishment.  A copy of

this memorandum of interview was provided to

establishment management, and the signed

original will be placed in the USDA files. 

(b) (6)
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15 M751 Pitman Farms Inc. (Moroni Turkey

Processing)

MMK1516

030316G

2018-03-16 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview to Discuss Birds

Held Over for Slaughter Norbest Turkey / Est#

P01049 Meeting Time: Friday, March 16, 2018

at 0945 Attendees: 

USDA                                                            

Establishment 

                           

This meeting was necessitated by observations

made while performing a Good Commercial

Practices task each day for the week of March 11,

2018. The establishment protocol concerning

live birds held over is documented in both their

Animal Welfare Program and also SOP #307 Live

Bird Holdover.  The written procedure pertains to

an unscheduled live bird holdover due to a

deviation such as a breakdown or shutdown and

“is in conjunction with applicable best industry

practices, notably National Turkey Federation

(NTF) “Animal Care Best Management Practices,

2012.”   Tuesday Holdover (approx. 2,700 toms) 

Three full trailer loads and a partial trailer load of

toms were held over from Tuesday morning to

Wednesday afternoon.  According to ,

the deviations in production causing the holdover

were “due to the delayed start from sanitation

and the breakdown experienced with the chiller.” 

Toms from this particular producer had a high

incidence of airsacculitis, inflammatory process

and synovitis which were associated with

documented failures of an FPS check and a zero

tolerance check as well as reduced line speeds on

Tuesday.  When unloaded on Wednesday for

slaughter, company records show the three full

trailers yielded 26, 23 and 24 dead birds in

comparison to 5, 1, 6, 5, 3 and 3 for the other

trailers which arrived from the same producer

Wednesday and were slaughtered Wednesday. 

Line speed reductions occurred during the

processing of those toms on Wednesday. 

Wednesday Holdover (approx. 1,000 toms) A

(b) (6)

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

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previous day. As documented in previous MOI,

issues outside of mechanical breakdowns (a trend

of lower line speeds due to quality of birds, zero

tolerance failures, FPS failures, etc) may be

historical and anticipated aspects of a particular

poultry operation for a prudent establishment to

consider when planning production.  

is going to review the matter further with Mr

Mellor.  According to , production

schedules are built for a roughly 5 week

projection, and they can be modified long term or

short term in response to holdovers; however, the

short term modifications are more problematic to

absorb thus contributing to the holdovers

becoming a multiple day event.  Also according to

returning the birds to the farm may

contribute to higher losses which compounds the

problem. As was discussed previously, it is not a

good practice nor is it in the establishment’s

interest to hold birds overnight.  A previous

complaint was filed with the district office by an

observer that concerned holdover birds.  

understood, therefore, that FSIS will continue to

issue MOI for this matter. This memorandum

serves to document what was discussed and also

provide the Denver district office with information

concerning the operations being conducted at this

establishment.  A copy of this memorandum of

interview was provided to establishment

management, and the signed original will be

placed in the USDA files. 

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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15 M751 Pitman Farms Inc. (Moroni Turkey

Processing)

MMK4017

033423G

2018-03-23 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview to Discuss Birds

Held Over for Slaughter Norbest Turkey / Est#

P01049 Meeting Time: Friday, March 23, 2018

at 1245 Attendees: 

USDA                                                            

Establishment 

                        

 This meeting was necessitated

by observations made while performing a Good

Commercial Practices task each day for the week

of March 18, 2018. The establishment protocol

concerning live birds held over is documented in

both their Animal Welfare Program and also SOP

#307 Live Bird Holdover.  The written procedure

pertains to an unscheduled live bird holdover due

to a deviation such as a breakdown or shutdown

and “is in conjunction with applicable best

industry practices, notably National Turkey

Federation (NTF) “Animal Care Best Management

Practices, 2012.”   Tuesday Holdover (approx.

500 toms) A partial trailer load of toms (truck

#96) were held over from Tuesday morning to

Wednesday afternoon.  According to ,

the holdover was determined appropriate due to

the unscheduled deviation from a late start due to

sanitation contractor performance and our

inability to process all of the birds scheduled.  

Birds held over at this facility, including this week,

are routinely held for more than 24 hours because

production begins with hens and ends with the

toms so the toms held over didn’t get killed until

the following afternoon even though they had

arrived the previous day. As documented in

previous MOI, issues outside of mechanical

breakdowns may be historical and anticipated

aspects of a particular poultry operation for a

prudent establishment to consider when planning

production.  According to ,

production schedules are built for a roughly 5

week projection, and they can be modified long (b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 76

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

term or short term in response to holdovers;

however, the short term modifications are more

problematic to absorb thus contributing to the

holdovers becoming a multiple day event.  Also

according to returning the birds to the farm

may contribute to higher losses which compounds

the problem. As was discussed previously, it is

not a good practice nor is it in the establishment’s

interest to hold birds overnight.  A previous

complaint was filed with the district office by an

observer that concerned holdover birds

understood, therefore, that FSIS will continue to

issue MOI for this matter. This memorandum

serves to document what was discussed and also

provide the Denver district office with information

concerning the operations being conducted at this

establishment.  A copy of this memorandum of

interview was provided to establishment

management, and the signed original will be

placed in the USDA files. 

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 77

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

15 M751 Pitman Farms Inc. (Moroni Turkey

Processing)

MMK2417

044820G

2018-04-20 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview to Discuss Birds Held

Over for Slaughter Norbest Turkey / Est# P01049 

Meeting Time: Friday, April 20, 2018 at 1600 

Attendees: 

USDA                                                            

Establishment 

                      

This meeting was necessitated by observations

made while performing a Good Commercial

Practices task on Friday, April 20, 2018. The

establishment protocol concerning live birds held

over is documented in both their Animal Welfare

Program and also SOP #307 Live Bird Holdover. 

The written procedure pertains to an unscheduled

live bird holdover due to a deviation such as a

breakdown or shutdown and

  Thursday

Holdover (approx. 1,000 toms) A trailer and a

partial trailer load of toms (trucks #78 and 59)

were held over from Thursday morning to Friday

morning.  According to , the deviation

in production causing the holdover was “due to

the late start experienced this morning in relation

to Sanitation issues.”  The start of operations in

evisceration was delayed on Thursday morning

due to deficiencies found during USDA

preoperational inspection. It was observed that

the partial trailer of toms was moved back to the

storage area with many of the coops of birds

remaining open.  Live birds were observed on the

ground under the trailer Thursday afternoon. 

Friday morning, when the trailer was brought into

the facility, live birds were found outside where

the trailer had been parked despite the

supervisor’s affirmation that all birds had been

collected and brought into production. The lead

supervisor for the 

 went back out and collected the loose

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

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

(b) (4)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 78

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Task

Code TaskName Status MOI Agenda

birds after I notified him not all had been

gathered.  Those birds would have remained loose

in the trailer storage area until Monday’s

production at the earliest had they not been

collected. As documented in previous MOI, issues

outside of mechanical breakdowns (a trend of

lower line speeds due to quality of birds, zero

tolerance failures, preoperational deficiencies, FPS

failures, etc) may be historical and anticipated

aspects of a particular poultry operation for a

prudent establishment to consider when planning

production.  As was discussed previously, it is not

a good practice nor is it in the establishment’s

interest to hold birds overnight.  A previous

complaint was filed with the district office by an

observer that concerned holdover birds.  

understood, therefore, that FSIS will continue to

issue MOI for this matter. This memorandum

serves to document what was discussed and also

provide the Denver district office with information

concerning the operations being conducted at this

establishment.  A copy of this memorandum of

interview was provided to establishment

management, and the signed original will be

placed in the USDA files. 

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 79

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Task

Code TaskName Status MOI Agenda

50 M791C Clemens Food Group, LLC QCF55090

30128G

2018-03-28 04C02 Livestock

Humane

Handling

Finalized met with M791C 

 from approximately 1000 to 1015 hours

in the west alleyway of the barn today

(03/28/2018). Also in attendance was 

. Discussed during this

meeting were observations has made

concerning hog movement at the entrance of the

serpentine. Of note were observations

that the leading hogs in a group being moved

fairly consistently balk at the vertical opening gate

(with it's bottom consisting of an approximately 3

foot high black rubber flap) that separates the

main central alleyway in the barn from the

serpentine. When the vertical gate is in the full

open position the opening through which the

hogs must pass is approximately three feet high.

Other than when exiting a trailer this is the first

location in the barn where hogs are required to

pass through a more “confined” opening. Usually

two barn employees drive the hogs into the

serpentine from the main alleyway but because of

the balking, this movement is often done with at

least some difficulty for the initial hogs as they

approach this opening. Once a few hogs have

traversed this opening, the remainder of the hogs,

in most cases, seem to follow without much

difficulty or hesitation. also discussed

the inefficiency and often times inability to drive

larger groups of hogs from the rear, especially at

this location. As far as the opening is concerned,

 indicated that he is aware of this potential

bottle neck location. indicated that

he had previously tried cutting a few inches off

the bottom of the flap to increase the opening

height. indicated that this helped a

little but not sufficiently so. He is planning as a

next step to paint the rubber flap a grey color so

that it blends in more with the overall grey

surroundings. He is hoping that the grey will make

the upper limit of the opening (now demarcated

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

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

(6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 80

Dist

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Task

Code TaskName Status MOI Agenda

by the black rubber flap) less noticeable to the

hogs and thus hoping that they will have less of a

tendency to balk at this location.

15 M9252 Bright Oak Meats, Inc. GHD29170

43618G

2018-04-18 04C02 Livestock

Humane

Handling

Finalized A customer attempted to unload a

non-ambulatory cow and attempted to pull its

tail. The CSI and plant personnel stopped the

customer before the tail was touched or any other

potentially harmful actions taken. The animal was

humanely euthanized and discarded. Plant

management immediately discussed the incident

with the customer and informed the customer

that this was unacceptable behavior. Plant

management will follow-up with additional

written information to this customer as well as

provide general humane handling information to

all customers to inform them of the expectations

of appropriate animal handling at the

establishment and in accordance with USDA

regulations.
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 81

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Task

Code TaskName Status MOI Agenda

15 M9289 Oregon Beef Co. AKG16150

21601G

2018-02-01 04C02 Livestock

Humane

Handling

Finalized A lot of 6 longhorn bulls were slaughtered at

M9289 Oregon Beef Company on the morning of

2/1/18. The bulls’ horns were too wide to enter

the normal chute, so the animals were unloaded

from the owner’s trailer directly into a chute

specifically designed for longhorn cattle (“Joe’s

Longhorn Chute”) that the owner had provided.

The chute was placed flush with the trailer and

adjacent to the side entrance of the kill floor. The

first 5 bulls were unloaded and stunned

uneventfully. The sixth bull was unloaded

successfully into the chute. The bull was

positioned in the chute with its head facing away

from the building and its horns locked between

two rails of the chute. The chute contains a small

gate on the top that can be opened so the

animal’s head can be accessed. This gate is

approximately 32 inches wide by 36 inches high

and placed approximately 36 inches from the

bottom of the chute. The animal’s horns were

approximately 62 inches wide. The gate was

closed but unlatched as the employee performing

stunning was about to shoot the animal. The bull

made a sudden movement to butt open the gate,

turned its head sideways, and leapt out of the

opening. It then ran off premises and into the

grassy hills around the plant. Plant employees

immediately ran after the bull. Mr. Tom Jones,

plant manager, retrieved a high-powered rifle

equipped with a scope. When the bull was

spotted after approximately 15-20 minutes, Mr.

Jones was able to effectively shoot the bull with

one shot.   Appropriate facilities to unload, pen,

and restrain livestock are required for humane

handling. This incident was considered an

aberration from typical handling that occurs at

this plant and the bull exhibited very unique

behavior. However, should the escape of animals

from holding facilities become a routine

occurrence or should an animal be injured upon
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 82

Dist

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Task

Code TaskName Status MOI Agenda

escape, the behavior could be considered

non-compliant or even egregious and further

enforcement action would be necessary.

35 P1009 Wayne Farms LLC DSM39150

20527G

2018-02-27 04C05 Poultry Good

Commercial

Practices

Finalized While doing a good commercial practices task, I

visited the live hang area and observed a live hang

employee hurrying along from the incoming

conveyor belt past the stunner with a live chicken

in each hand. He then proceeded to hang a

chicken by one leg just before the automatic kill

machine and back up killer. It seemed he couldn't

find another empty shackle to place the other bird

in, so he walked back to the live hang conveyor

area with the other bird. The hung bird

was noticed by the back up killer and able to be

bled out. The bird that was hung on the line,

wasn't stunned prior to being slaughtered.

There is some room for improvement in this case.

I discussed the issue with 

 and 

counseled the employee to not hang birds past

the stunner and to hang the birds by both legs in

a single shackle.

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 83

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Task

Code TaskName Status MOI Agenda

50 P1209 Whitewater Processing Co. FFG280805

1604G

2018-05-04 04C05 Poultry Good

Commercial

Practices

Finalized Est. P1209 Whitewater Processing Co. At 0903

hours while observing birds entering the scald

tank as part of a routine DVMS GCP audit, 

 observed the following. An old breeder

turkey (hen) was observed to be breathing on the

production line just before the scald tank. 

 alerted of the finding, and 

 hit the kill switch in the immediate area to

stop the production line. She then left to retrieve

a knife. When returned to the area, she

was joined by an establishment employee, who

re-cut the hen??s neck and then removed the bird

from the production line and carried her away.

The line was then restarted. observed

this area for an additional 12 minutes without

further incident. The stunning and sticking area 

was then observed. No issues were identified. The

observations were discussed during the exit

meeting of the audit. Exit Meeting 1020 hours in

attendance Establishment Management- 

, FSISand .

50 P1209 Whitewater Processing Co. FFG191305

4309G

2018-05-09 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1412 while observing live hang

at the end of the kill last truck pulled out of the

live hang dock. As the truck pulled out I noted a

breeder Tom between the rear wheels he has still

alive and moved briefly after the wheel passed

over and crushing him. I also noted a breeder hen

also alive who was sitting on the ground in the

center of the dock area where the trailer had

passed over her. I instructed a plant employee to

retrieve the bird and he hung it on the kill

shackle. I informed immediately

following the incident and informed her I was

issuing a GCP MOI.

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

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

(b) (6)

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

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 84

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Task

Code TaskName Status MOI Agenda

50 P1241 Tyson Foods, Inc. MGJ31150

14323G

2018-01-23 04C05 Poultry Good

Commercial

Practices

Finalized Poultry Mistreatment MOI At approximately

1455 hours, while performing a Poultry Good

Commercial Practices task on the Live Receiving

dock, I observed an establishment employee

dump a coop of chickens onto the live hang belt.

After he dumped the coop, I observed a live

chicken that remained in the coop. The coop was

then removed from the dump system and

replaced back onto a trailer of empty coops. I

informed the forklift driver that there was a live

chicken still in the coop, and he retrieved the

coop and removed the live chicken from it. I

immediately informed 

 and 

of my finding and of the impending

MOI. This finding was not in accordance with

Poultry Good Commercial Practices because the

chicken would have remained in that coop for an

extended period of time. At approximately 1710

hours, I met with and asked him

what actions were taken to prevent a

reoccurrence of this incident. informed

me that was going to have a

meeting with all of her live hang employees at the

next scheduled break, and she was going to

inform each of these employees to make a visual

inspection of each coop after dumping it, to make

sure that no live chickens remained in the coop. 

,

Est.1241-P Corydon, IN 47112

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

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 85

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Task

Code TaskName Status MOI Agenda

50 P1241 Tyson Foods, Inc. MGJ26210

15224G

2018-01-24 04C05 Poultry Good

Commercial

Practices

Finalized Poultry Mistreatment MOI At approximately

2215 hours on Wednesday, January 24th, while

performing a Poultry Good Commercial Practices

task on the Live Receiving dock, I observed an

establishment employee dump a coop of chickens

onto the live hang belt. After he dumped the

coop, I observed a live chicken that remained in

the coop. The coop was then removed from the

dump system and replaced back onto a trailer of

empty coops. As that same employee dumped the

next coop of chickens onto the live hang belt, I

again observed a live chicken that remained in

that coop. I immediately informed the forklift

driver and

of my findings. The forklift driver

removed the live chicken from the coop that had

been placed back on the trailer, and

instructed the employee working the

dump system to remove the live chicken that

remained in the second coop. Once I observed

that the chickens had been removed from the

coops, I then informed 

, and 

 of my findings and of the impending

MOI. This finding was not in accordance with

Poultry Good Commercial Practices because the

chickens would have remained in those coops for

an extended period of time. I had already issued

a MOI for the same finding the night before this

incident occurred. I also had just addressed this

same issue in the weekly USDA/Establishment

meeting earlier this afternoon. 

informed me that the establishment employee

working the dump would receive a written

reprimand for failing to ensure that all chickens

were emptied from the coops at the time they

were dumped. also informed me

that additional measures would soon be

implemented in an attempt to prevent this from

happening again. One such measure will be the

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

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

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 86

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Task

Code TaskName Status MOI Agenda

installation of a mirror which will enable the

employees working the dump system to see

inside the coops after they are dumped. 

, Est. 1241-P 

Corydon, IN 47112

80 P1243 Perdue Foods, LLC. XLB370804

1418G

2018-04-18 04C05 Poultry Good

Commercial

Practices

Finalized While performing the good commercial practice

task at approximately 0649 hours on 04/18/2108,

I observed a live bird in the DOA bin.  It was on

top of the pile and had denaturant on its feathers

and body.  I observed the bird blink its eyes and

move its head.  

 was walking by at the time and I called

out to him.  As he approached, I asked him to look

at this bird.  He picked the bird up and saw that it

was breathing, moving its head, and blinking.  He

agreed that it was alive.  At this time, he had the

bird humanely euthanized via cervical dislocation. 

  I prepared this report on 04/18/2018 and I

certify that this report has recorded in it a

summary of all pertinent matters discussed. 

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

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 87

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Task

Code TaskName Status MOI Agenda

90 P1254 Koch Foods of Ashland, LLC YFA442002

0111G

2018-02-11 04C05 Poultry Good

Commercial

Practices

Finalized On February 9, 2018 at approximately 2111 hours

while performing the Good Commercial Practices

and Ante Mortem task with the

following was observed outside where the

establishment disposes of DOAs.  A long transfer

belt is used to bring DOAs outside from live hang

and drops them into a metal basket prior to them

being disposed of in a final large metal dumpster. 

At the end of the belt in the basket there were

approximately 15 birds, two of which were alive. 

One of the live birds was very weak.  There were

dead birds on top of the live birds in the basket. 

Upon finding the live birds intermingled with the

DOAs and them being in imminent danger of

becoming crushed/suffocating/death by means

other than slaughter, I asked to notify a

Supervisor since there was no one in the area. 

DOAs (approximately 7) continued to pile on top

of the live birds while waiting for assistance.  

 an establishment employee and 

 arrived

to the area and was

informed of the issue.  One of the live birds was

returned to production and the other bird was

humanely euthanized.  The Supervisor was also

notified that a GCP MOI would be issued.     The

establishment is responsible for ensuring that

birds under their control on the official premises

are treated in a humane manner that will

minimize excitement, discomfort, injury and/or

death by means other than slaughter. As per

Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live

Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of

poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

Practices (GCPs) as described by industry

guidelines.  My observations are consistent with

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

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 88

Dist

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Task

Code TaskName Status MOI Agenda

less than Good Commercial Practices. A copy of

this Memorandum of Interview will be forwarded

to appropriate personnel in the District Office.  

Respectfully submitted on February 9, 2018 

 Cc: 

 Dr. David Thompson, DDM 

85 P1272 Pilgrim's Pride Corporation CCA420802

1108G

2018-02-08 04C05 Poultry Good

Commercial

Practices

Finalized Todd Shoemak, Plant Manager Pilgrim's Pride

Corporation P-1272 113 McNeal Drive Douglas,

GA 31533 On Wednesday, February 7, 2018 at

approximately 1718 hours while performing a

Good Commercial Practices Task at P-1272 I, 

 observed an issue with the

implementation of Good Commercial Practices in

the live hang/receiving area. I observed one live

bird enter the scald vat on line number one alive.

The bird was holding its head up and blinking. I

notified 

of the observation. stated he would

be switching out backup killers immediately as a

corrective action. No other live birds were

observed entering the scald vat alive. This issue

was discussed with management at a small

meeting in the USDA veterinarian’s office shortly

after the occurrence. 

 and

 were present.  

stated the matter would be addressed

immediately. Respectfully, 

(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 FOIA2018-328 10:22 Wednesday, May 30, 2018 89

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Task

Code TaskName Status MOI Agenda

85 P1272 Pilgrim's Pride Corporation CCA420904

2218G

2018-04-18 04C05 Poultry Good

Commercial

Practices

Open Mark Dean, Plant Manager Pilgrim's Pride

Corporation P-1272 113 McNeal Drive Douglas,

GA 31533 On Monday, April 16, 2018 at

approximately 0840 hours while performing a

Good Commercial Practices Task at P-1272 I, 

, observed an issue with the

implementation of Good Commercial Practices in

the pre-evisceration area. After approximately 30

minutes of downtime in the pre-evis area on line

number one, I observed the stunner filled with

water. I immediately notified 

 of my concern of the stunner being

filled with water and birds still hanging on the line

in the water. The water was drained from the

stunner to reveal approximately 15 birds

deceased. Once observed, I immediately notified

,

, and

 all of which

observed this. All deceased carcasses

(approximately 15) were removed from the line

and verified as deceased. All previous mentioned

establishment personnel observed these birds as

being deceased. All deceased birds were placed in

the DOA bin for condemnation. This issue was

discussed with management at a small meeting in

the USDA veterinarian’s office shortly after the

occurrence.

and were

present.  stated that as a preventative

in the future, stunners will be drained

immediately and will not be refilled until

instruction is given from himself or another

supervisor in his absence. Also, it was stated that

in future instances, a designee will be assigned to

the area to ensure no one fills stunners before the

correct time. These things as stated by 

 were given as a preventative. 

Respectfully, 

(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 FOIA2018-328 10:22 Wednesday, May 30, 2018 90

Dist

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Task

Code TaskName Status MOI Agenda

85 P1284 Pilgrim's GDA21200

44524G

2018-04-24 04C05 Poultry Good

Commercial

Practices

Finalized Est. P-1284, Pilgrim’s April 24, 2018, 0138 hours.

 At approximately

0138 hours, while verifying Good Commercial

Practices in the live room, I 

observed a live chicken in the DOA trailer. The

chicken was beneath several layers of DOA’s. The

chickens head and neck were visible and I could

see the chicken slowly moving its neck. I

immediately called to

notify him of this finding, and he was

accompanied by establishment

 informed me that the

chickens often move their head and neck after

cervical disarticulation. I requested the chicken be

retrieved from the trailer. The chicken was

removed with a catch wire. The chicken opened it

eyes and was alive despite its thin and unkempt

appearance. elected to euthanize the

chicken by decapitation. I then notified

 of my

findings. I reminded that the PPIA

and Agency regulations do require that live

poultry be handled in a manner that is consistent

with good commercial practices (GCPs), and that

they not die from causes other than slaughter.

Poultry are also to be handled in a manner that

prevents needless injury and suffering in order to

produce a commercially marketable product.

Compliance with these requirements helps insure

that poultry are treated humanely. I

recommended that the Federal Register on

Treatment of Live Poultry before Slaughter,

published September 2005, be reviewed for FSIS

recommendations concerning treatment of live

poultry before slaughter. A copy has been

provided to the establishment. The establishment

will provide any planned actions with their

written response. This MOI will be forwarded to

the District Office and the District Veterinary

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

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 91

Dist

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Task

Code TaskName Status MOI Agenda

Medical Specialist (DVMS) in the event additional

follow-up is recommended. Respectfully, 

, P1284, Pilgrim’s

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 92

Dist

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Task

Code TaskName Status MOI Agenda

60 P1304 Farmers Pride Inc. YVB500001

3405G

2018-01-05 04C05 Poultry Good

Commercial

Practices

Open On 01/05/18 (shift started on 01/04/2018), at

approximately 0119 hours, a night shift  meeting

was held at establishment 1304P, Farmer’s Pride,

Inc., located at 154 West Main Street,

Fredericksburg PA, 17026. 

attended the meeting for USDA. 

), attended the

meeting for the establishment.  At approximately

0119 hours on 01-05-2018, I was

conducting a GCP audit in the live receiving/live

hanging area. While observing operations on the

live hanging area, I noticed that the birds taken

out of the coops and dropped onto the walking

stand by the live hanging establishment

employees, were making a rock like thump when

they hit the stand. I proceeded to further

investigate and noticed that most all of the

feathers were missing from the belly of the birds

and the birds were hard to the touch. A total of

five to seven birds appeared to be frozen birds.

Furthermore, two and one quarter barrels

containing birds identified by plant management

as DOA birds were present at the time of the

audit. Discussion during this meeting focused

on these observations during the GCP audit and

on the prolonged period of abnormally low

temperatures.  Night time temperatures in

Fredericksburg, Pennsylvania during the week of

December 31, 2017 thru January 6, 2018 were in

the single digits with daytime highs in the teens. 

In addition, the birds originated from a truck

intended to be processed during day shift

beginning on January 4, 2018 but was held over

because of production delays until night shift of

January 4, 2018 (approximately 11 hours). 

Moreover, there was a marked increase in the

total number of birds listed by the plant as DOA

and plant rejects identified in the lot that included

the birds from the truck that was held over. Lot

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 93

Dist

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Task

Code TaskName Status MOI Agenda

#1 (DOA) = 38-Birds (Plant Reject) =453-Birds Lot

#2 (DOA) =32-Birds (Plant Reject) = 238-Birds 

Lot#3 (DOA) = 65-Birds (Plant Reject) = 70-Birds 

Lot #4(DOA) = 43-Birds (Plant Reject) = 956-Birds
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 94

Dist

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Task

Code TaskName Status MOI Agenda

90 P1307 Mar-Jac Poultry-AL KIL241301

5718G

2018-01-18 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 07:15 on January 18, 2018, I

observed less than Good Commercial Practices

(GCP) while performing

Antemortem/GCP/Mishandling verification at

Mar-Jac Poultry in Jasper, AL.  I observed a large

pile of DOA carcasses (approximately three feet

tall and approximately two feet in diameter) on

the floor at the end of live hang belt #2.  At the

time of my initial observation, no one

was working to remove the DOA's from the area. 

I notified to stop the

hanging process on line #2 because the process

appeared to be out of control, and there could

possibly be live, weak chickens trapped under the

pile of DOAs.  I also notified 

of the situation. 

As two live hang employees removed DOA

chickens from the pile, I observed three live

chickens being removed from the pile and placed

back on the hanging belt.  and 

also observed the finding of these live

chickens.  I notified that this is not

consistent with good commercial practices

because of the potential for the live chickens to be

suffocated and die from causes other than

slaughter.  I further notified him that the findings

would be documented on a GCP MOI.  While the

live employees on line #2 were completing the

cervical dislocation of the pile of chickens, I

observed that there was an accumulation of

DOA's at the end of line #1(approximately 2 feet

high and approximately one foot in diameter). 

Three live chickens were removed from this pile

and hung on the line. Federal Register Notice

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

"Treatment of Live Poultry Before Slaughter"

states that under the Poultry Products Inspections

Act (PPIA) and Agency Regulations, all

establishments engaged in the slaughter of

poultry to make every effort to treat poultry

(b) (6)

(b) (6)

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(b) (6)
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humanely and abide by Good Commercial

Practices. cc: 

90 P1317 Wayne Farms LLC QUI121301

4826G

2018-01-26 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 10:01, on January 26, 2018,

while performing the Review and Observation

component of the PHIS task, “Poultry Good

Commercial Practices,” I, along with Guntersville

,

observed three live birds covered by and

comingled with dead birds in a pile on the floor at

the end of the live bird belt.  

 was notified of the finding

and implemented corrective action(s).   As per

Federal Register Notice Docket No. 04-037N

dated September 28,2005, 'Treatment of Live

Poultry before Slaughter," the Food Safety

Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of

poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

Practices (GCPs) as described by industry

guidelines.   Corrective and preventive measures

addressing this incident are appropriate. I look

forward to your response.   Respectfully

submitted,   P-1317   

Cc:         Dr. Lorraine

Dozier, Acting DDM        

(b) (6)

(b) (6)

(b) (6)

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90 P1317 Wayne Farms LLC QUI221702

0702G

2018-02-02 04C05 Poultry Good

Commercial

Practices

Finalized TO: Mr. BRYAN ELROD, Plant Manager Wayne

Farms LLC. 700 McDonald Ave. Albertville AL,

35950 FROM: 

Dear Mr. Elrod, At approximately 16:30 hours, on

February 2, 2018, while performing the Review

and Observation component of the PHIS task,

“Poultry Good Commercial Practices,” I,

observed one live bird covered by and comingled

with dead birds in a pile on the floor at the end of

the live bird belt

and 

 were notified of the finding and

implemented corrective action(s).   As per

Federal Register Notice Docket No. 04-037N

dated September 28,2005, 'Treatment of Live

Poultry before Slaughter," the Food Safety

Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of

poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

Practices (GCPs) as described by industry

guidelines.   Corrective and preventive measures

addressing this incident are appropriate. I look

forward to your response. A copy of this

Memorandum of Interview will be forwarded to

appropriate personnel in the Jackson District

Office

, Acting DDM 

 Respectfully submitted,   

                                                                         

Albertville 02/02/2018

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

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(b) (6) (b) (6) (b) (6)
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90 P1353 Pilgrims Pride Corporation WUM3902

023005G

2018-02-05 04C05 Poultry Good

Commercial

Practices

Finalized On February 5, 2018 at approximately 0255

hours, while performing a Good Commercial

Practice Check, I observed a pile of dead birds at

the end of the live hang belt. The pile had reached

the belt itself and was approximately 3 feet in

height. I immediately notified 

 and instructed that he

cease hanging birds until the pile of birds was

taken care of. Two live birds were on the top of

the pile, but no additional live birds were

uncovered when transferring to a DOA container.

The inattentiveness of plant personnel put live

birds at risk of dying of means other than by

slaughter. Under my observation, the plant

employees finished disposing of the dead birds at

approximately 0300 hours and resumed hanging

at that time. 

was notified that a MOI would be filed

with the Jackson District Office. Per Federal

Register Docket #04-37N, the establishment is to

treat poultry in a manner consistent with good

commercial practices and take steps to prevent

the mistreatment, harm, distress and injury by

means other than slaughter. Also such abuse of

poultry and treatment in a manner not consistent

with good commercial practices, and death by

means other than slaughter, may render the

poultry adulterated. Respectfully submitted, 

 Cc: Dr. David Thompson,

DDM; 

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

85 P1480 Tip Top Poultry, Inc. JBA091903

5108G

2018-03-08 04C05 Poultry Good

Commercial

Practices

Finalized This MOI is for P-1480 Tip Top Poultry at

approximately 1635 on 03/07/2018. Attendees at

the meeting wer

),

) and 

). At approximately

1730 asked me ) to

come to the picking room. 

informed me that she had observed 5 birds that

were entered the scalder alive. notified

. and I observed

500 birds. We both observed 3 birds that were

vigorously moving when entering the scalder. I

notified that I observed several

birds moving vigorously when in the scalder. I

mentioned to that I would give

him five minutes due process. I returned to the

picking room at approximately 1740 -1745 with

and I observed several birds vigorously

moving as they entered. We also observed several

birds that did not have the neck cut enter the

scalder moving violently and water being splashed

on us. said that he would adjust

the kill line speed. I again checked another 500

birds at 1750-1755 and observed several birds

moving violently once into the scalder. 

 said he would adjust the kill line speed

again. I again checked from 1800 -1817 and

observed 5 birds once into the scalder violently

moving and observed a bird entering the scalder

without the neck being cut. I mentioned to 

 what I had observed. 

said he was going to check and explain to the

backup cutter to cut the necks of the birds that

miss the kill blade. I performed a 500 bird check

at approximately 1830 and and I

observed a bird enter the scalder without the neck

being cut and observed the bird moving violently

(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)
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in the scalder. I took regulatory control and said

to to stop the live hang area.

 said he is stopping the live hang

area and asked me if we could take an early

lunch. We took an early lunch break. I mentioned

to that production in the

evisceration area would not resume until

management could assure me that they could

control this process. I met with ,

and At approximately 1930 I

performed a 500 bird count and did not observe

any birds moving as they entered the scalder. At

approximately 2145 I performed a 500 bird count

and did not observed any birds moving when in

the scalder. I performed a 500 bird check at 2300

hours and did observe any birds moving at all

once entering the scalder.

90 P164 Tyson Foods Inc IJM261201

3515G

2018-01-15 04C05 Poultry Good

Commercial

Practices

Finalized Excessive DOA, weather related 7.5% for the day's

production. IPP did not observe any moribund

birds that were handled contrary to Principles of

Good Commercial Practices. All were euthanized

in accordance with AVMA humane methodology.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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90 P164 Tyson Foods Inc IJM120802

5014G

2018-02-14 04C05 Poultry Good

Commercial

Practices

Finalized , On February 12, 2018 at

approximately 0540, I, ,

observed less than Good Commercial Practices

(GCP).  In the Picking Room while performing a

Good Commercial Practice Task, I observed a live

small chicken, prior to entering the Scalder, with

its head lifted up, eyes wide open and then it

entered into the Scalder on Line   I

immediately brought the matter to the attention

of .  

and I went back into the picking

room and waited for the bird to exit the Scalder. 

 and a Plant employee got the carcass

in question off the Picking Line after the carcass

exited the Scalder and the first Picker.  Upon

closer observation the carcass was red in

appearance, with lots of blood under the skin in 

the neck area.  No visible cut was present to the

neck.  This finding is consistent with a Cadaver, 

having died by means other than slaughter.  

 was notified at 

approximately 0544.  notified 

 at 00164—P, of her findings

while performing the GCP Task.  At approximately

0640 Mr. Ricky Meyers, Assistant Plant Manager

at P-164 was notified verbally of a GCP MOI that

would be written. Allowing birds to enter the

Scalder live is not consistent with Good

Commercial Practices and bird(s) dying by means

other than slaughter results in adulterated

product.  Every effort must be made by the

Establishment to prevent live bird(s) from entering

the Scalder, and measures to prevent

mishandling of poultry must be adhered to by the

Establishment to ensure unnecessary suffering by

poultry under the Establishment’s control. Refer

to FSIS Docket No. 04-37N, Treatment of Live

Poultry before Slaughter. ,

00164--P Forest, Ms CC. 

,

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

(b) (6)

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

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (4)
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40 P165H OK FoodsProcessing Plant DAF42070

25727G

2018-02-27 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0623 on 2/27/18, while

performing a good commercial practice check, I

observed a sensible bird (eye open) proceeding

down the line and into the line 2 scalder.  

 was notified of my

observation.  We traveled down the line and

observed a cadaver exit the pickers.  

removed the cadaver from the line, examined it

and notified me that there was no cut on the

neck.  Shortly thereafter, I performed a recheck

and observed zero sensible birds prior to the

scalder.  During the discussion that followed, 

 and

 notified me that both employees

past the automatic knife would be retrained and

be disciplined according to company policy.

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

(b) (6)

(b) (6) (b) (6)
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40 P165H OK FoodsProcessing Plant DAF02040

52216G

2018-05-16 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2036 hours, while performing

ante mortem in the live shed, I noticed a bird that

had its head caught in between the door and the

cage cell side. The bird was not showing any signs

of life at the time of my observations. The live side

employee also saw this and immediately began

trying to open the door to free the bird’s head.

Although he was able to free the bird’s head, the

bird was not alive due to the crushing of the

throat in the extremely narrow space that exists

between the door and the side wall of the cage

cell. I immediately located who works

for the live side department of OK Foods. I

explained to my observations and

concerns for the welfare of the chickens. 

 stated that he would address this with the

appropriate people on live side. I also informed

 of

my observations. USDA’s concerns are that the

employees are not being watchful when the

chickens are loaded into the cages, which has

resulted in the strangulation type death as seen

today. Last week, both live side and the

establishment were notified 4 out of 5 nights for

cage doors being open on cages loaded with birds.

USDA is concerned that the continued situation

with the doors may result in additional birds

being seriously injured. The establishment is

encouraged to reply to this MOI.

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

(b) (6)
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35 P165S OK Foods, Inc. LWA00060

15303G

2018-01-03 04C05 Poultry Good

Commercial

Practices

Finalized On Tuesday, January 02, 2018, at approximately

0525 hours, while performing the Good

Commercial Practices Task, I observed DOAs, too

numerous to count. It was 17 degrees F. The

trailers of birds had shield boards on the front end

and back end of the end cages, and side shield

boards on approximately 1/4 of each cage, leaving

3/4 of each cage exposed to the weather

conditions. I met with 

 about the conditions and my concern of

numerous DOAs. I asked if there

were additional ways to keep the birds warm. He

stated that there wasn't. I met with

, to inquire of actual

counts of DOAs. presented me with

the record that indicated a high number of DOAs

in the morning weather conditions, and quite a

significant reduction as weather temperatures

warmed. had also met with Plant

Manager Amelia Lawhorn regarding this issue.  He

had requested information regarding the distance

the birds were hauled and if the trailers were

going to be tarped or if there were some other

measures going to be implemented to protect the

birds from the cold.  She said that she would have

to get with Live Haul for that information.  She

returned to the USDA office approximately 7AM

Wednesday.  She said that she was told that the

birds had been hauled about 50 miles and that

the trucks stopped for 15 minutes about half way

to let the birds warm up.  asked how

stopping alongside the road would allow the birds

to “warm up” when the temperature was in the

mid teens.  wasn’t sure.  She stated that

she was relaying information that had been given

to her. also asked about if/when

measures were going to be taken to protect the

birds from the cold.  She said that they were going

to begin adding boards to the outside of the

cages.  She said that they may have done some of

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (b) (6)
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them.    stated that as he was coming to

work this morning (Wednesday, 1-3-18) he met

two live haul trucks on their way out.  He didn’t

see any protection on the cages of either trailer. 

However, they were empty.

90 P17766 Southern Hens, Inc SSN441501

0031G

2018-01-31 04C05 Poultry Good

Commercial

Practices

Finalized Good Commercial Practices MOI: On January 30,

2018 at approximately 1338 hours, 

 and  observed a less

than good commercial practice while performing

Ante-mortem inspection and a Good Commercial

Practices check at Establishment P-17766. While

performing a 500 bird count, a live, uncut bird

was observed entering the scalder. The bird was

lifting its head in an attempt to right itself as it

approached and entered the first scalder. 

 was

immediately notified of this finding. In accordance

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

Poultry before Slaughter, live poultry must be

handled in a manner that is consistent with good

commercial practices. In order for this to occur,

poultry must be treated in a manner that will

minimize excitement, discomfort and accidental

injury throughout processing. A copy of this

Memorandum of Interview will be sent to the

Jackson District Office for further review. Thanks

for your attention to this matter. Respectfully, 

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

(b) (6)

(b) (6) (b) (6)
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90 P17766 Southern Hens, Inc SSN281502

1612G

2018-02-12 04C05 Poultry Good

Commercial

Practices

Finalized Good Commercial Practices MOI: On February 9,

2018 at approximately 1020 hours, 

 and 

and I observed less than Good Commercial

Practices while performing a routine Ante-mortem

and Good Commercial Practices audit at P-17766.

On the back loading docks, the workers were

aggressively tossing cages containing live hens

onto the conveyer belt that feeds into the live

hanging room. The cages were being tossed from

stacks ~10ft high, as well as ~3.5ft from left to

right. The metal unloading chutes were not in use

at the time. We immediately informed 

 and 

of this mistreatment; each manager

was accompanying us as we were performing the

GCP task. In accordance with FSIS Docket No.

04-037N, Treatment of Live Poultry before

Slaughter, live poultry must be handled in a

manner that is consistent with good commercial

practices. In order for this to occur, poultry must

be treated in a manner that will minimize

excitement, discomfort and accidental injury

throughout processing. A copy of this

Memorandum of Information will be sent to the

Jackson District Office for further review. Thanks

for your attention to this matter. Respectfully, 

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

(b) (6)

(b) (6)

(b) (6)
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90 P17766 Southern Hens, Inc SSN171203

3416G

2018-03-16 04C05 Poultry Good

Commercial

Practices

Finalized On March 15, 2018 at approximately 0750 hours,

I observed less than Good Commercial Practices

while performing a routine Ante-mortem and

Good Commercial Practices task at P-17766. On

the back loading docks, a worker was aggressively

tossing cages containing live hens onto the

conveyer belt that feeds into the live hanging

room. He was working without any assistance

from other back dock employees.  The cages were

being tossed from stacks ~10ft high, as well as

~3.5ft from left to right. The metal unloading

chutes was not in use at the time.  

 was immediately

informed of this mistreatment. In accordance with

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

Poultry before Slaughter, live poultry must be

handled in a manner that is consistent with good

commercial practices. In order for this to occur,

poultry must be treated in a manner that will

minimize excitement, discomfort and accidental

injury throughout processing. A copy of this

Memorandum of Information will be sent to the

Jackson District Office for further review. Thanks

for your attention to this matter. Respectfully, 

,

(b) (6)

(b) (6)

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60 P18414 MB Consultants LTD JYI4207025

901G

2018-02-01 04C05 Poultry Good

Commercial

Practices

Finalized While performing ante-mortem inspection at

0828, IPP observed a blue rubber glove in a crate

with chickens on truck #148 between the bottom

crate and second crate on the right side of the

trailer in the second column.  The blue fingers of

the glove were extending into the bottom crate.
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60 P18414 MB Consultants LTD JYI5608032

928G

2018-03-28 04C05 Poultry Good

Commercial

Practices

Finalized On 03/27/2018 at 14:55 I was conducting a

routine Poultry Good Commercial Practices task.  I

observed the chickens entering the bleed-out

loops from the kill room by looking through the

small window in the hallway where the kill line

shackles return to live hang from the bird transfer

machine.  I noticed that one chicken was still

attempting to right itself near the end of the first

loop although its neck had been cut and it was

visibly bleeding. I continued to watch to confirm

that the chicken had stopped trying to right itself,

but the chicken was still attempting to right itself

when it reached the end of the second loop.  The

third loop is not visible from the window in the

hallway, so I ducked under the kill line to walk

through to the rooms with the scalding vats in

order to confirm that the chicken was dead before

it entered the water.  As the chicken entered

through the doorway from the bleed out room, it

was still attempting to right itself, and as it

entered the cold water vat, it was struggling

violently.  On exiting the cold water vat, the

chicken was coughing up water and shaking its

head from side to side. At this point I chose not to

continue to observe the chicken as it entered the

first scalding vat still alive. No other chickens

were observed to be attempting to right

themselves after their necks were cut, and this

was the first time that I have observed an animal

entering the water vats while still alive. In

accordance with 9 CFR 381.65(b), Poultry must be

slaughtered in accordance with good commercial

practices in a manner that will result in thorough

bleeding of the carcasses and ensure that

breathing has stopped prior to scalding. 

Furthermore, in accordance with 9 CFR

381.1(d)(v) a poultry carcass is considered

adulterated if it has died other than by slaughter

as would be the case with a chicken that died by

drowning in the scalder. As a reminder, our
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expectation is that all live poultry should be

treated in a manner consistent with good

commercial practices, which means they should

be treated humanely.
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90 P18557 Sanderson Farms, Inc. QNA31060

31229G

2018-03-29 04C05 Poultry Good

Commercial

Practices

Finalized On March 29, 2018 at approximately 0615, 

, observed less than Good

Commercial Practices while performing an

Ante-Mortem Inspection and Good Commercial

Practices check at 18557 P in Summit, MS. While

observing the kill machine of each picking line for

proper function, I did not observe any

abnormality in the equipment's operation. I did

observe several of the birds on line 1 were only

being hung by one leg and the employee was

having some difficulty addressing the birds that

were missed by the kill machine. I walked to the

end of the blood trough to observe for any live

birds entering the scalder. I observed a single, live

 bird at 0615 enter the scalder on picking line #1.

The bird was hanging on the shackle with its eyes

open, still breathing, and without a cut on its

neck. This bird entered the scalder alive and still

breathing.  I did not take any regulatory action

with this single-bird incident, since no evidence of

a system failure existed. I notified 

, of the

observed nonconformance, during a brief meeting

held in his office at approximately 0618. I

presented the cadaver to him, explained my

observation, informed him that a Memorandum

of Information (MOI) was going to be

documented, and relinquished the carcass into his

control. FSIS Docket No. 04-037N, Treatment of

Live Poultry before Slaughter, states that under

the Poultry Products Inspection Act (PPIA) and

Agency regulations, live poultry must be handled

in a manner that is consistent with good

commercial practices. In order to ensure that

poultry is handled and slaughtered in a manner

that is consistent with good commercial practices,

poultry should be treated in such a manner as to

minimize excitement, discomfort, and accidental

injury throughout processing.A copy of this

Memorandum of Information will be forwarded to

(b) (6)

(b) (6) (b) (6)
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the appropriate personnel in the Jackson District

Office. Respectfully, 

cc: , and  

 Jackson

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

(b) (6)

(b) (6)
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80 P19128 Case Farms of North Carolina, Inc. FCA430901

4227G

2018-01-27 04C05 Poultry Good

Commercial

Practices

Open On Saturday 1/27/18 at approximately 1006

hours I was returning to the inspection office after

performing ante-mortem evaluation of birds

presented for slaughter.  As I walked in front of

one of the trailers staged under the live dock

canopy I heard a loud "Bang" and then looked

down and saw at least one loose chicken under

the trailer.  I walked back around the trailer and

noticed an entire cage had dropped off the fork

truck from the 2nd tier of the trailer and it was

now sitting on its side next to the trailer.  I

observed that all 5 individual tiers of the cage had

open doors with several loose chickens on the

ground in front of it.  There were many more

chickens remaining in the tiers of the cage and

they were sitting on top of one another at least 2

to 3 birds deep.  I tried to communicate with the

fork truck driver regarding what happened but

due to a language barrier could not; however the

driver pointed up to the cage next to where that

one came from and I noticed the top right cage

door was open with chickens poking their heads

out.  I went to the dumper operator to see if he

had a radio but he did not so I entered the back

end of live hang.  I observed a maintenance

employee and I asked him to notify a supervisor

to come outside due to a cage falling.  He did

come out and radioed 

 to come to the back dock.  In the

interim I requested that an empty cage be placed

to begin unloading birds to reduce suffocation

deaths. Several more people arrived and began to

move birds however there was a lot of discussion

amongst them on how to proceed including

knocking the cage down for it to sit properly and

load onto the dumper platform.  However, I

interceded more than once informing 

 that while everyone was discussing what

to do birds were suffocating, i.e. no one was

trying to move birds during some of these

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

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 suggested that moving forward they

would include training for the associates on how

to address birds involved in a pile up situation

after ensuring personnel safety was not at risk.  I

conceded this was a good practice and I informed

 about the Federal Register

regarding treatment of live poultry before

slaughter. Also, I informed him that the

documentation of our discussion would be

forwarded to my supervisor and the DVMS in case

additional follow-up was necessary. Respectfully, 

(b) (6)

 P19128

(b) (6) (b) (6)
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90 P192 Pilgrims Pride Corporation OOB23190

22313G

2018-02-13 04C05 Poultry Good

Commercial

Practices

Finalized Establishment P-912 Prigrim’s Pride, February 13,

2018 @ ~1835 hr. At approximately 1835 hour,

while observing conditions during Ante mortem

inspection and Poultry Good Commercial practice

task,  I observed ~5 or more live birds lying

underneath a pile of approximately 3 feet high full

of dead birds and debris in the Live Hang area

from off the floor. The amount of birds

was ~ 50-75 that were on the floor, surrounding

the entire area. I could walk the area for full

inspection of the birds due to the pathway being

blocked by the birds; one person started to work

on removing the pile of birds from off the floor,

but it wasn’t sufficient enough to keep up with

the constant moving of birds on the conveyor belt

pushing more loose birds onto the floor and by

birds not being picked up at a reasonable amount

of time to make a significant difference. I took

regulatory action by instructing all live hanging

personnel to stop hanging immediately until the

live birds were removed from the floor and DOA

birds were cleared out enough to walk the

passageway for more observation. I informed the

 and 

 of finding live birds cluttered

among dead birds, and that it was not acceptable

due to discomfort and suffering of birds in such

conditions. I also told them that I will document it

as an MOI for failure of humane handling. 

 discussed to me that the plant would be

assigning additional personnel to the live hang

area to prevent such high numbers of birds on the

floor.  He also mentioned that he was not aware

of negligence concerning the high volume of birds

on the floor, and that he will be sure it doesn’t

happen again during the remainder of shift.

(b) (6)(b) (6) (b) (6)
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90 P192 Pilgrims Pride Corporation OOB32200

30315G

2018-03-15 04C05 Poultry Good

Commercial

Practices

Finalized On March 12, 2018 at 1835, while performing a

Good Commercial Practices (GCP) task, I observed

a live bird underneath a pile of DOAs.  The bird

was moving his leg and breathing.  I immediately

notified live receiving clerk and she immediately

removed the birds.  I asked to speak with the live

receiving supervisor, but was not able to because

he was hanging birds in the hanging pen.  The live

receiving clerk immediately notified the

supervisor of the noncompliance and informed

him that they would be receiving an MOI. The

establishment has failed to adhere to the Federal

Register 04-037N, which encourages those

involved in the slaughter of poultry to abide by

Good Commercial Practices.
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90 P20245 Equity Group Kentucky Division, LLC ISL112101

5424G

2018-01-24 04C05 Poultry Good

Commercial

Practices

Finalized On January 24, 2018 at approximately 0003 hours

while performing the Ante Mortem and Good

Commercial Practices Verification Task, the

following was observed in live hang at the distal

end of the belt under the shackles that feeds

evisceration line one.  There was a pile of

approximately 15-20 DOA birds with one live bird

towards the bottom of the pile that was weak,

moribund and in imminent danger of dying from

becoming crushed or suffocating.  When I first

entered live hang I approached the belt that feeds

evisceration line two first and used my flashlight

to check for any live birds intermingled with DOA

birds at the end of the belt as this has been a

previous issue at this establishment.  There were

only two DOAs on this belt.  I then approached

the belt that feeds evisceration line one and

discovered the large pile of DOAs.  There was no

floor person in the area working on the pile of

birds.  I started to look through the pile for several

minutes prior to a line lead and 

 arriving and removing the dead birds.  As

several layers of dead birds were removed I

discovered the live bird by shining my light on it.  I

pointed this bird out to the supervisor and

informed him that this would be documented in a

GCP MOI and was unacceptable to have live birds

intermingle with dead birds.  In depth discussions

have been had with Supervision / Management at

this establishment about this issue in the past. 

 The establishment is responsible for ensuring that

birds under their control on the official premises

are treated in a humane manner that will

minimize excitement, discomfort, injury and/or

death by means other than slaughter. As per

Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live

Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of

(b) (6)
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poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

Practices (GCPs) as described by industry

guidelines.  My observations are consistent with

less than Good Commercial Practices. 

Respectfully submitted on January 24, 2018 

 Cc: 

 Dr. David Thompson, DDM Dr. Lorraine

Dozier, acting DDM 

(b) (6) (b) (6) (b) (6)
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90 P20245 Equity Group Kentucky Division, LLC ISL120201

4424G

2018-01-24 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0135 hours on January 23, 2018

while performing the Good Commercial Practices

verification task, the following was observed at

the entrance to the scald tank.  A young chicken

was seen entering the scald tank with an uplifted

head, pupillary reflexes, rhythmic breathing,

controlled movements and a superficial cut that

only penetrated the skin (no vasculature was cut). 

This bird by-passed both of the establishments

head pullers thus entering the scald tank alive. 

Just after the start of this evenings shift

(approximately 2020 hour) I informed 

 that I had seen

numerous superficial cuts on the birds necks and

many birds were by-passing the first head puller

and it only would take one bird entering the scald

tank live to result in documentation.  An

additional verification was started at

approximately 0100 hour and the same

conditions were present and again this

information was relayed to plant supervision. 

When the bird went in alive at approximately

0135 an establishment maintenance worker with

a radio was in the area.  I had asked him to please

radio for me and let him

know a live bird just entered the scald vat. A

brief meeting was held in the USDA office and

 was notified that a GCP MOI

would be issued as well as live birds entering the

scald vat was discussed.  Live bird(s) entering the

scald system live is a less than Good Commercial

Practices and results in adulterated product. The

establishment is responsible for ensuring that

birds under their control on the official premises

are treated in a humane manner that will

minimize excitement, discomfort, injury and/or

death by means other than slaughter. As per

Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live

Poultry before Slaughter,” the Food Safety

(b) (6)

(b) (6) (b) (6)
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Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of

poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

Practices (GCPs) as described by industry

guidelines.  A copy of this Memorandum of

Interview will be forwarded to appropriate

personnel in the District Office.  Respectfully

submitted on January 23, 2018 

 Cc: Dr. David Thompson, DDM 

Dr. Lorraine Dozier, acting DDM 

(b) (6)

(b) (6)
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90 P20245 Equity Group Kentucky Division, LLC ISL420303

3902G

2018-03-02 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0130 hours on March 2, 2018

while performing the Good Commercial Practices

and Ante Mortem task, the following was

observed in live hang.  At the end of the belt

under the shackles that feeds evisceration line #1

there was a pile of 4 large/heavy birds.  Two of

the birds were dead, one of the birds on top of the

pile was alive and more alert, and the bird on the

bottom of the pile was barely breathing and could

not be observed well due to the other birds on top

of it.  There were no supervisors in the immediate

area or any “floor employees” to alert to the pile

of birds.  As part of the establishment’s previous

corrective actions to GCP MOI’s written for live

birds intermingled with DOAs they were to have a

floor person present at all times.  This has been

the fourth incident this week where a floor person

was not present and has been discussed with

management.  The bird on the bottom of the pile

was pulled partially out for closer observation. 

This bird was breathing agonal, was weak and

could not support its own neck in an upright

position.  An establishment employee was seen

and I flashed my flashlight at him.  Once he

approached I asked for him to please get a

supervisor for me.  By the time 

arrived the weak bird now was breathing

normally, sitting up and blinking now that it was

no longer being crushed/suffocated.  I informed

Supervision of my observations and that a GCP

MOI would be issued.  At approximately 0136

 and 

 arrived at the USDA

PHV office.  The above information was relayed to

them and it was also discussed again that live

birds should not be comingled with DOAs due to

imminent danger of birds becoming crushing and

dying by means other than slaughter. The

establishment is responsible for ensuring that

birds under their control on the official premises

(b) (6)

(b) (6) (b) (6)
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are treated in a humane manner that will

minimize excitement, discomfort, injury and/or

death by means other than slaughter. As per

Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live

Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of

poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

Practices (GCPs) as described by industry

guidelines.  My observations are consistent with

less than Good Commercial Practices. A copy of

this Memorandum of Interview will be forwarded

to appropriate personnel in the District Office.  

Respectfully submitted on March 2, 2018 

 Cc: Dr. David Thompson,

DDM 

(b) (6) (b) (6)
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90 P20245 Equity Group Kentucky Division, LLC ISL022104

5011G

2018-04-11 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0126 hours on April 11, 2018

while performing the Good Commercial Practices

verification task, the following was observed at

the entrance to the scald tank that feeds

evisceration line two.  A young chicken that was

much smaller than the remainder of the lot was

seen entering the scald tank with an uplifted head

that was moving from side to side, rhythmic

breathing, controlled movements with wing

flapping, blinking and a superficial nick that only

penetrated the skin (no vasculature was cut) to

the very front of the neck.  This bird by-passed

both of the establishments head pullers thus

entering the scald tank alive.  Verification of a 500

bird sample set was done shortly after the

incident was observed and no other live birds

were observed entering the scald vat alive. A

brief meeting was held with 

 to discuss the above and

he was notified that a GCP MOI would be issued.  

Live bird(s) entering the scald system live is a less

than Good Commercial Practices and results in

adulterated product. The establishment is

responsible for ensuring that birds under their

control on the official premises are treated in a

humane manner that will minimize excitement,

discomfort, injury and/or death by means other

than slaughter. As per Federal Register Notice

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

“Treatment of Live Poultry before Slaughter,” the

Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the

slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good

Commercial Practices (GCPs) as described by

industry guidelines.  A copy of this

Memorandum of Interview will be forwarded to

appropriate personnel in the District Office.  

Respectfully submitted on April 11, 2018 

 Cc: Dr. David Thompson,

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

15 P20251 Tecumseh Poultry, LLC PBM18100

22609G

2018-02-09 04C05 Poultry Good

Commercial

Practices

Finalized On 02/09/2018, at approximately 0940 hours,

 and

 observed the following Good

Commercial Practice (GCP) issue. In the

dead-on-arrival (DOA) barrel in the CAS room, IPP

observed a live bird (breathing, bright, alert,

responsive, and blinking) in the barrel, sitting on

top of dead birds. Live birds coming into contact

with dead birds in the DOA barrel is not consistent

with Good Commercial Practices. IPP

immediately showed 

the GCP issue. She removed the live bird

from the DOA barrel and placed the bird back on

the belt prior to the CAS system. The Poultry

Products Inspection Act and Agency regulations (9

CFR 381.65(b)) require that live poultry be

handled in a manner that is consistent with Good

Commercial Practices (GCPs). Compliance with

GCPs increases the likelihood of producing

unadulterated product. Poultry are to be handled

in a manner that prevents needless injury and

suffering in order to produce a commercially

marketable product. Establishment management

may review Federal Register notice “Treatment of

Live Poultry before Slaughter”, 70 Fed. Reg. 56624

(September 28, 2005) for FSIS recommendations

concerning the treatment of live poultry before

slaughter. This MOI will be forwarded to the

District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. Respectfully, 

 MPH, CPH

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

(b) (6) (b) (6) (b) (6)
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15 P20251 Tecumseh Poultry, LLC PBM58100

23809G

2018-02-09 04C05 Poultry Good

Commercial

Practices

Finalized On 02/06/2018, at 610 hours, while performing

ante-mortem inspection and Good Commercial

Practice task in the loafing shed for the “veggie”

trailers, I, , observed a Good

Commercial Practice mistreatment of young

chickens on trailer T325. The trailer had a

module on the bottom row with a compartment

that had damaged floor board. The floor board

was bent downward on one end of the

compartment creating a dip. This dip collected

several birds that were piling on each other. When

viewed on the side of the trailer, 3 birds can be

seen in plain view layered on each other to create

3 layers of birds. The bird on the bottom, under 2

other birds, was stretching its neck and was

open-mouth breathing. It was unable to move.

Further back toward the middle of the

compartment, there were also an unknown

number of birds on top of each other. One of

these birds attempted to unsuccessfully climb

(flapped its wings and moved its legs) out of the

dip onto the even surface of the floor board. At

639 hours, when I showed 

 of the mistreatment, the bird on the bottom

that was open-mouth breathing has died (stopped

breathing and did not move its head when I

manipulated its head and neck). 

stated that when the “veggie” lot is slaughtered,

she would have Trailer T325 be one of the first

trailers to be slaughtered. She also took a picture

of the mistreated birds. At 930 hours, I met with

 and

 to discuss this

mistreatment. The Poultry Products Inspection

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

require that live poultry be handled in a manner

that is consistent with Good Commercial Practices

(GCPs). Compliance with GCPs increases the

likelihood of producing unadulterated product.

Poultry are to be handled in a manner that

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
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prevents needless injury and suffering in order to

produce a commercially marketable product.

Establishment management may review Federal

Register notice “Treatment of Live Poultry before

Slaughter”, 70 Fed. Reg. 56624 (September 28,

2005) for FSIS recommendations concerning the

treatment of live poultry before slaughter. This

MOI will be forwarded to the District Office and

the District Veterinary medical Specialist (DVMS)

in case additional follow-up is recommended. 

Respectfully, 

(b) (6)
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15 P20251 Tecumseh Poultry, LLC PBM05140

45509G

2018-04-09 04C05 Poultry Good

Commercial

Practices

Finalized On 04/09/2018, at approximately 1003 hours,

while performing a routine Poultry Good

Commercial Practice Verification task, I, 

observed a live bird (bright, alert

and flapping its wings) in an inedible barrel in the

carousel room (where the hangers hang stunned

birds). The bird had its neck bent toward the

bottom of the barrel and laid in an almost vertical

angle. This barrel in the carousel room is often

used to hold birds that are dead-on-arrival (DOA)

and disposed of by the establishment hangers.

 and 

were in the area and were notified of this live bird.

 agreed that this bird was

alive, removed it from the barrel, and placed it

onto the conveyor belt to be stunned again in the

CAS machine. The Poultry Products Inspection

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

require that live poultry be handled in a manner

that is consistent with Good Commercial Practices

(GCPs). Compliance with GCPs increases the

likelihood of producing unadulterated product.

Poultry are to be handled in a manner that

prevents needless injury and suffering in order to

produce a commercially marketable product.

Establishment management may review Federal

Register notice “Treatment of Live Poultry before

Slaughter”, 70 Fed. Reg. 56624 (September 28,

2005), for FSIS recommendations concerning the

treatment of live poultry before slaughter. This

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended. 

Sincerely, 

(b) (6)

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

(b) (6)

(b) (6)
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15 P20251 Tecumseh Poultry, LLC PBM22090

40417G

2018-04-17 04C05 Poultry Good

Commercial

Practices

Finalized On 04/12/2018, at approximately 0600 hours,

while performing a routine Poultry Good

Commercial Practice Verification task, I, 

, observed three instances of bird

mistreatment on two “veggie” trailers in the

loafing shed. On trailer number 529, I observed a

bird with its left antebrachium being trapped

between a metal bar and the floor board of the

compartment above. Due to the anatomical part

being trapped, the bird was unable to lie down

and its breast was slightly held above the floor

board so that it appeared to be partially “hung”

by its trapped wing. On trailer T-797, I observed

two trapped birds. One of these birds had its left

distal antebrachium trapped between the hinged

door mechanism. The bird had attempted to

unsuccessfully free itself and was resting in an

abnormal position; the medial side (inner wing) of

the stretched out left wing and the left side of its

body were resting adjacent to the side of the

compartment. The other bird had its left foot also

trapped by the hinged door mechanism. I

observed the bird struggle to free its leg and flap

its left wing multiple times against the

compartment’s side bars, leading to an abrasive

injury on this wing. At 0630 hours, I met with

 and 

 to show them the mistreatments.

The birds were subsequently freed with only one

showing signs of visible external injury. The

Poultry Products Inspection Act and Agency

regulations (9 CFR 381.65(b)) require that live

poultry be handled in a manner that is consistent

with Good Commercial Practices (GCPs).

Compliance with GCPs increases the likelihood of

producing unadulterated product. Poultry are to

be handled in a manner that prevents needless

injury and suffering in order to produce a

commercially marketable product. Establishment

management may review Federal Register notice

(b) (6)

(b) (6) (b) (6)
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“Treatment of Live Poultry before Slaughter” 70

Fed. Reg. 56624 dated September 28, 2005, for

FSIS recommendations concerning the treatment

of live poultry before slaughter.                       

This MOI will be forwarded to the District Office

and the District Veterinary Medical Specialist

(DVMS) in case additional follow-up is

recommended. Sincerely, 

40 P206 Pilgrim's Pride Corporation KCC131201

2102G

2018-01-02 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1000 hours after identifying

three birds that appeared to be misbleeds, I

observed a large number of DOAs piled on the

floor in the Live Hang area.  There were birds piled

behind both hang lines (approximately 100 birds

total) as well as birds piled approximately 2 feet

high against the east wall.  Upon closer

observation, live birds (approximately 4-5) were

observed interspersed in with the DOAs.  Due to

the loss of process control, regulatory control

action was taken immediately by stopping both

lines. 

 and 

 were notified.  stated that he

did not know if the birds had been transported for

a long distance or had been at the complex for a

long period of time.  The area was experiencing

cold temperatures.  Regulatory control action was

relinquished at approximately 1025 hours after all

of the birds had been sorted and the area was

cleaned.

(b) (6)

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

(b) (6)
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40 P206 Pilgrim's Pride Corporation KCC480805

4202G

2018-05-02 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1200 hours, on my way to

re-inspect the offal trailer area, I immediately

noticed a cage with major damage on a trailer

that was waiting to be picked up and reloaded. I

went back to the USDA office and requested Plant

Manager Tonya Byers to walk with me so that I

could show her the cage. As we approached the

trailer, I showed Ms. Byers the damaged cage.

One of the metal sides of the cage was bent

outward leaving an approximate 4-5” gap

between the metal and the cage floor. The metal

was bent in an arc shape which would allow for a

chicken to get caught in this gap and injure itself.

Depending on the size of the chicken, a medium

size chicken could fall out of the cage through this

gap. I continued then to show her other cages

with minor damage to them. I asked her if anyone

was supposed to be identifying these cages so

that they could be repaired. She told me that they

did have someone that was supposed to be

identifying these cages. As we were standing there

discussing the issue, a semi backed up to the

trailer and hooked up to it to take it to a farm and

reload. Ms. Byers immediately spoke to the driver

and told him that he could not take this trailer. I

then showed her another trailer that had several

of the wires broken on the metal frame. The

broken ends of the wires were sharp and pointed.

They were also angled inward which could cause

injury to a bird. Approximately 4 weeks ago, I

was covering for and noticed several

damaged cages on trailers that were going to be

reloaded with chickens. At that time, I informed

and showed 

 the damaged cages. Yesterday,

4/30/18, I also noticed numerous damaged cages

on trailers that were waiting to be reloaded. I

informed of my findings at that

time. On both occasions, 

informed me that he had spoken to the necessary

(b) (6)

(b) (6)

(b) (6) (b) (6)
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employees to ensure that these cages were being

identified and removed for repair. The

observations that were made today indicated that

the employees are continuing to fail in identifying

cages with major damage. USDA’s concerns are

that cages with major damage in which a bird

could be injured are not being removed from

circulation for repair but instead are being refilled

and putting more birds at risk of injury. The

establishment has not been proactive in

addressing this issue since it was discussed with

them approximately 4 weeks ago and yesterday.

USDA encourages the establishment to respond to

this MOI.
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40 P206 Pilgrim's Pride Corporation KCC241405

0404G

2018-05-04 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1350 hours, while performing

ante mortem on Lot 3 at the back dock area, I

observed a chicken with its head caught in an

approximate 2” gap. The chicken had its eyes

closed and the mouth was opening in a gasping

motion. I immediately had the driver radio for a

management team member

 arrived and I showed him the chicken

that was caught in the gap. The wires on the cage

were bent at an angle which allowed for this gap

to be created. I requested that the cage be gently

removed from the trailer and placed on the

ground so that the birds head could be freed. 

 had the employee gently place the

cage on the ground and then gently freed the

bird’s head. I expressed my concern to 

 about the cages having both major

and minor damage that could injure birds on

several occasions (week of 3-11-2018, Monday

4-30-18, and 5-1-2018). On Tuesday, 5-1-2018, a

MOI was issued to the establishment for the

failure to identify and repair cages with sufficient

damage that would cause injury to a bird. At that

time, I encouraged the establishment to respond

to the MOI and implement a program that would

identify these cages to prevent unnecessary injury

to a bird. USDAs concerns are that the

establishment is not being proactive in addressing

these cages in which birds can become injured,

which has resulted in this incident today. I

strongly encourage the establishment to respond

to this MOI and prevent any further incidents

where birds could become injured or trapped.

(b) (6) (b) (6) (b) (6)
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35 P208 George's Processing, Inc. XIC592001

0804G

2018-01-04 04C05 Poultry Good

Commercial

Practices

Finalized January 04, 2018 at approximately 1940 hours,

while observing the scalding and picking process

on Kill Line #1 I observed a live, conscious bird

enter the scalder. The bird did not appear stunned

and there was no evidence of a cut on the neck or

head. Due to the height and speed of the line I

was unable to safely remove the bird from the kill

line before it entered the scalder.  I immediately

observed the stun and kill operations for both

lines and determined that the slaughter process

was not out of control. I notified 

and 

of my findings.  immediately

investigated the incident.  I monitored scalding

and picking operations on both kill lines for an

additional 10 minutes and did not observe any

more live birds enter the scalder.  Live poultry

entering the scalder reflects poor commercial

practices and is noncompliant with 9 CFR

381.65(b) which states that "poultry must be

slaughtered in accordance with good commercial

practices in a manner that will result in thorough

bleeding of the carcasses and ensure that

breathing has stopped prior to scalding".

(b) (6)

(b) (6) (b) (6)
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35 P208 George's Processing, Inc. XIC461901

1615G

2018-01-15 04C05 Poultry Good

Commercial

Practices

Finalized On 01/15/2018 at approximately 1935 hours

while observing operations in the live hang area I

noticed a condemn barrel staged next to the

condemn auger and filled to near capacity with

carcasses. Upon closer observation I identified a

live chicken in the condemn barrel partially

covered by two of the carcasses.  The live chicken

was depressed and cool to the touch but was

breathing and slightly responsive to being

handled.  I immediately removed the live chicken

from the condemn barrel and notified 

 of my findings. 

 quickly directed a live hang employee

to sort through the remaining carcasses in the

condemn barrel for signs of other live chickens. 

No other live chickens were found in the condemn

barrel. The stainless steel condemn auger located

in the live hang area macerates chicken carcasses

allowing them to be delivered to offal through a

pipe system.  A live chicken in a condemn barrel

which is staged next to the condemn auger could

potentially be placed in this auger.  I discussed my

findings with 

who told me that a meeting would be

held with live hang personnel at the end of the

shift to discuss proper bird handling in the live

hang area.

(b) (6)

(b) (6)

(b) (6)
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35 P208 George's Processing, Inc. XIC181204

5423G

2018-04-23 04C05 Poultry Good

Commercial

Practices

Finalized On 4/23/18 at approximately 0736 hours, I

observed the line two pile of carcasses at the end

of the live hang belt and observed there was a live

carcass on the left side of the pile that had about

1/4 to 1/3 of the tail end of its body sticking out

from the dead-on-arrival (DOA) carcasses on top

of it. , removed the bird and

placed it back on the line. I started looking

through the pile and identified another live bird

that was completely covered and surrounded by

DOA carcasses. removed this bird and

placed it back on the line. I notified that

this was not in accordance with good commercial

practices and I would be issuing an MOI relating

to this incident. I stated I would need to know the

actions he was going to take to prevent this in the

future. At about 1155 hours that same day, I met

with and 

 and stated that the event

happened during their water breaks and they are

going to pull the lead from the paw room to the

area during the water breaks to ensure that there

is someone offline at all times.

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

(b) (6)

(b) (6)
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80 P2178 PERDUE FOODS LLC MXM2910

023307G

2018-02-07 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0950 hours, one of the Food

inspectors on Evisceration Line#2 identified a

cadaver. She held that carcass for Veterinary

disposition and immediately notified me. Upon

arriving at her station I observed that head of the

carcass was intact with no bleeding cut on neck.

The facial area was swollen; skin around the neck

area was purple in color while rest of the carcass

was bright red in color. 

 and 

 were notified of USDA findings. I

reminded that the PPIA and Agency

regulations do require that live poultry be handled

in a manner that is consistent with good

commercial practices (GCPs), and that they not

die from causes other than slaughter. I

recommended that review the Federal

Register on Treatment of Live Poultry before

Slaughter, published September 2005 for FSIS

recommendations concerning treatment of live

poultry before slaughter, and provided her a copy

of this document. I notified that this

MOI will be forwarded to the District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended. 

Respectfully, P-2178

Perdue Foods

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

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

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40 P218 Pilgrim's Pride Corporation WOD4216

013204G

2018-01-04 04C05 Poultry Good

Commercial

Practices

Finalized At about 1440 on 01/04/2018 while performing a

Poultry Good Commercial Practices task USDA

 observed a yellow condemned

barrel at the end of live hang belt number two

that contained one DOA and one live bird.  Upon

further inspection, the live bird could be seen

breathing buried underneath a pile of feathers

and dirt.   was

notified and he removed the live bird from the

barrel.  He stated that the employee working with

DOAs and the condemned barrels would be

disciplined. The establishment is reminded it is

important to treat poultry in a way that minimizes

accidental injury to include proper sorting of live

and dead birds at rehang as well handling prior to

euthanasia.  In addition, employing humane

methods of handling consistent with Good

Commercial Practices can help produce an

unadulterated product.  was notified

that although, non-regulatory, USDA expects the

establishment to employ handling methods

consistent with Good Commercial Practices. Plant

Management is asked to consider these USDA

concerns and prevent future occurrences.    

Copies of this Memorandum of Interview (MOI)

will be distributed to the establishment,

inspection file and District Veterinary Medical

Specialist per FSIS Directive 6100.3. Documented

by 

(b) (6) (b) (6) (b) (6) (b) (6)
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40 P218 Pilgrim's Pride Corporation WOD5219

013910G

2018-01-10 04C05 Poultry Good

Commercial

Practices

Open At approximately 1640 while performing a Poultry

Good Commercial Practice task USDA

observed birds on line #1 not being

properly bled out prior to entering the scalder.

While observing birds entering the head remover

just prior to the scalder for about one minute 15

birds could be seen flapping their wings, moving

their heads up and down, and swallowing before

their head was pulled off. 

was notified immediately. He stated

that the cutting machine was making

improper cuts and needed to be adjusted. 

was instructed to stop hanging birds.

Maintenance was notified to replace the blade on

the cutting machine and make the proper

adjustments. Following the plant break around

~1720 observed the birds being

properly bled out prior to going into the scalder. 9

CFR 381.65(b) states ” Poultry must be

slaughtered in accordance with good commercial

practices in a manner that will result in thorough

bleeding of the carcass” and thus the

establishment was not operating in accordance

with Good Commercial Practices for Poultry. 

Plant Management is asked to consider properly

investigating the root causes contributing to the

observations at P-218 regarding GCPs, particularly

to the design/setup of the stunning/kill

equipment.  The establishment is asked to

establish and implement effective preventive

measures to avoid future occurrences. Copies of

this Memorandum of Interview (MOI) will be

distributed to the establishment, inspection file

and District Veterinary Medical Specialist per FSIS

Directive 6100.3.  The establishment is reminded

that NRs for noncompliance with 381.65(b) and

MOI for GCPs when finalized are posted for public

review on the FSIS website and that the

information associated with NRS and GCPs can be

FOIA requested by individuals from the general

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

(b) (6)
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public.  Documented by 

40 P218 Pilgrim's Pride Corporation WOD5016

051803G

2018-05-03 04C05 Poultry Good

Commercial

Practices

Finalized On May 3, 2018 at approximately 1430 

 observed a chicken in the middle of the

road in route to the Pilgrim’s Pride facility. 

 informed

 as well as of the

observation. performed a

Poultry Good Commercial Practice task to observe

the truck trailers and cages that the birds are

transported in. On inspection of the trucks there

were numerous damaged cages with holes

variable in size with some big enough for chickens

to fit through. There were also cages with wire

bars bent inward with the ends of the rods

pointed toward the chickens. The damaged cages

were marked by establishment personnel with

blue tape to be identified for repair. 

 was notified of

the findings. The establishment is reminded that

it is important to treat poultry in a way that

minimizes accidental injury and death prior to

humane euthanasia. This includes the

transportation, loading and unloading of chickens

onto the truck trailers. The cages should be

maintained in good repair so that the chickens

remain safe during transportation, loading and

unloading. It is the expectation that the

establishment employ handling methods

consistent with Good Commercial Practices. Plant

Management is asked to consider these USDA

concerns and prevent future occurrences.    

Copies of this Memorandum of Interview (MOI)

will be distributed to the establishment,

inspection file and District Veterinary Medical

Specialist per FSIS Directive 6100.3.

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

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

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90 P308 Koch Foods of Mississippi LLC SPL421602

2706G

2018-02-06 04C05 Poultry Good

Commercial

Practices

Finalized P-308 Koch Foods of Mississippi LLC Dear 

 Today at approximately 0642 hr, I

observed a less than Good Commercial Practice.

While performing portions of a routine Good

Commercial Practice check in the live hang area,

 observed a pile of DOAs inside

the DOA catch bin just past the DOA conveyor.

Upon further observations, I observed a live bird

commingled in with the DOAs.  The bird was in

eminent danger of smothering under the pile of

others birds. The bird was breathing and the pile

of birds was moving as the live bird was breathing.

This occurred on the big bird side along the north

side of the holding shed. I asked the 

 to notify the supervisor for

the area to come to the bin. However, the 

 arrived, observed the live

bird and removed the bird from the bin.

 was informed of the

finding of the bird, but did not arrive in time to

see the bird. My observation leads me to conclude

that had I not observed, discovered, or otherwise

intervened, it is reasonable to conclude that the

bird would have been crushed or suffocated and

as such died by means other than slaughter. 

 as well as 

was notified of the good commercial practice

issue.I was informed by that the lead

person turned the DOA conveyor on but did not

see the live bird. I informed Management for the

establishment that preventing mistreatment of

poultry decreases the production of adulterated

carcasses. This MOI documents the discussion

between myself, and the

establishment management about this poultry

mistreatment event.  It has been discussed with

Management previously about the concerns of

the treatment and conditions relative to the

establishment handling of birds. 

____________________________________          

(b) (6)

(b) (6)

(b) (6)

(b) (6)

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

(b) (6)

(b) (6)

(b) (6)
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    _____________________________________ 

                                       

                       

(b) (6)
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90 P320 Sanderson Farms, Inc. MRA39160

10517G

2018-01-17 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0942 hours on January 16, 2018

while performing the Good Commercial Practices

verification task, the following was observed at

the entrance to the scald tank.  One young

chicken was seen entering the scald tank with an

uplifted head, pupillary reflexes, rhythmic

breathing, controlled movements and a superficial

cut to the side of the neck that only removed the

skin (did not penetrate any vasculature).  At 0945,

0946 and 0948 additional live birds entered the

scald tank that appeared physically the same as

the one described above.  The 

 was present and shown the

last two birds that entered the scald vat live and

informed that as of that moment it would be

documented as a GCP MOI but was approaching

the point where they would have to stop hanging

to take corrective actions prior to resuming

production and would lead to a noncompliance

being issued.  elected to stop hanging

and start lunch a couple minutes early to be

proactive with corrective actions and avoid any

further live birds entering the scald vat.  Several

minutes later entered the USDA office

of inform USDA that the blade had been adjusted

to make deeper cuts and he asked to be present

at my next verification check.  I informed him that

I would do a 500 bird verification as soon as

production resumed after lunch.  During that time

no additional live birds were seen entering the

scald system.  Verification was done

approximately 1 1⁄2 hours later with 

present as well and again no other live birds were

seen entering the scald system.       Live bird(s)

entering the scald system live is a less than Good

Commercial Practices and results in adulterated

product. The establishment is responsible for

ensuring that birds under their control on the

official premises are treated in a humane manner

that will minimize excitement, discomfort, injury

(b) (6)

(b) (6) (b) (6) (b) (6)
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and/or death by means other than slaughter. As

per Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live

Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of

poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

Practices (GCPs) as described by industry

guidelines.  A copy of this Memorandum of

Interview will be forwarded to appropriate

personnel in the District Office.  Respectfully

submitted on January 16, 2018 

 Cc: Dr. David Thompson, DDM 

(b) (6) (b) (6)
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90 P320 Sanderson Farms, Inc. MRA36140

23615G

2018-02-15 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2105 hours on February 14,

2018, while verifying the PHIS Good Commercial

Practices in Poultry (GCPIP) verification task at

P320, Sanderson Farms, Laurel, MS, the following

less than GCPIP incident was observed.   One live

young chicken from an approximately 500 bird

sample subgroup entered the first scald tank

exhibiting rhythmic breathing, pupillary reflexes,

uplifted head, controlled movement of the head,

and an approximately 1⁄2 inch cut to the

neck.  Establishment took immediate action

according to their written welfare policy and

made adjustments to machinery. A second

verification prior to the scalder of an approximate

500 bird sample subgroup had three live birds

exhibiting the same signs entering the scalder at

approximately 2125 hours.  The establishment

took further action, added a second backup killer

and readjusted the machinery.  Slaughter process

ended approximately 2135, so a third verification

was not performed. This was determined to be

an isolated incident and not a loss of process

control.   Birds entering the scalder while still

breathing is not consistent with GCPIP and results

in adulterated product.  Establishments are

responsible for birds entering the official premises

and must employ GCPIP to prevent unnecessary

suffering, injury and death. This will be discussed

at the weekly meeting with establishment

personnel on 2/15/2017   As per Federal Register

Notice Docket 04-037N, dated September

28.2005, “Treatment of Live Poultry Prior to

Slaughter”, the Food Safety Inspection Service

(FSIS) strongly encourages all establishments

engaged in the slaughter of poultry to abide by

Good Commercial Practices (GCPs) as described in

industry guidelines. Respectfully, 

 Public Health

Veterinarian USDA FSIS OFO Jackson District, Est.

P-320, 2nd Shift Phone: Email:

(b) (6)

(b) (6)
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Code TaskName Status MOI Agenda

@fsis.usda.gov Cc: Dr. David

Thompson, DDM 

(b) (6)

(b) (6)
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90 P320 Sanderson Farms, Inc. MRA02170

45124G

2018-04-24 04C05 Poultry Good

Commercial

Practices

Finalized To:               

Sanderson Farms, Inc., P320 At approximately

1426 hours on April 24, 2018, the following less

than Good Commercial Practices in Poultry

(GCPIP) incident was observed at P320 Sanderson

Farms, Inc., Laurel, MS. A live bird was observed

by sitting

on a pile of decapitated carcasses inside the dead

on arrival (DOA) bin. The 

 was present at the time of

discovery and immediately removed the live bird

from the DOA bin. The live bird was not covered

by any carcasses, and appeared to be sitting up

with no obvious sign of morbidity.  As there was

no sign of morbidity and the bird had no

denaturant on it, the live bird was returned to

production. 

and 

 were notified of the incident at

approximately 1430 hours. This incident was

determined to be an isolated event and not a loss

of process control or systemic event. Allowing live

bird(s) to become entrapped under other live

birds and DOAs is a less than GCPIP and can cause

needless suffering and death from suffocation

resulting in adulterated product. Poultry slaughter

establishments must take every precaution to

ensure poultry under their control on the official

premises are treated in a humane manner,

subjected to minimal excitement, discomfort, and

injury, or death by means other than slaughter. 

, and

 met at the time of notification to

discuss the less than GCPIP. No response to the

incident was given at this time, other than they

will investigate the incident and the employee

responsible for removing the DOAs and live birds

from the hanging pen floor would be disciplined.

 was advised a GCPIP Memorandum

of Interview would be issued to management

(b) (6)

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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pending review by . 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, 

USDA

FSIS OFO Jackson District Sanderson Farms, Est.

P-320, 2nd Shift cc: Dr. Larry Davis, DM Dr.

Gregory Brookhauser, DDM 

(b) (6)

(b) (6)

(b) (6)
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40 P34308 Sanderson Farms, Inc. PHY102103

3807G

2018-03-07 04C05 Poultry Good

Commercial

Practices

Finalized On March 7, 2018 at approximately 1600 while

conducting a Poultry Good Commercial Practice

task, I was reviewing at the Animal Welfare

records and found the following concerns with the

broken wing  section of the animal welfare record.

The paper work states: All of the checks below are

to be conducted on 500 birds per line. If the limits

are exceeded on any item immediately notify

Production and QC Supervisor A retest must be

done following corrective action.     The Limit for

broken wings is 15 per line. On 2/21/2018 First

shift at 0523 on line 1  had 22 broken wings.  

There was no corrective action recorded.  A

retest at 11:36 on line 2 resulted in 15. On

2/22/2018 Second shift at 1507 on line 1 had 24. 

There was no corrective action recorded. A

retest on line 2 resulted in 14 2/26/2018 First

shift at 0826 had 20 on line 1.    There was no

corrective action recorded.         A retest on line

1 resulted in 15                      Second shift at

1505 had 24 on line 1      There was no corrective

action recorded.           A retest on line 1 resulted

in 15                    2/27/2018 Second shift at

1510 had 18 on line 2.            There was no

corrective action recorded.                   A retest

on line 2 resulted in 11                     3/01/2018

First shift at 0523 had 17 on line 1 and 22 on line

2                          Retest line 1 14 Line 2 15 

 There was no corrective action recorded. A

retest on line 1 resulted in 14    A retest on line 2

resulted in 15                               

                                                Second Shift at 1502

had 17 on line 1 and 19 on line 2                 There

was no corrective action recorded.                 A

retest on line 1 resulted in 14    A retest on line 2

resulted in 15                      03/02/2018 Second

shift at 1501 had 20 on line 1 and 23 on line 2   

There was no corrective action recorded.   A

retest on line 1 resulted in 14     A retest on line 2

resulted in 15                     03/05/2018 Second
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shift at 1459 had Line 1 20 and line 2 20   There

was no corrective action recorded.   A retest on

line 1 resulted in 14     A retest on line 2 resulted

in 15                                    The monitoring form

states a retest must be done following corrective

action.  There is no corrective action on the

monitoring form. Documented by

40 P34308 Sanderson Farms, Inc. PHY071703

2721G

2018-03-21 04C05 Poultry Good

Commercial

Practices

Finalized Sanderson’s Farm (est. #P34308) has developed a

procedure which allows only 10 miscuts in a 500

bird inspection to prevent birds still breathing

from entering the scalder.  These machines are

used to properly cut the necks of the birds prior to

stunning.   When the kill machine is properly

working, the time that is allowed for proper

bleeding of the birds will make inspection stations

easier.  On March 21, 2018 at approximately

1400 hours, various size birds were being

slaughter on the evisceration floor.  Upon further

investigation in the picking room, TNTC (too

numerous to count) miscuts were observed from

both kill machines.  At approximately 1530 hours,

the kill machine on line #2 missed 30 cuts and the

kill machine on line #1, 15 cuts was missed in a 3

minutes 10 seconds time. 

was verbally

notified.  A retest was conducted at 1645 hours,

and kill line #2 and passed with 7 miss cuts and

kill line #1 had 5 miss cuts.  Due to the smaller

bird size, the establishment adjusted the height of

the kill machine and reduces the possibilities of a

bird still breathing from entering the scalder. 

Documented By: 

(b) (6)

(b) (6)(b) (6)
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25 P34668 Simply Essentials Poultry, LLC SFJ461501

2605G

2018-01-05 04C05 Poultry Good

Commercial

Practices

Finalized While performing ante-mortem inspection in the

Live Receiving area at approximately 0530 hours

on 01/04/18, I observed the following Good

Commercial Practice concern on Trailer #40.  I

observed a live chicken with both wings trapped

between the corner of the floor above it and the

metal frame of the cage.  The chicken was

exhibiting signs of extreme lethargy: shallow

breathing, did not open its eyes to stimuli of

flashlight and touch, and felt cold when I touched

it.  There was no available management personnel

to show the affected chicken to at that time.  I

also observed in the Live Receiving area during

this same time a cage move down the track after

being dumped and going past the door closing

machine with several drawers still full with

chickens and all the doors to the cage open.  One

chicken fell out through an open door as the cage

was lifted by the forklift from the track.  I

continued my observations with walking over to

the dumping apparatus.  There, I observed 4 live

chickens under it and 2 dead chickens.  One of the

dead chickens appeared to have been smashed by

a cage because its belly and chest were ripped

open, exposing torn and strung-out viscera, and a

leg and awing were separated from the body and

laying strung-out on the floor between the

dumping apparatus and the door closing

machine.  The other dead chicken's breast skin

was partially removed, exposing muscle beneath. 

One of the live chickens appeared to have broken

wings because they were not tucked in close to its

body and it was reluctant to move. At

approximately 0630 hours while in the Live

Receiving area, I observed employees remove

approximately 20 DOAs from a cage that had

already been dumped and removed from the

track.  I observed 4 DOA hoppers full of chickens

at this time, as well.  I checked the number of

DOAs recorded by that time and saw that out of
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2.5 trucks, approximately 800 DOAs had been

recorded.  Usually there is approximately 

chickens per truck, indicating the establishment

was at a DOA rate already for the day.  This

was addressed in the Weekly Meeting MOI from

today (MOI #SFJ3911015504G) and at that time

Management still did not know the cause of the

large number of DOAs. At approximately 1530

hours I observed a cage removed from the trailer

but the roof was not intact above one of the top

drawers.  It had partly fallen inside of the drawer

on top of chickens.  I did not see an employee

remove any DOAs from the drawer prior to

placing the roof back on top of it.  I noticed the

roof did not appear to be secured back into place,

but rather resting on top.  I watched the cage get

dumped and saw the roof fall into the drawer

blocking the door and chickens from getting

dumped out of the cage.  I was walking away from

the dumper when I heard the alarm go off at the

dumper.  I saw that the roof from the cage I

watched dump was under the next cage at the

dumper.  It must have fallen off when the cage

moved away from the dumper and then jammed

up the track for the next cage.  The chickens in the

top drawer that was now missing the roof

appeared to be unharmed. This MOI is

assoiciated with weekly meeting MOI

#SFJ3911015504G dated 01/04/18 and GCP MOI

#SFJ4108121230G dated 12/30/17. The

establishment must employ humane methods of

handling and slaughtering consistent with Good

Commercial Practices in a way that minimizes

injury to poultry.  Poultry are to be handled in a

manner that prevents needless injury and

suffering.  Employing humane methods of

handling and slaughtering that are consistent with

Good Commercial Practices increases the

likelihood of producing unadulterated product.

(b) (4) (b) (4)
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25 P34668 Simply Essentials Poultry, LLC SFJ051101

2806G

2018-01-06 04C05 Poultry Good

Commercial

Practices

Finalized While performing ante-mortem inspection in the

Live Receiving area at approximately 0415 hours

on 01/05/18, I observed 4 live chickens sitting

directly on the bed of Trailer #42 in the space

between the 4-tier cages and the 5 tier cages. 

One of the chickens was lying on its back and

struggling to correct itself onto its feet by kicking

and trying to push itself up with the back of its

wings.  The other 3 chickens appeared to be

uninjured.  In the top 5-tier cage on one side of

the space, I noted a larger-than-normal gap

between the roof and the backside of one of the

top drawers.  A chicken from this drawer climbed

onto the edge of the drawer in the mentioned gap

and jumped down to the bed of the trailer with

the other loose chickens.  The chicken showed

some difficulty walking at first, but was able to

stand and appeared to be uninjured.  There was

no supervisor in the area at this time and at

approximately 0430 I asked an employee to turn

the chicken that was lying on its back over to its

feet, and he did so.  I also noted that the second

drawer of the mentioned 5-tier cage was missing

a door and half of its floor and the back corner of

the other half of the floor was collapsing into the

3rd drawer.  Neither the 2nd or 3rd drawer were

holding any chickens. At approximately 0610

hours while in the Live Receiving area, I observed

on Trailer #40 2 cages each with a chicken with its

wing trapped between the floor above it and the

frame of the cage.  I also observed a cage with its

plastic side and metal bar bent inward toward

chickens.  I showed 

 my observations and he released the

trapped wings.  As I continued to make my

observations, I observed 5 live birds under the

dumping apparatus and one dead chicken with

skin torn away from its body and muscle

exposed.  I observed a cage dump and from where

I was standing I observed a smashed chicken on

(b) (6)
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the arm that lifts the cage to dump it.  After the

cage dumped, I observed 5 more chickens fall to

the floor under the dumping apparatus.  One

chicken had a broken wing where the humerus

bone was protruding through the skin at the

elbow joint, and another chicken appeared

half-dead (purplish in color, hanging head, gasping

for air) when it fell and died shortly after landing

on its back on the floor.  The other chickens that

fell appeared unharmed.  I watched the second

cage dump without incident. As I was walking

away from the dumping apparatus I observed a

cage that had already been emptied and the

doors closed, sitting up on the track second in line

to be removed by the forklift.  One drawer door

was closed on a live chicken’s neck with its head

out the door.  The chicken was struggling to

breath/ gasping for air and its head was starting

to turn purple in color.  I asked an employee if

there was any way he could open the door for

that bird.  He first shook his head, but then he ran

and got a hook (used to snare a loose chicken by

the leg) and pulled the door open with it.  The

chicken was still alive.  The cage behind this one

also had a chicken caught in a door in the same

way, but it appeared to be dead.  The employee

opened this door too, and we were able to

confirm the chicken was dead.  At this time I

observed one full DOA hopper and another that

was a quarter of the way full.  I saw that 900

DOAs had been recorded with the first trailer only

half way through.  At approximately 0800 hours

I met with 

and told him of my observations.  He informed me

that the birds falling from the dumper was likely

due to all the DOAs, and that he did not know at

that time what could be the cause for the large

number of DOAs. At approximately 1000 hours I

met with to find

out what he found out about the previous two

(b) (6) (b) (6)
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days (Wednesday 1/3/18 and Thursday 1/4/18)

high numbers of DOAs, and to discuss the possible

cause of this morning’s high number of DOAs.  I

explained that I had not noticed anything on

ante-mortem nor post-mortem inspection

indicating that a disease process could have

caused the high numbers of DOAs.  He said that

the previous two days is still unexplained because

the holding shed checks were all okay.  He

explained that today’s DOAs are very surprising

because the chickens had a short travel time of

about an hour.  He said that the trailer were

parked in the holding shed for approximately 3

hours prior to slaughter, which is about an hour

longer than they usually like to hold them, but

that it should not have caused an issue like this. 

This MOI is associated with GCP MOI

#SFJ4615012605G for the discussion on the DOAs

from productions day 1/3/18 and 1/4/18 and

previously mention observations of injured and/or

loose chickens due to poor cage conditions. The

establishment must employ human methods of

handling and slaughtering consistent with Good

Commercial Practices in a way that minimizes

injury to poultry.  Poultry are to be handled in a

manner that prevents needless injury and

suffering.  Employing humane methods of

handling and slaughtering that are consistent with

Good Commercial Practices increases the

likelihood of producing unadulterated product.
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 158

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Code TaskName Status MOI Agenda

25 P34668 Simply Essentials Poultry, LLC SFJ131001

0410G

2018-01-10 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0900 hours, while I was

performing a Good Commercial Practices Task in

the Live Receiving area, I observed a cage on

Trailer #44 (second trailer of lot 2) that the floor

panel on the door-side of the cage was collapsed

from the middle (where it meets with the other

floor panel) in to the drawer below.  It appeared

that both drawers likely had been holding

chickens prior to the collapse, based on the

number of chickens affected.  When the cage was

removed from the trailer by the forklift, I could

only observe two chickens that appeared to be

dead.  They were located on the bottom floor. 

The driver placed the cage on the track in the

same condition as found on the trailer.  I observed

the cage as it approached the dumping

apparatus.  From where I was standing I could not

see the affected drawers during dumping.  When

the cage was lowered back onto the track after

dumping, it appeared to get "hung-up" on the

dumping apparatus and did not move.  Two

employees came over to the dumper and tried to

push it down the track and at first were

unsuccessful.  I could see there were still chickens

in the bottom drawer affected by the collapsed

floor.  I walked over to the other side of the track

to get a better view of the situation causing the

hang-up of the cage.  I could see several chicken

still inside the bottom drawer/ behind the

collapsed floor.  I could also see the floor had slid

forward through the second drawer door.  The

part of the floor sticking out the door got caught

on one of the arms on the dumping apparatus

that open the drawer doors.  After approximately

five to ten minutes the cage was freed.  I observed

approximately eight dead chickens removed from

the affected drawer and approximately thirty live

chickens.  One of the live chickens had a broken

wing where the humerus bone was protruding

through the skin at the location of the elbow
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 159

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Code TaskName Status MOI Agenda

joint. Almost immediately after my observations,

I met with to

share them with him and notify him of my intent

to document an MOI. This MOI is associated with

MOI #SFJ0511012806G for previously mentioned

observations of loose and/or injured/dead

chickens due to poor cage conditions. The

establishment must employ humane methods of

handling and slaughtering consistent with Good

Commercial Practices in a way that minimizes

injury to poultry.  Poultry are to be handled in a

manner that prevents needless injury and

suffering.  Employing humane methods of

handling and slaughtering that are consistent with

Good Commercial Practices increases the

likelihood of producing unadulterated product.

(b) (6)
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Code TaskName Status MOI Agenda

25 P34668 Simply Essentials Poultry, LLC SFJ241001

4523G

2018-01-23 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1000 hours on 1/22/18, I was

performing a Good Commercial Practices Task on

the trailer that was parked inside the Live

Receiving area.  It was during the company break

time and only one cage had been unloaded from

the trailer. The cages are stacked two-high on the

trailer, and therefore I cannot see inside every

cage and every drawer of every cage.  I first

examined the cages from the driver's side of the

trailer. The chickens on this side appeared to be of

normal health.  I continued my inspection to the

passenger side of the trailer, starting from the

back of the trailer.  I first noted that the chickens

on this side were wet and lethargic compared to

the other side.  As I continued to walk toward the

front of the trailer I noticed all the chickens on

this side of the trailer were wet and the DOAs per

cage seemed to be increasing.  I counted 141

dead chickens, which includes the DOAs that I

observed in the cage that was unloaded from the

trailer and waiting to be dumped.  In this cage I

also observed dry normal healthy appearing

chickens on one side and wet, lethargic, and dead

chickens on the other side just like the rest of the

cages on the trailer.  I summoned 

 to show him my findings. 

 He contacted by

phone, who contacted the catch crew supervisor

to investigate the findings. At approximately

0830 hours on 1/23/18, I met with 

 to discuss their findings on

the incident.  He informed me that the trailer was

already untarped at the holding shed before it

was brought over to 1st Processing, and that the

truck driver did not notify anyone of any

abnormalities with the tarp or trailer at the time

of parking and untarping the trailer.  Through

their investigations, they suspect that the tarp

became unlatched somewhere toward the front of

the trailer during transit, which caused the DOAs

(b) (6)

(b) (6)

(b) (6)
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and wet birds.  A total of 166 DOAs were recorded

from Trailer #36.The establishment must employ

humane methods of handling and slaughtering

consistent with Good Commerical Practices in a

way that minimizes injury to poultry.  Poultry are

to be handled in a manner that prevents needless

injury and suffering.  Employing humane methods

of handling and slaughtering that are consistent

with Good Commercial Practices increases the

likelihood of producing unadulterated product.

25 P34668 Simply Essentials Poultry, LLC SFJ161402

0112G

2018-02-12 04C05 Poultry Good

Commercial

Practices

Finalized There were a large number of DOAs on loads 1

and 2 for this lot.  There were a total of 3,361

Dead on Arrival for the day, 2/9/18.   The

slaughter number was   On 2/12/18 I

spoke with , and was

told a cause and corrective action will be

documented and provided to USDA.

(b) (6) (b) (4)
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80 P419 Case Farms Processing, Inc. VDB48090

20408G

2018-02-08 04C05 Poultry Good

Commercial

Practices

Finalized Establishment: 00419P Case Farms 121 Rand St.

Morganton, NC 28655 At approximately 0612

hours on 2/8/2018, while observing maintenance

working on line 2.   I observed a

cadaver with its head attached and no cut mark

on the neck.  It had obviously died by means

other than slaughter.  The cadaver was identified

on line 1 rehang table in the evisceration

department.   , was

notified.  Also notified was 

 and Mr. Matthew

Martin, plant manager.  The carcass was

condemned.  PPIA and Agency regulations

require that live poultry be handled in a manner

that is consistent with good commercial practices,

and that they not die from causes other than

slaughter. I recommended that management

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

published September 2005 [Docket No. 04–037N]

for FSIS recommendations concerning treatment

of live poultry before slaughter. A copy of this

federal register notice can be provided on

request.  A copy of this MOI will be forwarded to

the District Office and the District Veterinary

Medical Specialist (DVMS) in case additional

follow-up is recommended.

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

(b) (6)
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25 P425 Northern Pride, Inc. MYG25120

44920G

2018-04-20 04C05 Poultry Good

Commercial

Practices

Finalized Attendees:

 Plant Manager Warren

Leighton , ,

,

 On

Friday April 20, 2018 at approximately 0700

hours a cadaver was hung back by IPP.  The

cadaver was a large tom.  I observed a superficial

laceration through the skin, however the jugular

vein on the left side was intact and a large blood

clot was present on the right side of the neck,

over the right jugular vein.  At 0723 hours and

0725 hours respectively two additional cadavers

were hung back by IPP. Between 0735 hours and

0745 hours 6 additional cadavers were identified

on the line and hung back by IPP.  I confirmed

that these additional 8 birds were cadavers, and

all had ineffective neck cuts.    At approximately

0745 hours I discussed the above observations

with plant management.  Plant management

discussed that the auto killer is only able to cut an

estimated 98% of the birds, and due to varying

bird sizes this number can fluctuate. 

Establishment management determined the auto

killer would be adjusted immediately to deliver a

deeper cut this morning.  Concerns about bird

head loss due to a deep neck cut was discussed,

and establishment management agreed the head

loss needs to be kept at a level where

presentation on the line is acceptable.   It was

discussed that the employee performing the

back-up cutting is responsible for identifying

those birds of abnormal size and those birds

receiving ineffective cuts.  Plant management

discussed the visibility concerns of the back-up

cutter caused by blood splashing that is

exacerbated by the birds beating their wings.  It

was noted the employee has a face shield, but no

way to maintain its cleanliness.  Plant

(b) (6)

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

(b) (6)
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management will provide material for the back-up

cutter to maintain cleanliness of the face shield

(wipes or towels), and a curtain will be hung to

minimize the blood splashing onto the employee

at his work station.  The back-up cutter

employee’s station will be moved down the line

to improve visibility. I advised plant

management that an MOI would be written and

forwarded to the District Office for the 

 and 

 to review and they will contact us should

additional follow-up be needed. Respectfully, 

25 P425 Northern Pride, Inc. MYG00150

42223G

2018-04-23 04C05 Poultry Good

Commercial

Practices

Finalized Attendees: 

 On

Monday April 23, 2018 at approximately 1410

two cadavers were identified on the line and hung

back by IPP.  Both birds did not have any cuts on

the neck. At approximately 1425 hours I

discussed the above observations with plant

management.  Plant management acknowledged

the back-up cutter had missed these two birds. 

 stated that she would discuss this

incident with the back-up cutter.  She stated the

back-up cutters would be rotated to assist

with maintaining attention to the job.  I advised

plant management that an MOI would be written

and forwarded to the District Office for the

and , to review and they will contact us

should additional follow-up be needed. 

Respectfully, 

(b) (6)

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (4)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 165

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25 P425 Northern Pride, Inc. MYG39160

43224G

2018-04-24 04C05 Poultry Good

Commercial

Practices

Finalized Attendees:  ,

 On Tuesday April 24, 2018 at

approximately 0950 hours two cadavers were

identified on the line and hung back by IPP.  Both

birds had a cut on the distal neck.  The cut was

ineffective and lacerated only the skin.   At

approximately 1040 hours, while observing at the

back-up cutting station, I observed 3 conscious

birds in approximately 2 minutes.  Observing the

stunner operation I noted approximately 5 birds

in several minutes that were not stunned.  These

birds were able to elevate their heads above the

stunner. I discussed the above observations with

.  

stated that it is the back-up cutter’s first day on

the job, as the back-up cutter employees are

rotating.  We discussed the ineffective stuns, and

 contacted maintenance to adjust the

stunner.  stated she would talk to the

back-up cutter and provide coaching. At

approximately 1200 hours two additional

cadavers were identified by IPP and were

confirmed to have only a superficial cut on the

distal neck.  I observed the stunner, and found the

equipment was appropriately adjusted and was

effectively stunning the birds.  These findings were

discussed with , who said she would

provide additional training to the back-up cutter. 

I advised plant management that an MOI would

be written and forwarded to the District Office for

the 

 and , to review and they will

contact us should additional follow-up be needed.

Respectfully, 

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

(b) (6)

(b) (6) (b) (6)
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25 P425 Northern Pride, Inc. MYG21170

45825G

2018-04-25 04C05 Poultry Good

Commercial

Practices

Finalized Attendees: 

 On Wednesday April 25, 2018 at

approximately 1330 hours I identified four

cadavers in the condemn barrel located in the

picking room.  None of the birds had a cut on the

neck.  Observing the back-up cutter for several

minutes I observed two birds that were not

stunned.  I noted the bird sizes were highly

variable in this lot. I notified 

 of the finding of the

cadavers in the condemn barrel.  stated

that she wants cadavers hung on the line so that

they are identified by IPP at inspection and the

issue can be addressed immediately by plant

management.  also stated she would be

meeting with the back-up cutters today to discuss

the cadaver issue.  She is evaluating the lighting to

see if a second light would help the back-up killers

identify uncut birds.  stated the

back-up killers will be rotating at lunch to improve

variability in the day and thus attention span

during the back-up cutting shift.  

contacted maintenance to check the stunner and

auto killer. I proceeded to the stunner and auto

killer where I observed for approximately 5

minutes.  I noted two smaller birds that were not

stunned, and I noted 2 stunned birds which

missed the auto killer because their necks were

not long enough to be caught in the guide to the

auto killer.  

 and I observed for approximately 5

additional minutes, and noted approximately 5

more birds that either were not stunned or not

killed by the auto killer.  adjusted

the stunner upwards approximately 3”-4” and the

auto killer upwards approximately 2”.  This

adjustment was successful in stunning and killing

more of the smaller birds in the lot, but it was

discussed that this adjustment would not kill (b) (6)

(b) (6)

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

(b) (6)

(b) (6)
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100% of the birds. While observing at the auto

killer, I noted that the birds which are stunned

drag their head on the decline on the way to the

blood tunnel, which is covered in blood.  This

makes the stunned birds harder to identify, as the

head and proximal necks are covered in blood. 

This was brought to attention, and we

discussed that just observation of a blood covered

head is not synonymous with being cut, or an

effective cut.  We discussed that the visible

appearance of good blood flow from the neck is a

better indication of an effective cut.  We discussed

that it is a hindrance that the back-up killer

cannot see the auto killer to visibly see what birds

the auto killer misses. I advised plant

management that an MOI would be written and

forwarded to the District Office for the 

 and

 to review and they will contact us should

additional follow-up be needed. Respectfully, 

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

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

(b) (6)
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25 P425 Northern Pride, Inc. MYG28130

41827G

2018-04-27 04C05 Poultry Good

Commercial

Practices

Finalized Attendees:  ,

 On Friday April 27, 2018 at

approximately 0945 hours one cadaver was

identified by online IPP and hung back for

disposition.  The bird was a large tom and had a

superficial cut on the distal neck.  The cut was

ineffective and lacerated only the skin.   At

approximately 1230 hours a second cadaver with

the same presentation (superficial but ineffective

cut) was hung back for disposition. At

approximately 1245 hours I discussed the above

observations with 

 stated that she knows which

back-up cutter is occasionally missing birds.  At

the time of the meeting had already

addressed the issue with the employee.  Their

discussion included the importance of checking all

larger and smaller birds in a lot to ensure they are

cut.  stated that maintenance will be

installing a second light in this area at a different

angle to improve the visibility. I advised plant

management that an MOI would be written and

forwarded to the District Office for the 

 and 

, to review and they will contact us should

additional follow-up be needed. Respectfully, 

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

(b) (6)

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

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

(b) (6)

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25 P425 Northern Pride, Inc. MYG14120

53002G

2018-05-02 04C05 Poultry Good

Commercial

Practices

Finalized Attendees:  

 On Wednesday May 2, 2018

at approximately 0605 hours one cadaver was

hung back by online IPP.  The bird had a

superficial cut on the mid neck, consistent with an

insufficient cut by the auto killer.  At 0700 hours a

second cadaver was hung back.  This cadaver had

both a cut on mid-neck area consistent with a

superficial auto killer cut, and a cut on the ventral

proximal neck consistent with a back-up killer

cut.  Both cuts were ineffective in sufficiently

lacerating the vessels in the neck.  At 1130 hours

a third cadaver was hung back, which had the

same presentation as the second cadaver

(ineffective auto killer cut, and ineffective back-up

killer cut). I notified 

of the findings.  We discussed the

lighting at the back-up killer station.  A third

spotlight had been added last night and

positioned correctly, just to the south of the

back-up killer station.  The purpose of the light

was to effectively illuminate the area and help to

eliminate shadows.  I observed at the back-up

cutting station at approximately 0730 hours for

approximately 4 minutes and observed the

back-up cutter palpating the neck of each bird to

assist with determining efficacy of the auto killer

cut.  and I discussed this observation. 

We also discussed that a superficial cut on the

ventral aspect of the neck may fail to lacerate the

vessels in the neck, which sit more laterally.  

 stated she will be discussing the issue

immediately with both back-up cutters with a

translator in Spanish, and she will meet with them

for a longer meeting after the shift is complete. I

advised plant management that an MOI would be

written and forwarded to the District Office for

the 

and , to review and they will

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

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

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

(b) (6)


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Code TaskName Status MOI Agenda

25 P425 Northern Pride, Inc. MYG09110

54511G

2018-05-11 04C05 Poultry Good

Commercial

Practices

Finalized Previous MOIs Documented for Cadavers: 

4/20/18 MYG2512044920G          MOI / Poultry

Good Commercial Practices:

Cadavers / MYG2512042220I 4/23/18

MYG0015042223G          MOI / Poultry Good

Commercial PracticesCadavers / MYG5914044623I 4/24/18

MYG3916043224G          MOI / Poultry Good

Commercial PracticesCadavers / MYG3916040624I 4/25/18

MYG2117045825G          MOI / Poultry Good

Commercial

Practices / MYG2117043225I                4/27/18

MYG2813041827G          MOI / Poultry Good

Commercial

Practices / MYG4309040927I                  5/1/18

MYG0806052001G            MOI / Poultry Good

Commercial PracticesCadaver / MYG5013043630I   5/2/18

MYG1412053002G            MOI / Poultry Good

Commercial PracticesCadavers / MYG1312052102I 5/7/18

MYG3415051507G            MOI / Poultry Good

Commercial PracticesCadaver / MYG3207053207I Attendees:  Plant

Manager Warren Leighton, 

 On Monday May 11,

2018 ten cadavers were identified at P425

between approximately 0620 hours and 0740

hours.  All of the ten cadavers had an ineffective

auto killer cut and an ineffective back-up killer

cut.   At approximately 0700 hours, after four

cadavers had been identified, stated

she had contacted maintenance to adjust the auto

killer.  I observed stunning, which was effective,

and I observed for conscious birds on the line and

found none.  At approximately 0720 hours after

two additional cadavers were identified, (b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 174

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 stated she had contacted maintenance to

adjust the auto killer a second time. At

approximately 0725 hours I observed the auto

killer was not making effective cuts on a majority

of the birds.  The back-up cutter was struggling to

identify those birds needing a second cut.  I

observed and remove

approximately six conscious birds from the line. 

0740 hours, after nine cadavers total had been

identified, stated the auto killer was

not operating properly and was “down.”  The

back-up cutters would be assuming the job as

primary killers for the remainder of the day.  At

approximately 0820 hours, plant management

met with IPP to discuss the auto killer function

and the identified cadavers.  stated

that the auto killer was checked first thing this

morning.  About 30 minutes after the initial check

a maintenance team member noted loose screws

on one of the rollers that secure the bird’s neck

for the auto cutter.  The loose screws hollowed

out the roller drive shaft, causing a jumping

motion.  stated that maintenance

had secured the roller so that it would not move. 

Maintenance later raised up the blade in the auto

killer.  explained that when the auto

killer is not working properly, the back-up cutters

have a very challenging job to determine which

birds need a second cut.  stated

that the auto killer is monitored for 10 min at the

start of the shift.  Plant management discussed

that checking the auto killer a second time 30

minutes into the shift, to ensure that the initial

adjustments were effective, would be beneficial.  

Plant management discussed that in the future, if

the auto killer is not functioning properly, it

should be taken out of the production line

immediately due to the critical nature of this

piece of equipment.  The back-up killers should

resume their position as the primary killer.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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  Maintenance will assess repairs and

re-implement the auto killer once fixed after a

plant break or lunch.  The back-up killers need to

communicate with if anything

abnormal appears to be occurring with the

stunner and auto killer, so that the issue can be

addressed immediately.  stated

that parts have been ordered for the auto killer,

and extra parts were also ordered to assist with

rapid repairs in the future.   I advised plant

management that an MOI would be written and

forwarded to the District Office for the

and 

 to review and they will contact us should

additional follow-up be needed. Respectfully, 

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

(b) (6)(b) (6)
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50 P44826 Case Farms Processing, Inc JOD010201

0708G

2018-01-08 04C05 Poultry Good

Commercial

Practices

Finalized On 01/06/2018 at approximately 0545 hours,

while conducting a routine walkthrough of the

live-hang department did

note the following deviation from accepted good

commercial practices (GCP’s): While inspecting

birds in the DOA barrels, noted that

the plant was not performing cervical dislocation

of DOA birds as is their normal procedure.  Upon

checking the DOA barrels, noted

motion from inside the barrel.  On investigation,

pulled one bird that was still shallowly breathing

from underneath two to three DOA birds. 

Checking the rest of the DOA barrels in live hang,

a total of 6 birds that were shallowly breathing

and covered to various degrees by other DOA

cadavers were retrieved from the DOA barrels. 

 explained that

live-hang had been short staffed, and with the

cold weather bringing an increase in DOA’s they

had been unable to keep up with the practice of

cervical dislocation.  I notified

and Assistant Plant Manager Jeff

Ragan of this deviation from accepted GCP’s and

that I would be documenting a memorandum of

interview (MOI)

stated that they would be returning to the

practice of cervical dislocation for DOA’s.  On

discussion with Assistant Plant Manager Jeff

Ragan, he stated that as a further preventative

measure the plant was looking into additional

methods besides the plastic paneling currently in

use on the trucks to keep the cold air off the birds

during transit and decrease the number of DOA’s

the plant receives during cold weather.

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

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

(b) (6)
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80 P45910 SANDERSON FARMS, INC GRI130603

4323G

2018-03-23 04C05 Poultry Good

Commercial

Practices

Finalized This MOI is to document a meeting that was held

at approximately 7:00AM in the USDA Office with

and 

 At approximately 6:55 AM,

I had been monitoring the plant employees

hanging live birds on the shackles when I notice

that there were three birds lying on the floor at

the end of the conveyer belt.Two birds were DOA

and lying on top of one bird that was on its back

and was seen struggling to breathe, and moving

its legs. I immediately retrieved this bird and I

observed it raise its head. After placing the bird on

the floor it was able breathe, to remain in a sitting

position and move its head and wings. Had this

bird remained in the condition it was found in it

would have been smothered to death and

therefore died my means other than by slaughter.

I tried to find a supervisor in the area but none

was present until I was able to communicate my

concerns to on the Evisceration

Floor and I notified him that I would be issuing an

MOI for failure to follow Good Commercial

Practices.

(b) (6)

(b) (6) (b) (6)
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80 P45910 SANDERSON FARMS, INC GRI311204

0517G

2018-04-17 04C05 Poultry Good

Commercial

Practices

Finalized MOI for establishment P-45910, Sanderson Farms,

Inc., April 17, 2018 at 08:36 hours.  In

attendance:  and 

. 

At approximately 08:06 hours, while observing

conditions in the live hang area, I saw a bird that

was still breathing and moving its wings in the

DOA (dead on arrival) cart.  I notified personnel in

the live hang area about the live bird.  While the

bird was removed from the cart and checked, the

supervisor had  summoned to the

area.  I notified that live birds should

not be in the DOA cart as they could be

smothered by other birds.  Shortly after this, he

came to my office and gave corrective actions to

prevent a repeat incident of poultry

mistreatment.  He stated that a mechanical neck

breaker would be reattached to the wall in the

live hang area (the neck breaker had been

removed from the wall and was not being used at

that time.) Birds would then have their necks

broken (cervical dislocation) and heads removed

before being placed in the DOA cart.  Until all

personnel could be trained, the live receiving

supervisors on 1st and 2nd shift would be the only

ones ensuring that birds were dead before putting

the birds in the DOA cart.  I verified that the bird

was deceased when it was returned to the DOA

cart.  Later, at approximately 12:25 hours, I

discussed this incident with Dane Beall, Plant

Manager.  A copy of this MOI will be sent to

Raleigh District Office.

(b) (6)

(b) (6)

(b) (6) (b) (6)
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80 P46897 IHSAN FARMS, IIC SVH11060

25728G

2018-02-28 04C05 Poultry Good

Commercial

Practices

Finalized At 1000, while performing a poultry good

commercial practices check in the slaughter area,

the following was observed: The male employee

who was transferring birds from the live hang belt

to the moving cone line picked up two birds by

their necks (not their feet/legs) and placed them

into the cones.  Mr. Fernando Wong was

immediately notified and I observed him speaking

with the employee who was mishandling the

birds. Similar mishandling (though picking up

birds by their wings, not necks) has been

documented previously in MOIs.

80 P46897 IHSAN FARMS, IIC SVH37120

44605G

2018-04-05 04C05 Poultry Good

Commercial

Practices

Finalized At 1001, while performing a poultry good

commercial practices check in the kill

room / dressing department, the following poultry

welfare concern was observed: There were 3 live

birds on the ground beneath the feet of the

workers in this area.  The workers were

transferring birds from the live hang belt to the

slaughter cone line or transferring birds from the

slaughter cones to the production line leading to

the scalder.  One male worker was observed to

pick up a bird from the ground by grabbing its

tail.  The worker did not pick up a single leg, only

the tail of the bird.  The bird was placed into a

slaughter cone.  Immediately, I contacted Mr.

Fernando Wong (plant manager) and told him

about my observation and that handling birds by

their tails was a poultry welfare concern.  

was

also present during this conversation.  Mr. Wong

immediately went to speak with the workers

involved in handling the birds.  This is not the

first time that workers at this plant have been

observed handling birds by means other than by

their legs.  In the past, they have been

documented (in MOIs) to pick up birds by their

wing(s) and necks.  My concern is that this trend

continues to be a problem.

(b) (6)


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35 P481 Tyson Foods, Inc. VHF15040

20313G

2018-02-13 04C05 Poultry Good

Commercial

Practices

Finalized On 2/13/18 at approximately 0356 hours the

night shift , observed the

following good commercial practice failure. The

cull basket affixed to the end of the livehang belt

was piled up with numerous small birds. The

chickens in the basket were primarily small and or

sick birds that were piled two to three deep. The

basket was filled with culled birds and the mesh

at the bottom was not visible. One plant

employee was stationed at the basket to

cervically dislocate birds, but was unable to keep

up with the workload. During observation

multiple gasping birds were seen pressed to the

bottom of the pile. I notified

of the issue. 

immediately started culling the birds via the

cervical dislocation and placing their carcasses in

the condemn barrels located at the end of the

line, as is normal for this establishment.  I

observed multiple dyspneic birds, but none that

appeared to have died by suffocation. FSIS

observation continued until all the birds were

euthanized and placed in condemn barrels. I then

left the live hang area and spoke with 

, and 

. I

explained the condition I observed and the

corrective actions taken by . It was

stressed to the livehang employees by plant

management if they observe a large volume of

birds in the cull basket they are to drop a shackle

and assist with cervical dislocation until the

process is back in control. It is not within the

standards of good commercial practice to let birds

asphyxiate, as was the potential outcome of this

incident, and as such is concerning to the USDA.

(b) (6)

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

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

(b) (6)
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90 P509 Koch Foods LLC IPG062101

0318G

2018-01-18 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2140, while performing my GCP

task, I entered the live hang room.  I found a pile

of birds on the floor under the belt.  This pile was

very wide and it reached up to the belt.  There

was one associate trying to take care of the pile. 

There was one spot of the pile that moved.  I

shone my flashlight on it and the associate found

a live bird under others and hung it on the line. 

There were several almost dead birds that he was

euthanizing by disarticulating the head and neck. 

However, the pile was growing almost as quickly

as he was removing carcasses from it.  I went to

the evis floor and had someone radio for the live

hang supervisor to meet me in the live hang room.

I returned to live hang and at that time the

associate called for 2 more people to help him

with the pile of birds on the floor.  

 came in shortly after

me and removed more associates from the line to

help with the pile of birds.  

 also came in. I informed 

and that a prudent

establishment would know that their numbers of

DOAs would be high with these freezing

temperatures and would have more people

available to sort through the birds coming off the

end of the live hang belt.  This would allow any

live birds that made their way off the belt to be

picked up before they were covered, and possibly

smothered, by dead carcasses and any birds that

needed euthanasia could be taken care of quickly

and not covered with dead carcasses.  The

establishment failed to implement any

interventions to prevent this situation and failed

to implement any to quickly address the growing

mound of carcasses allowing live birds and dying

birds to be covered with dead carcasses.   I

informed that I would be writing a

MOI.

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

(b) (6) (b) (6)
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80 P510 House Of Raeford Farms RHB02080

43824G

2018-04-24 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 5:52am on 04/24/2018 while

conducting a Good Commercial Practices

Verification Task I observed a bird on the

evisceration line with neck cuts that was

breathing and headed toward the first scalder.  I

immediately stopped the line before the bird

reached the scalder.  

removed the bird from the line.  The bird was

large, had visible cuts on it’s neck but was

still breathing.  I discussed the issue with 

, and reminded him

that good commercial practices require that birds

must have stopped breathing before they enter

the scalder, and that this bird would have entered

the scalder still breathing if I had not observed it

and stopped the line. The bird was decapitated

with a knife.  had maintenance

working on the issue and it was mentioned that

the stunner was thought to be involved.  

and I then both monitored the line.  He

indicated he was concerned about a bird farther

up the line that had not yet reached the area

where I was standing by the scalder.  I stopped

the line so he could remove the bird before it

reached the scalder.  It had neck cuts but it was

breathing at the time.  Cervical disarticulation was

performed on the bird.  A break was put in the

line by the plant to allow maintenance to work on

the issue

 reported they identified

and resolved an issue with the neck cutter blade.

 I continued monitoring the birds on the line prior

to the scalder and saw no further issues.   I also

discussed the issue later in the morning with

(b) (6)

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

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

(b) (6)
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40 P51179 Sanderson Farms, Inc. RQE46050

34608G

2018-03-08 04C05 Poultry Good

Commercial

Practices

Finalized On 03-07-18 at approximately 0836 hours while

performing GCP in the live hang area I, 

observed multiple Dead On Arrival (DOA)

birds on the floor at the end of the live hang belt

located on the north side of the room. I observed

a production employee placing a live bird into a

red inedible barrel, upon further observation I

found four DOA birds on top of one live bird in the

same red barrel labeled “inedible”.  I notified

 and shown him

the noncompliance.  pulled

both live birds from the red (DOA) barrel and

placed them back on the production line.  The

piling of DOA birds on top of live birds is an

unacceptable practice as it could lead to the

smothering of the live birds. The establishment

has failed to handle the birds properly and

dispose of DOA’s according to GCP regulations.

(b) (6)

(b) (6) (b) (6) (b) (6)
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90 P517 Mar-Jac Poultry-MS QOO17000

12906G

2018-01-06 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Jeff Monroe Plant Manager Mar-Jac

Poultry, MS 1301 James Street Hattiesburg, MS

39401 Mr. Monroe, At approximately 2146

hours on January 3, 2018, the following less than

Good Commercial Practices in Poultry (GCPIP)

incident was observed at P517, Mar-Jac Poultry,

MS, Hattiesburg, MS.   One (1) live young chicken 

with uplifted head, rhythmic breathing, pupillary

reflexes, and no cut to the neck from an

approximate 500 bird random subgroup sample 

entered the scald tank on the north picking line

which feeds evisceration line #1.   A carcass with

head attached consistent with a cadaver,

exhibiting ventral pooling of blood to the neck

and head and a reddish hue exited the 1st picker

on the north picking line at approximately 2150

hours.  The cadaver entered the evisceration

department and was removed at approximately

2151 hours by a plant employee on the rehang

table at the request of 

   The associated paws were rejected.   

 was

notified at approximately 2155 hours and was

given an opportunity to examine the cadaver    A

second verification check of an approximate 500

birds random subgroup sample on the north

picking line at approximately 2156 hours had no

live bird(s) entering the scald tank.  A Dead on

Arrival (DOA) bird was observed entering the

scalder during the second verification.  The DOA

was removed at the rehang table and the paws

were rejected. 

was notified.  This incident was

determined to be isolated event and not a loss of

process control or a systemic event. Allowing

bird(s) to enter the scald tank while still breathing

is a less than GCPIP and causes needless suffering

and death resulting in adulterated product.  

Poultry slaughter establishments must take every

precaution to ensure poultry under their control

(b) (6) (b) (6) (b) (6)
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on the official premises are treated in a humane

manner, subjected to minimal excitement,

discomfort, and injury, or death by means other

than slaughter. Mr. Jeff Monroe, Plant Manager

and met in the USDA office at

approximately 0600 hours on January 5, 2018 to

discuss the less than GCPIP incident.  No response

to the less than GCPIP incident was given at this

time.  Mr. Monroe was advised a GCPIP

Memorandum of Interview would be issued to

management pending review by 

. 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:  Dr. Larry

Davis, DM        Dr. David Thompson, DDM       

Dr. Loraine Dozier, acting DDM        

        

(b) (6)

(b) (6)

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

(b) (6)
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90 P517 Mar-Jac Poultry-MS QOO39060

14224G

2018-01-24 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Jeff Monroe Plant Manager Mar-Jac

Poultry, MS 1301 James Street Hattiesburg, MS

39401 Mr. Monroe, At approximately 2132

hours on January 22, 2018, the following less than

Good Commercial Practices in Poultry (GCPIP)

incident was observed at Mar-Jac Poultry, MS,

Hattiesburg, MS.   One (1) live young chicken 

with uplifted head, rhythmic breathing, pupillary

reflexes, and no cut to the neck from an

approximate 500 bird random subgroup sample 

entered the scald tank on the north picking line

which feeds evisceration line #1.   A carcass with

head attached consistent with a cadaver

exhibiting ventral pooling of blood to the neck

and head and a reddish hue exited the 1st picker

on the north picking line at approximately 2136

hours.  The carcass, with feet attached, was

removed from the evisceration line at

approximately 2137 hours by 

  

 was notified and given an opportunity

to examine the cadaver.  A second verification

check of an approximate 500 bird random

subgroup sample on the north picking line at

approximately 2138 hours did not have any live

bird(s) entering the scald tank.  This incident was

determined to be an isolated event and not a loss

of process control or systemic event. Allowing

bird(s) to enter the scald tank while still breathing

is a less than GCPIP and causes needless suffering

and death and resulting in adulterated product.  

Poultry slaughter establishments must take every

precaution to ensure poultry under their control

on the official premises are treated in a humane

manner, subjected to minimal excitement,

discomfort, and injury, or death by means other

than slaughter. 

and met at approximately 0600 hours

on January 24,2018  to discuss the less than

GCPIP.  No response to the incident was given at

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

(b) (6) (b) (6)
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this time.   was advised a GCPIP

Memorandum of Interview would be issued to

management pending review by 

. 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:  Dr. Larry

Davis, DM        Dr. David Thompson, DDM 

       Dr. Loraine Dozier, acting DDM       

        

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

(b) (6)

(b) (6)
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90 P517 Mar-Jac Poultry-MS QOO18130

21202G

2018-02-02 04C05 Poultry Good

Commercial

Practices

Finalized On February 2, 2018 @ approximately 1212

hours, I observed a less than good commercial

practice while performing an Ante-mortem and

Good Commercial Practices (GCP) check at

Mar-Jac Poultry (P-517). While performing the

GCP, I noticed two moribund birds, one of which

was partially covered with other DOAs, within a

large number of birds piled in a large plastic vat of

DOAs on the back dock. After freeing the partially

covered bird for further examination, I observe a

wing tip of third bird move that was buried

underneath several DOAs in this pile of DOAs. The

two of birds appeared to be in distress, being

unable to ambulate and sparse breathing. The

third bird was observed with rhythmic chest

movements and open, alert, blinking eyes and

uplifted head. The 

 was notified and the birds were

humanely euthanized by rapid cervical

disarticulation which is a practice consistent with

Good Commercial Practices. Comingling live

bird(s) with DOAs can lead to suffocation and

death by means other than normal slaughter

methods. , and

, were

informed of this unacceptable practice. In

accordance with FSIS Docket No. 04-037N,

Treatment of Live Poultry before Slaughter, live

poultry must be handled in a manner that is

consistent with good commercial practices. In

order for this to occur, poultry must be treated in

a manner that will minimize excitement,

discomfort and accidental injury throughout

processing.  A copy of this Memorandum of

Interview will be sent to the Jackson District Office

for further review.  Thanks for your attention to

this matter. Respectfully, 

CC: 

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

(b) (6)

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

(b) (6)
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90 P517 Mar-Jac Poultry-MS QOO38150

23713G

2018-02-13 04C05 Poultry Good

Commercial

Practices

Open Good Commercial Practices MOI: On February

13, 2018 @ approximately 1040 hours, I observed

a less than good commercial practice while

performing an Ante-mortem and Good

Commercial Practices (GCP) check at Mar-Jac

Poultry (P-517). While performing the GCP, I

noticed one moribund bird in a grey vat of

denatured DOA carcasses.  The vat was located on

the side of the unloading dock next to the staged

live haul trailers.  The carcass' head was buried

within the pile of DOAs, as its red stained body

exhibited shallow breathing.  

 was immediately notified of this

finding.  He freed the head of the bird, which

revealed the bird exhibiting shallow

open-mouthed breathing.    He then removed the

bird from the vat and humanely euthanized it by

rapid cervical disarticulation.  

 was also informed of this unacceptable

finding. Comingling live birds with DOAs can lead

to suffocation and death by means other than

normal slaughter methods. In accordance with

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

Poultry before Slaughter, live poultry must be

handled in a manner that is consistent with good

commercial practices. In order for this to occur,

poultry must be treated in a manner that will

minimize excitement, discomfort and accidental

injury throughout processing. A copy of this

Memorandum of Interview will be sent to the

Jackson District Office for further review. Thanks

for your attention to this matter. Respectfully, 

(b) (6) (b) (6) (b) (6)
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90 P517 Mar-Jac Poultry-MS QOO49120

21727G

2018-02-27 04C05 Poultry Good

Commercial

Practices

Finalized Good Commercial Practices MOI: On February

26, 2018 @ approximately 0556 hours, I observed

a less than good commercial practice while

performing an Ante-mortem and Good

Commercial Practices (GCP) check at Mar-Jac

Poultry (P-517). While performing the GCP, I

noticed a live bird in the fecal material/chicken

feather collection vat at the end of the DOA

conveyor. Rain water had collected in this vat

resulting in this bird setting in approximately 8

inches of water up to its head. 

 and 

, were informed of

this unacceptable practice. 

removed the bird from the vat. In accordance

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

Poultry before Slaughter, live poultry must be

handled in a manner that is consistent with good

commercial practices. In order for this to occur,

poultry must be treated in a manner that will

minimize excitement, discomfort and accidental

injury throughout processing.  A copy of this

Memorandum of Interview will be sent to the

Jackson District Office for further review.  Thanks

for your attention to this matter. At

approximately 1050 hours, a meeting was in the

USDA office with 

 and . The incident

was discussed regarding the treatment of a live

bird in the debris vat and preventative measures

for preventing future incidences. 

, indicated that the conveyor

opening will be modified to prevent live birds

from entering the debris vat.   Respectfully, 

I CC:

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)

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

(b) (6)
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90 P517 Mar-Jac Poultry-MS QOO28050

23828G

2018-02-28 04C05 Poultry Good

Commercial

Practices

Finalized Mar-Jac

Poultry, MS 1301 James Street Hattiesburg, MS

39401 , At approximately 2205 hours

on February 26, 2018, the following less than

Good Commercial Practices in Poultry (GCPIP)

incidences were observed at P517, Mar-Jac

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

chicken  with uplifted head, rhythmic breathing,

pupillary reflexes, and no cut to the neck from an

approximate 500 bird random subgroup sample 

entered the scald tank on the north picking line

which feeds evisceration line #1.   A carcass with

head attached consistent with a cadaver

exhibiting ventral pooling of blood to the neck

and head and a reddish hue exited the 1st picker

on the north picking line at approximately 2209

hours.  The carcass, with feet attached, was

removed from the evisceration line at

approximately 2210 by a plant employee.  The

plant employee rejected the paws at rehang. 

was notified at approximately 2212 hours and

given an opportunity to examine the cadaver.  A

second verification check of an approximate 500

bird random subgroup sample on the north

picking line at approximately 2215 hours had one

live bird with uplifted head, pupillary reflexes,

rhythmic breathing, and no cut to the neck enter

the scald tank.   At the exit of the first picker 3

cadavers exited the picker prior to bird entering

the scalder at approximately 2215 hours.  This

bird observed on the second verification exited at

approximately 2219 hours.   No cadavers

observed at the exit of the first picker entered the

evisceration department.   

and were

notified and advised of the cadavers observed

during the second verification on the north

picking line.  A third verification on the north

picking line of an approximate 500 bird random

(b) (6)

(b) (6)

(b) (6)

(b) (6)(b) (6)
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sample was performed at approximately 2228

hours, and no live bird(s) entered the scald tank

during this observation.  These incidences were

determined to be an isolated events and not a loss

of process control or systemic event. Allowing

bird(s) to enter the scald tank while still breathing

is a less than GCPIP and causes needless suffering

and death and resulting in adulterated product.  

Poultry slaughter establishments must take every

precaution to ensure poultry under their control

on the official premises are treated in a humane

manner, subjected to minimal excitement,

discomfort, and injury, or death by means other

than slaughter. and 

 met in the Quality Assurance

office at approximately 2220 hours.   The second

observation at the entrance of the scalder, the

cadavers exiting the first picker, and no cadavers

entering the evisceration department were

discussed.   All cadavers exiting the first picker

were properly shackled.  No response to the

incident was given at this time.  was

advised a GCPIP Memorandum of Interview would

be issued to management pending review by 

 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:  Dr. Larry Davis, DM 

       Dr. David Thompson, DDM        

        

(b) (6)

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

(b) (6)
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90 P517 Mar-Jac Poultry-MS QOO22090

30805G

2018-03-05 04C05 Poultry Good

Commercial

Practices

Finalized Good Commercial Practices MOI: On March 5,

2018 at approximately 0755 hours, I observed a

less than good commercial practice while

performing an Ante-mortem and Good

Commercial Practices (GCP) check at Mar-Jac

Poultry (P-517).   While performing the GCP, I

noticed multiple birds had legs protruding

through the sides of their cages, leaving them

unable to ambulate.  Just before 0600 hours, live

haul trailer #377 was placed in an open area away

from the holding shed.  Once released from the

hitch of the truck, trailer fell over on its side into a

large puddle of mud.  After the cages were

removed from the trailer and placed upright onto

the ground, several birds were left wedged in

between dead birds due to their legs being stuck

in the dried mud.  

 was informed of this finding.

Comingling live birds with DOAs can lead to

suffocation and death by means other than

normal slaughter methods. In accordance with

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

Poultry before Slaughter, live poultry must be

handled in a manner that is consistent with good

commercial practices. In order for this to occur,

poultry must be treated in a manner that will

minimize excitement, discomfort and accidental

injury throughout processing. A copy of this

Memorandum of Interview will be sent to the

Jackson District Office for further review. Thanks

for your attention to this matter. Respectfully, 

(b) (6) (b) (6)
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90 P517 Mar-Jac Poultry-MS QOO53040

35306G

2018-03-06 04C05 Poultry Good

Commercial

Practices

Finalized Mar-Jac

Poultry, MS 1301 James Street Hattiesburg, MS

39401 , At approximately 2055 hours

on March 4, 2018, the following less than Good

Commercial Practices in Poultry (GCPIP) incident

was observed at P517, Mar-Jac Poultry, MS,

Hattiesburg, MS.   One (1) live young chicken 

with uplifted head, rhythmic breathing, pupillary

reflexes, and no cut to the neck from an

approximate 500 bird random subgroup sample 

entered the scald tank on the north picking line

which feeds evisceration line #1.  A second

verification of the north picking line from an

approximate 500 bird random sample had 1 live

bird enter the scald tank at approximately 2105

hours.  The bird was observed with uplifted head,

pupillary reflexes, rhythmic breathing, and no cut

to the neck.  A third verification of the north

picking line at approximately 2110 hours from an

approximate 500 bird random sample had no live

bird(s) entering the scald tank.  

 was  notified

of the less than GCPIP incidences at

approximately 2115 hours.  

 was notified shortly thereafter. 

These incidences were determined to be  isolated

events and not a loss of process control or

systemic event. Allowing bird(s) to enter the

scald tank while still breathing is a less than GCPIP

and causes needless suffering and death and

resulting in adulterated product.   Poultry

slaughter establishments must take every

precaution to ensure poultry under their control

on the official premises are treated in a humane

manner, subjected to minimal excitement,

discomfort, and injury, or death by means other

than slaughter.  and 

met in the USDA office at approximately

0505 hours on March 6, 2018.  The less than

GCPIP incidences were discussed.  No response to

(b) (6)

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(b) (6)

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(b) (6)
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the incident was given at this time.  was

advised a GCPIP Memorandum of Interview would

be issued to management pending review by 

 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:  Dr. Larry Davis, DM 

       Dr. David Thompson, DDM        

        

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

(b) (6)
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90 P517 Mar-Jac Poultry-MS QOO02090

40505G

2018-04-05 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0946 hours on March 30, 2018,

while verifying Good Commercial Practices (GCP)

at P517, Mar-Jac Poultry, MS, the following less

than GCP was observed. and 

 observed on the back dock in the

live hang area one live bird with rhythmic

breathing under a pile of Dead on Arrival (DOAs)

located at the end of the conveyor for the South

picking line. The bird was removed from the pile

placed on the concrete floor of the live hang dock

in preparation for decapitation before being

placed in the DOA bin.

 observed this

breathing bird and was informed of the pending

GCP MOI.     As per Federal Register Notice Docket

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

"Treatment of Live Poultry before Slaughter," the

Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the

slaughter of poultry to make every effort to treat

poultry humanely and abide by Good Commercial

(GCPs) as described by industry guidelines.   

Respectfully,       CC: 

(b) (6)

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

(b) (6)

(b) (6)
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90 P517 Mar-Jac Poultry-MS QOO01150

42618G

2018-04-18 04C05 Poultry Good

Commercial

Practices

Finalized Mar-Jac

Poultry, MS 1301 James Street Hattiesburg, MS

39401 At approximately 0600 hours

on April 18, 2018, the following less than Good

Commercial Practices in Poultry (GCPIP)

incidences were observed at P517, Mar-Jac

Poultry, MS, Hattiesburg, MS. while performing

ante mortem inspection and the PHIS Poultry

Good Commercial Practices task. Trailer #395 and

trailer #1161 has open compartments with live

chickens sitting between the cages.   A number of

cages were observed with missing compartment

doors or missing spring loaded hinges.  Chickens

were also observed in compartments with no

doors.   One live chicken was sitting on the ground

between the 2 trailers.   Three live chickens were

observed loose under the cage dumper, and one

live chicken was observed on the ground at live

receiving with heavy equipment traffic in the

area.  At approximately 0627, one (1) live young

chicken  with uplifted head, rhythmic breathing,

pupillary reflexes, and no cut to the neck from an

approximate 500 bird random subgroup sample 

entered the scald tank on the north picking line

which feeds evisceration line #1.   A carcass with

head attached consistent with a cadaver,

exhibiting ventral pooling of blood to the neck

and head and a reddish hue exited the 1st picker

on the north picking line at approximately 0632

hours.  The cadaver carcass entered the

evisceration department at approximately 0633

hours.   requested the

hot rehang employee to remove the bird from the

table at approximately 0634 hours.   The

associated paws were dumped by the rehang

employee.   

and 

 were notified at

approximately 0636 hours and given an

opportunity to examine the cadaver.   A second

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

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

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90 P519 Wayne Farms LLC KMH02030

10708G

2018-01-08 04C05 Poultry Good

Commercial

Practices

Finalized Wayne Farms LLC 

 525 Wayne Drive Laurel, MS 39440 

, At approximately 0340 hours on

January 6, 2018, the following less than Good

Commercial Practices in Poultry (GCPIP) incident

was observed at 00519-P, Wayne Farms LLC,

Laurel,Ms.  One cage in the repair set-off area by

the fence adjacent to live unloading was found to

contain six birds, four or which were expired; the

remaining two were exhibiting signs of distress ie,

labored breathing and an inability to remain

upright. A discussion with who

had been operating the forklift all night revealed

he had not placed any cages in this area; this was

evidenced by two cages setting at the corner of

the hanging pen area with malfuctioning doors.

This incident was determined to be an isolated

event and not a loss of control or systemic event. 

Allowing birds to remain unprotected in fridgid

tempatures for extended period of time causes

needless suffering and death. Poultry slaughter

establishments should take every precaution to

ensure poultry under their control on official

premises are treated in a humane manner,

subjected to minimal excitement, discomfort,

injury, or death by means other than slaughter. 

 and

 met in the USDA office at

approximately 0430 hours on January 6, 2018 to

discuss the less than GCPIP incident. did

advise USDA that he would have the remaining

birds euthanized by rapid cervical dearticulation.

No response was given as to how or when the

cage in this incident was placed in area. 

was notified that a GCPIP Memorandum of

Interview would be issued to management

pending review by . 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

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

(b) (6)

(b) (6) (b) (6) (b) (6)
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Safety and  Inspection Service (FSIS) strongly

encourages all establishments engaged in the

slaughter of poultry to make every effort to treat

poutry humanely and abide by Good Commercial

Practices(GCPs) as described in industry

guidelines. Respectfully, 

 00519-P, Wayne Farms, Laurel, Ms. 39440 

cc;  Dr. Larry Davis, DM        Dr. David Thompson,

DDM        Dr. Loraine Dozier, acting DDM        

        

(b) (6)

(b) (6)
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90 P519 Wayne Farms LLC KMH15060

12419G

2018-01-19 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1250 hours on January 18, 2018

while performing the Good Commercial Practices

verification task, the following was observed at

the entrance to the scald tank.  The first young

chicken was seen entering the scald tank with an

uplifted head, pupillary reflexes, rhythmic

breathing, controlled movements and a cut across

the base of the beak (did not penetrate any

vasculature).  was

present at the scald tank as well and the bird was

pointed out to him.  He attempted to stop the line

to remove the bird but was unsuccessful. 

Additional birds that appeared in the exact same

manner as the one described above were unable

to be removed from the line and entered the scald

tank live at 1253 and 1254.  During this time

period had called for

maintenance to come work on the equipment. 

Between 1254-1259 an additional six birds that all

appeared the same physically as those previously

described were pointed out by USDA to

Supervision and two establishment employees

just prior to entering the scald tank live.  The

establishment employees manually decapitated

these six birds prior to them entering the scald

system.  At 1300 an additional live bird with an

uplifted head, that was looking around, blinking,

had pupillary reflexes, controlled movements,

rhythmic breathing and a superficial abrasion that

just removed the top layer of skin over the center

of the throat was just about to enter the scald vat

live.  USDA pointed this bird out to the

establishment workers and they manually

decapitated this bird as well. 

was informed that this would be documented as a

GCP MOI.  He was also informed that the

establishment had already gotten one GCP NR

earlier this week and FSIS takes live birds entering

the scald system very seriously.  This cannot

continue to occur, please provide USDA with more

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


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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:  Dr. Larry Davis, DM 

       Dr. David Thompson, DDM        Dr. Loraine

Dozier, acting DDM       

       

(b) (6) (b) (6)
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90 P519 Wayne Farms LLC KMH33220

15421G

2018-01-21 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0735 hours on January 20, 2018

while performing the Good Commercial Practices

verification task, the following was observed at

the entrance to the scald tank.  The first young

chicken was seen entering the scald tank with an

uplifted head, pupillary reflexes, rhythmic

breathing, controlled movements and a cut

towards the back of the head that did not pen

etrate any of the major vasculature effectively. 

This bird was hanging in the shackle by one leg. 

 was in the area and

immediately informed of my observations and

that documentation would occur.  Additional live

birds entered the scald vat at 0736, 0737 and

0745.  All appeared physically the same as the

first bird described and were hanging in the

shackle via one leg except the bird that entered

the scald system at 0736.  The only physical

difference in this bird was that it was in the

shackle hanging by two legs instead of one. Past

similar NR KMH5112010417N / 1 dated January

16, 2018 in which previous preventative measures

either were not implemented or were ineffective. 

Also, past similar GCP MOI KMH3816013518I

dated January 18, 2018 for similar conditions in

which live birds entered the scald vat. Live bird(s)

entering the scald system live is a less than Good

Commercial Practices and results in adulterated

product. The establishment is responsible for

ensuring that birds under their control on the

official premises are treated in a humane manner

that will minimize excitement, discomfort, injury

and/or death by means other than slaughter. As

per Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live

Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of

poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

(b) (6)
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Practices (GCPs) as described by industry

guidelines.  A copy of this Memorandum of

Interview will be forwarded to appropriate

personnel in the District Office.  Respectfully

submitted on January 20, 2018 

 Cc: Dr. David Thompson, DDM 

(b) (6) (b) (6)
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90 P522 Sanderson Farms, Inc. (Processing Div) IKB281804

4926G

2018-04-26 04C05 Poultry Good

Commercial

Practices

Finalized April 26th, 2018 To: 

 Sanderson Farms, P-522 Today, April

26th, 2018, the following was observed by me, 

 at P-522, Sanderson Farms, in

Collins, Mississippi: At approximately 1400

hours, I was informed by USDA IPP that one of the

picking lines (the “outside” picking line) was not

running due to a mechanical issue. At

approximately 1450 hours I proceeded to the live

hang area to conduct a Good Commercial

Practices task. In the live hang area I observed

that the picking line in question was not running

and there were no birds hanging in the shackles

on this line in the live hang area. I proceeded to

the stunner entrance and observed five (5) live

birds hanging in shackles at the entrance to the

stunner. The stunner was full of birds and

appeared to be turned “off” and drained. I could

not tell if the birds in the stunner were alive or

not. The five birds at the stunner entrance were

alive, and were breathing rhythmically, moving

their bodies and heads, and opening and closing

their eyes. I informed 

of my findings. 

removed four of the live birds from the line at

1452 hours. I stated that there was still one live

bird hanging in the shackles at the stunner

entrance. said that the bird could not

be removed from the shackles. I asked how long

the line had been stopped. stated that

the line had been down for approximately one

hour. I located ,

and informed him of my findings and stated that

this incident would be documented in a Good

Commercial Practices MOI. 

proceeded to the stunner entrance and we

observed the remaining live bird together. 

said that the bird could not be removed

from the shackles. Mr. Barry Sparks, Plant

(b) (6)

(b) (6)

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

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

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Manager, also observed the bird at this time. At

approximately 1503 hours the picking line began

to run and 8 live birds immediately emerged from

the scalder exit. Establishment employees

removed the birds from the line and euthanized

them. The picking line was run further, and

approximately 10 dead birds emerged from the

stunner, followed by two more live birds.

Establishment employees removed the dead birds

from the line and disposed of them, and then

removed the live birds from the line and

euthanized them. At 1505 all of the affected birds

had been removed from the line and disposed of. 

On April 25th, 2017, a similar incident occurred in

which birds were left suspended in shackles in or

near the stunner during a prolonged line

stoppage. This was documented in GCP MOI

#IKB5818050025I. On July 25th, 2017, a similar

incident occurred in which birds were left

suspended in shackles in or near the stunner

during a prolonged line stoppage. This was

documented in GCP noncompliance record

#IKB3219072625N/1. The treatment of live birds

before slaughter is an important animal welfare

concern. Live birds left suspended upside down in

the shackles for a prolonged period of time in the

event of a line stoppage may suffer and/or die. A

prudent establishment would operate equipment

that permits removal of live birds from the

production line in the event of a line stoppage. 

Stunning is not a regulatory requirement in

poultry but is commonly used in poultry slaughter

to render the birds immobile and insensitive to

pain. If the stunner is left “on” during a line

stoppage, birds left in the stunner may die of

means other than slaughter (eg. drowning or

electrocution), although a properly functioning

stunner quickly renders the birds unconscious. If

the stunner is turned “off”, drained, and the birds

are allowed to recover consciousness, the

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25 P529 Pilgrim's Pride Corporation ODE19000

20009G

2018-02-09 04C05 Poultry Good

Commercial

Practices

Finalized On February 4, 2018 at approximately 9:30 PM,

while performing a Good Commercial Practices

Verification Task, , asked 

to report to the Live Hang Area.  

 reported that the plant was experiencing a

higher than normal amount of Dead on Arrival

(DOAs) birds in the first load of the shift (Table 1.

Inspection results for lot 36A, Poultry Cadaver

Summary for District 25(not attached)).   The

floor by the dead bird augur from the Live

Transfer System was strewn with approximately

50 dead chickens and more were being delivered

to the augur every minute.  Approximately 5

establishment employees were disposing of the

dead carcasses. Gross examination of these birds

revealed no remarkable pathology indicating a

flock disease.  The dead chickens I examined were

cold to the touch and stiff.  The breast

temperature of four dead chickens was taken with

a calibrated thermometer and ranged from 38 to

67 degrees F.  The live birds I observed in the

crates were slow moving and their heads were

tucked back.  Many appeared to be dead, as they

were not moving or breathing.  Post-mortem

pathology observed in live slaughtered birds from

this lot was unremarkable.  Rates of Sep/Tox, Air

Sacculitis, and Inflammatory Process etc., did not

indicate any abnormal flock disease(s) (Table 1.

Inspection results for lot 36A). The outside

temperature was less than 0 degrees F (reported

by www.weather.com) in Arcadia, WI and the

plant reported that the birds had come from a

grower close to .  

 is approximately  miles from Arcadia, WI

(reported by www.googlemaps.com).  The mean

temperature for the day in 

(reported by www.weather.com) was -6 degrees F

with a maximum high of 2 degrees F.  The

maximum cold weather protective panels on

livestock haulers were in place during transport

(b) (6)

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

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

(b) (4)
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and holding of the birds.  The plant ensured all

dead birds were properly disposed of and the load

was finished with no further incident.  The plant

subsequently reported that of the birds in

lot 36A, 6,093 were DOA, a rate of (Table 1.

Inspection results for lot 36A).  This is above their

normal rate of over the last year and the

 from the month of January, 2018 (Poultry

Cadaver summary for District 25(not attached)). 

 discussed this situation

during the weekly meeting on February 6, 2018

with establishment management, Mr. Bruce Ford,

Plant Manager at 10:00 am.  The plant informed

him they were investigating the incident to

ascertain the cause and prevent it from happening

again.   informed Mr. Ford that this

incident was concerning to him and he asked Mr.

Ford what corrective actions and/or preventive

measures the plant would be taking (or had

taken) to ensure that this incident wouldn’t

happen in the future. Mr. Ford explained that the

plant was investigating the incident further but

provided that they had brought birds over from

 in the past when the

temperature was around 0 degrees F with no

notable incident. He said that they were planning

on bringing over another lot next week from 

 but they decided to cancel this lot

until they could investigate this situation more

thoroughly. Finally, Mr. Ford said that the

establishment documented the animal welfare

incident in their animal welfare plan. The

establishment must employ humane methods of

handling and slaughtering consistent with Good

Commercial Practices in a way that minimizes

injury to poultry.  Poultry are to be handled in a

manner that prevents needless injury and

suffering.  Employing humane methods of

handling and slaughtering that are consistent with

Good Commercial Practices increases the

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

(b) (4)

(b) (4)
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likelihood of producing unadulterated product. 

Table 1. Inspection results for lot 36A.     1. DATE

INSPECTED 02/04/2018 2. PLANT NO. 

P-529V-529 3. CLASS OF POULTRY Young

Chicken 4. NO. HEAD IN LOT* 43015 5.

LOT NO(S) (As stated by plant management) 36A

ANTE-MORTEM INSPECTION CONDEMNED ON

ANTE-MORTEM INSPECTION DEAD ON

ARRIVAL 6. NO. HEAD * 7. WEIGHT * lbs.

8. NO. HEAD * 9. WEIGHT * 

lbs. POST-MORTEM INSPECTION 

CONDEMNED ON POST-MORTEM INSPECTION 

10. CARCASSES (NYD) * . 11.

PARTS * 12. TOTAL NO. HEAD

CONDEMNED/DISPOSED OF ** 1030 

CONDEMNATION CAUSE NO. HEAD

CONDEMNED CONDEMNATION CAUSE NO.

HEAD CONDEMNED CONDEMNATION CAUSE 

NO. HEAD CONDEMNED Tuberculosis 0 

Bruises 0 Inflammatory Process (IP) 0 

Leukosis 0 Cadavers 28 No Viscera

(NV) 0 Septicaemia and Toxemia 37 

Contamination 0 Plant Rejects 963 

Synovitis 0 Overscald 0 Miscellaneous 

0 Tumors 1 Airsacculitis 1

(b) (4) (b) (b) (4) (b) (4) (b) (4)
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60 P533 Hain Pure Protein Corporation - FreeBird

East

AKB072002

3526G

2018-02-26 04C05 Poultry Good

Commercial

Practices

Finalized On February 19 at 0430 at P533 Hain Pure

Protein Inc., the online inspector at inspection

stand number 3 called me, ,

to examine a suspected Cadaver that was

removed from the evisceration line.  When I

arrived, the 

, was present.  Upon examination the

carcass was diffusely hyperemic and congested,

especially the head.  In addition, the carcass was

intact including the head and there was no

evidence of a ventral cervical incision or

exsanguination.  The lack of exsanguination and

condition of the carcass are evidence that the bird

was not properly exsanguinated and entered the

scalder alive. I condemned the carcass and

proceeded to the kill area. I observed the back-up

killer and noted that he was incising an increased

number of birds. I examined the stunner and kill

machine.  Several birds exiting the stunner lacked

an arched neck and tucked wings and gave the

appearance of an ineffective stun. 

 was present in the

kill area and stated that he had checked the water

level and salt concentration in the stunner. He

also stated that he had verified the height of the

blade in the kill machine. I asked him to check

and verify the proper voltage supplying the

stunner.  As I was leaving the kill area a plant

employee was removing a grey inedible barrel

from the hot rehang area that contained

additional cadavers.  At the time of my inspection

the kill machine and back up killer appeared to be

resulting in birds exiting the blood tunnel that

appeared to be appropriately exsanguinated and

not breathing so regulatory control action was not

taken. Birds dying by means other than

slaughter is evidence of a process out of control

and represents noncompliance with 9 CFR

381.65(b).

(b) (6)

(b) (6) (b) (6)
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60 P533 Hain Pure Protein Corporation - FreeBird

East

AKB502105

4301G

2018-05-01 04C05 Poultry Good

Commercial

Practices

Finalized On 5/1/18 at establishment P533 Hain Pure

Protein at approximately 2015 hours, I, 

 went to live receiving to

investigate after one of the food inspectors found

a DOA on the line. I noticed that the DOA table

was full and there were approximately 10 DOAs

that had fallen onto the floor. 

went out to the holding area to look at the trucks

and informed me that the side panels were still in

place, despite the warm temperature of

approximately 75 degrees. The fans were also on

in the holding area. I went out to inspect the

trucks and and I saw that many of the

birds were panting or lying on their backs, and we

could see a larger than normal number that were

dead. At 2030 hours we spoke with Tom Cazee,

Assistant Plant Manager, about why the panels

were still on the trucks, and we were told that the

panels are not put on and taken off in response to

fluctuations in temperature, but instead are put

on in the fall and taken off in the spring. Tom said

that because the weather forecast for this week

shows the temperature increasing to mid-80s,

they would begin the process of removing the side

panels from the cages. requested that a

plant employee add up the DOA numbers for lot

#1, which totaled 317. At approximately 0330

hours, I went to live receiving to do a Good

Commercial Practices check and found that a

single live bird had been placed in the auger. I

immediately notified 

 and he removed the bird from the

auger. I also notified Tom Cazee that I would be

documenting this incident; he later stated that

the employees working in the live hang area had

been re-trained.

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

(b) (6)

(b) (6)

(b) (6)
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25 P544 Jennie-O Turkey Store Sales KXJ220401

3904G

2018-01-04 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 4:00 AM on the night of January

3, 2018 I was observing the live hang operation,

verifying Good Commercial Practices and

observed a live hang employee toss a DOA carcass

down the stairs toward the "USDA Condemned"

barrel for condemnation.  Upon closer observation

of that carcass I saw that the skin had been peeled

off the entire back of the bird.  I showed 

and said that it looked like that bird had

been abused. I then went upstairs and

summoned ) who

also wanted to see the carcass.  He met me

downstairs and I showed him the carcass.  He

took some photographs of it to send to the live

hang foreman.  He explained that he thought it

looked like a loader issue.  I asked if a loader

machine can snag the skin of a bird, and he

replied that it probably could.  He told me that he

would call the loading crew's management and

discuss this finding with him to launch an

investigation and develop a plan for preventive

action.The investigation at the loading crew's

level yielded the following.  The loader head had

jolted and gotten stuck in a cage on the truck. 

Maintenance personnel were called out to the

farm to remove the loader head from the cage,

and upon its removal there were two damaged

turkey carcasses discovered and removed from

the cage.  It is believed that the one that arrived at

the plant as a DOA was a third one that also was

damaged in the incident, but was not discovered

out at the farm.  This incident appears to be the

result of an isolated, mechanical malfunction.

(b) (6)

(b) (6)
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25 P544 Jennie-O Turkey Store Sales KXJ520301

5711G

2018-01-11 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 23:00 on the night of January 7,

2018 I was called to the inside inspection line,

where had retained

two birds for my examination.  He had retained

them in order to alert me that they both were

seriously bruised.  Each of them was bruised on

one entire side of its body.  Concerned about the

possibility that the loading crew may have been

abusing birds, I summoned 

 to look at them as well.  He did

so and took some photographs.  He also said that

he would contact the loading crew's management

to initiate an investigation. During follow up

conversation with him, informed me

that the loading crew management reported that

their loader machine's head belt was not

functioning properly for two nights.  This problem

did not get reported until the second night, and

when it did get reported, the head belt was

replaced.  I asked how such a malfunction could

create the evidence that we were seeing in the

birds and was told that a malfunctioning head

belt could create a pinch point that may have

affected the two birds we saw. It was further

reported to me that the loading crew's

management briefed the loader operator

regarding the procedure he is to follow.  That is,

when something is malfunctioning in any way it is

to be written up for correction right away.

(b) (6)

(b) (6)

(b) (6)
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25 P544 Jennie-O Turkey Store Sales KXJ580701

0317G

2018-01-17 04C05 Poultry Good

Commercial

Practices

Finalized P544-Jennie-O Turkey Store, Melrose, MN Good

Commercial Practice (GCP) Poultry Mistreatment

Memorandum of Interview (MOI): The following

is a documentation of observations and

discussions with 00544P/Jennie-O Turkey Store,

Melrose, MN establishment personnel regarding

the observation of a live bird run over by a trailer

in the live haul area, and the carcass allowed into

part of the processing flow: During GCP

verification on the 17th of January around

07:00am, I observed in the live hang area the live

haul lead checking under trailer 0706M and

collecting a live bird picked up underneath.  As

the trailer left the bay, I observed a live bird on

the trailer lift flopping around on the ground,

unable to right itself, with blood stained feathers

along its neck.  The neck skin was ruptured and

the skull abnormally shaped.  I was unable to

assess the bird, as 

retrieved the bird and handed it to a live hang

employee, who hung it on the shackle line.  The

bird demonstrated an agonal flapping pattern

when hung on the shackle line and the wings

went flaccid.  The bird did not move going around

the shackle line turns or hold up its head, and

appeared unresponsive going through the water

stunner.   The bird was observed flaccid going

through the cut machine and was manually

decapitated after the neck cut machine.  

informed me that he would remove the carcass

from the shackles after going through the scalder

and pickers and check the carcass for bruising.  I

advised that a bird being run over by a trailer was

not part of the slaughter process; a carcass that

didn’t die by means of slaughter should not be

knowingly allowed into the slaughter process. 

The identified carcass came through the pickers at

7:13am, was removed and condemned by

. Correlation with on

the 18th of January included review of corporate

(b) (6)

(b) (6) (b) (6)(b) (6)
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policy regarding humane handling and slaughter

of injured birds.  discussed the

practice of hanging injured birds on the shackle

line to be electrically stunned then slaughter cut

to be humanely slaughtered.  I asked if there was

any policy regarding moribund and birds hung on

the shackles that die before they can be

electrically stunned and slaughter cut, as observed

yesterday.  I also asked about corporate policy

definition for injured birds eligible for this style of

slaughter or assessment for consciousness to

identify injuries rendering birds who died by

means other than slaughter.  The corporate policy

includes other approved methods for humane

slaughter, and does not include definitions or

parameters for injured birds entering the shackle

process for humane slaughter.  With respect, 

 P544

(b) (6)

(b) (6)
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90 P548 JCG Foods of Alabama, LLC WYI431702

4623G

2018-02-23 04C05 Poultry Good

Commercial

Practices

Finalized On the date of February 23, 2018 at

approximately 1728 hours, I observed less than

Good Commercial Practices while performing an

Ante-Mortem Inspection and Good Commercial

Practices verification task at P-548, a NPIS poultry

establishment. I observed a live, uncut bird at

approximately 1728 hours as it was

approximately 8 inches from entering the scald

vat on Line 2. The bird was holding its head

up vertically against its body, exhibiting normal

eye movements, and displaying an increased

breathing pattern. After observing the bird I

employed the available stop button after all other

plant interventions had been surpassed, and it is

reasonable to conclude that had I not intervened,

the bird’s entrance into the scald vat was

imminent. 

 walked over to address

the issue, and then I restarted the line after

corrective action had been taken and the bird was

removed from the line.  I examined the bird

closely and a cut had not been made on the bird. 

I also notified Plant Manager, Amy Patterson and

, of the

observed deficiency, and the

establishment immediately initiated

further corrective actions. It is pertinent to add,

as of May, 2013, JCG Foods of Alabama provided

the additional process forethought to provide a

process for personnel to intervene and prevent

birds entering the scald vat alive and dying by

means other than slaughter.  Line stoppage

devices were installed on both lines to

accommodate these circumstances. FSIS Docket

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

Slaughter, states that under the Poultry Products

Inspection Act (PPIA) and Agency regulations (9

CFR 381.65 (b)), live poultry must be handled in a

manner that is consistent with good commercial

practices. In order to ensure that poultry is

(b) (6)

(b) (6)
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handled and slaughtered in a manner that is

consistent with good commercial practices,

poultry should be treated in such a manner as to

minimize excitement, discomfort, and accidental

injury throughout processing. Additionally, the

Poultry and Poultry Product Inspection Act states

within (21 USC 10 453 (g) (5)), “For purposes of

this chapter... The term “adulterated” shall apply

to any poultry under one or more of the following

circumstances (5) if it is, in whole or in part, the

product of any poultry which has died otherwise

than by slaughter." A copy of this Memorandum

of Interview will be forwarded to the appropriate

personnel in the District Office. Respectfully

submitted on February 23, 2018. 

(b) (6)
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO072002

4206G

2018-02-06 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1830 hours in the Evisceration

Department I observed large gaps of empty

shackles, and I discovered the cause to be a

breakdown in the live-hang area.  I observed two

carcasses in the blood tunnel area with signs of

ante mortem injury, including torn skin,

hemorrhage and muscle mutilation.  One turkey’s

skin was torn to reveal the entirety of both

underlying breasts, both of which were

superficially mutilated.  Another turkey was

missing a 4 x 6 inch patch of skin over its left

breast with bright red blood staining the

surrounding feathers.  The underlying exposed

muscle tissue in both turkeys was moist. After

speaking with , I

learned that the injuries were caused by a faulty

conveyor belt in the CO2 stunning system that

caused a blockage and pile-up of birds within the

tunnel.  I spoke with 

who informed me that this was not the

same belt that broke on 2/2/2018 as is

documented in GCP MOI UIO3819022406G.  He

said that an establishment employee noticed the

break and was able to shut the system off

relatively quickly.  The conveyor belts on the

affected side of the system were left off for the

remainder of the shift; after the shift was

complete, had the maintenance

crews examine every aspect of the rest of the

system. I did not observe any additional injuries.

(b) (6)

(b) (6)

(b) (6)
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO381902

2406G

2018-02-06 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1600 while performing a Good

Commercial Practices Task in the live hang area, I

observed a number of carcasses with signs of ante

mortem injury.  I observed the carcasses as they

passed through the blood tunnel area.  There

were 12 carcasses over an approximately 15

minute observation window with varying degrees

of injury, which included freshly torn skin,

hemorrhage, and muscle mutilation.  All 12 had

freshly torn skin.  The less-affected carcasses had

patches of torn skin, primarily on the backside of

the carcass, which covered an area approximately

4 x 4 inches.  The underlying exposed tissue was

moist with varying amounts of bright red blood

staining the surrounding feathers.  One carcass

had an approximately 4 x 4 inch skin tear over its

left breast.  One carcass had torn skin from the

entire dorsal surface of the tail and extending

cranially up the lower back approximately 6-8

inches.  Two carcasses had torn skin from the

dorsal tail extending laterally to include the lateral

surface of the proximal halves of both thighs, and

extending cranially up the lower back; in addition

to the torn skin on these two carcasses, the

exposed underlying muscle tissue of the thighs

and back was mutilated. After speaking with

 and 

, I learned that the

injuries were likely caused by a faulty conveyor

belt in the CO2 stunning system which caused a

blockage and pile-up of birds within the tunnel. 

This belt had been broken down for much of 1st

shift and the beginning of second shift.  

 said he would have maintenance adjust

the belt as soon as possible.  said he

would ensure that all employees are reminded

that if a blockage occurs, they are to shut the

conveyors down immediately. I did not observe

any further injuries outside of that approximately

15 minute window at 1600.

(b) (6)

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

(b) (6)
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO511502

0921G

2018-02-21 04C05 Poultry Good

Commercial

Practices

Finalized On 2/19/2018 while performing a Good

Commercial Practices task in the blood tunnel

area, I observed 12 turkeys with torn-skin injuries

between approximately 16:46 hours and 17:08

hours.  These injuries ranged in size from

approximately 1 x 2 inches up to approximately 8

x 6 inches, with most somewhere in between.  

For most of the injuries, the exposed tissues were

moist, and the surrounding feathers were

blood-stained.  There was clotted blood present

adhered to some of the injuries, and some of the

exposed tissue in at least two injuries was

beginning to dry.  These injuries were all located

on the turkeys’ backsides and included the dorsal

surface of the tail, over the hips and over the

shoulders.  One turkey had a large tear over its

hips and a separate tear over its shoulders.  I

observed one additional turkey with a 1 x 2 inch

skin tear over the dorsal surface of the tail at

approximately 18:26 hours. 

 and 

inspected conveyor belts of the CO2 stunning

system and did not find any probable cause for

the injuries.  Most of these turkeys came from the

same trailer, #5186, and and 

 did not find any probable cause for the

injuries there either.  As part of his investigation,

 instructed the establishment

employees who were unloading the turkeys from

the trucks to set aside any turkeys with skin-tear

injuries; none were found.

(b) (6)

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

(b) (6)

(b) (6)
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO192102

0926G

2018-02-26 04C05 Poultry Good

Commercial

Practices

Finalized On 02/21/2018, during the second shift at P579, I

observed three issues relating to Poultry Good

Commercial Practices.  Four turkeys were

observed in the blood tunnel with recent injuries,

the packing densities in multiple coops of one

trailer were such that turkeys were standing over

top of each other, and there were many turkeys

that were dead-on-arrival (DOA).  All turkeys run

on this shift were from the same grower and lot. 

At approximately 14:06, I observed three turkeys

with torn-skin injuries on their backsides.  Two of

the injured turkeys had torn skin of approximately

4 x 4 inches on their mid-back over the cranial

hip.  The third turkey’s torn skin extended from

the dorsal aspect of the tail to the mid-back, with

a total area of exposed underlying tissue

approximately 6 x 8 inches.  The exposed tissue

on all three turkeys was moist, and the

surrounding feathers were stained with blood.  At

14:14, I observed one turkey with an

approximately 6 inch long laceration of skin and

underlying tissues running parallel and just lateral

to the spine over the right hip.  The wound was

moist and the surrounding tissues were stained

with blood.  I documented similar injuries in GCP

MOI UIO4114020519I from 02/19/2018. I

observed trailer #5578 as it was parked in the

staging shed outside.  I observed three coops in

the trailer that were so densely packed that the

turkeys were essentially in two layers, standing

over top of each other.  The back half of this

trailer was empty.  

said that with the cold weather and with

many of the old breeder hens missing so many

feathers, it is important to pack them into the

coops so they are tight enough to keep each other

warm.  and 

will discuss packing densities with the

crew responsible for loading the trailers. While

observing in the live-hang area, I noticed that the

(b) (6)

(b) (6) (b) (6)
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DOA bin was already full very early in the shift. 

Following up on this observation, I found a

percent DOA for that lot was 2.76%.  There was a

lot run earlier on first shift from the same grower,

and the percent DOA for this lot was 3.21%. 

Treating the two lots as one population, the

percent DOA was 2.86%.  To put this percentage

in context, I analyzed PHIS slaughter data from

the past year.  From 02/01/2017 through

02/21/2018 there were 273 slaughter days. 

During this period, there were 14 days in which

the percent DOA exceeded 1%.  Of these 14 days,

there were 9 days in which the percent DOA also

exceeded 2%, and 3 days in which the percent

DOA also exceeded 3%.  As on 02/21/2018, “old

breeder turkeys” represent thirteen of the

fourteen >1% DOA days, eight of the nine >2%

DOA days, and two of the three >3% DOA days. 

While the age of these turkeys may have

contributed to the high DOA rate seen on

02/21/2018, of the 64 days in which old breeder

turkeys were run between 02/01/2017 and

02/21/2018, there were 51 days in which the

DOA rate was less than 1%.  I am concerned that

packing density also contributed to the high

percent DOA and the observed injuries.
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO081902

5428G

2018-02-28 04C05 Poultry Good

Commercial

Practices

Finalized Between approximately 14:35 and 14:42, I

observed 5 turkeys in the blood tunnel area with

various injuries including torn skin and muscle

mutilation.  All injuries appeared to be relatively

fresh.  After 14:42 I did not observe any additional

injuries.  The first turkey had an approximately 2

x 6 inch patch of exposed muscle on the lateral

aspect of the right drum, extending from the hock

to the knee.  There was blood around the margins

of this injury and the exposed muscle tissue was

moist.  The second turkey had an approximately 6

x 6 inch patch of exposed muscle on the right

thigh that was also moist and ringed by a small

amount of blood.  In addition, this second turkey

was missing skin and muscle tissue from the

entire medial aspect of the left drum; the bone of

the drum was exposed on this medial surface for

its entire length.  The third turkey had an

approximately 6 x 6 inch patch of exposed muscle

tissue on the right thigh with additional muscle

mutilation and associated hemorrhage.  The

fourth turkey had an approximately 4 x 6 inch

patch of torn skin and exposed tissue extending

from its mid-back to its shoulders; some of the

underlying muscle near the shoulders was

mutilated with associated hemorrhage.  The fifth

turkey had an approximately 4 x 5 inch patch of

exposed muscle of its left thigh with muscle

mutilation and associated hemorrhage.  

 reported that a group of

turkeys became plugged in the CO2 stunning

conveyor system at approximately 14:25.  It is

possible that the injuries I observed resulted from

this incident, as all the injuries appeared to have

occurred relatively recently, and the torn skin and

mutilated muscle tissue would be expected if

turkeys were pinned down against a moving

conveyor belt.  

 will review surveillance footage from

around this time.

(b) (6) (b) (6)
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO072003

2216G

2018-03-16 04C05 Poultry Good

Commercial

Practices

Finalized Between approximately 16:05 and 16:40, I

observed 11 turkeys in the blood tunnel area with

torn skin in various locations.  One turkey had

three separate tears on its backside extending

from the dorsal surface of its tail up to the base of

the neck.  The injury that included the tail

extended cranially approximately 8 inches and

was approximately 5 inches wide.  There was

another discrete, approximately 4 x 3 inch patch

of torn skin just cranial to the previously

mentioned injury, and a third approximately 1 x 2

inch patch of torn skin near the base of the neck

on the dorsal midline.  I observed three turkeys

with skin torn from the dorsal surface of their

tails, and four turkeys with torn skin from over

their dorsal vertebrae and/or synsacrum on their

dorsal midline.  The sizes of these injuries ranged

from approximately 3 x 3 inches to approximately

4 x 5 inches. There were three turkeys with skin

torn from a breast.  One of these injuries was

approximately 3 x 3 inches, and the other two left

nearly the entire underlying breast muscle

exposed, and one of these was mutilated. The

exposed tissues on all injuries described above

were still moist, so the injuries were relatively

fresh.  and 

were notified, and they observed some of the

injuries with me.  I later spoke with

 about the CO2

stunning system because I wondered if it was

playing a role in the observed injuries.  There

was a component of the delivery system that was

not functioning properly, so to ensure that the

turkeys came out of the system unconscious, the

concentration of CO2 being pumped into the

system was held at a higher level than normal. 

We observed turkeys through windows into the

CO2 system: all were unconscious and still.  The

readout of CO2 levels over time showed that the

concentration had not dipped below effective

(b) (6) (b) (6) (b) (6)
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stunning concentrations.  Therefore, It is unlikely

that the CO2 delivery system played a role in the

observed injuries.  I observed turkeys in the

blood tunnel with and 

around 19:30 and did not observe any fresh

injuries like those observed at 16:05.

(b) (6) (b) (6)
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO312104

5103G

2018-04-03 04C05 Poultry Good

Commercial

Practices

Finalized On 04/03/2018 beginning at approximately

2:00pm while performing a Poultry Good

Commercial Practices Task in the blood tunnel

area, I observed 4 turkeys with torn-skin injuries

on their backsides.  Two of these turkeys had

small patches of torn skin, approximately 1 x 2

inches, on the dorsal aspects of their tails.  The

exposed tissue was moist, and the feathers

bordering the torn skin were stained with blood. 

One turkey had an approximately 12 x 12 inch

patch of torn skin over its mid-back; an

approximately 2 x 2 inch patch of exposed muscle

was mutilated; all exposed tissues were moist,

and the surrounding feathers were stained with

blood.  The fourth turkey had 2 discrete torn-skin

injuries: an approximately 2 x 3 inch patch over

the right hip, and an approximately 6 x 4 inch

patch over its mid-back to the left of midline; the

exposed underlying tissue was moist and the

surrounding feathers were blood-stained.  The

total observation time was approximately 20

minutes. I removed the turkey with the 12 x 12

inch injury from the line for the establishment to

inspect.  I spoke about this bird and observed for

others with and

 explained that

he thought the injuries were the result of old

injuries or scabs that were made worse

somewhere in the process.  I examined the

margins of the injury on the bird I pulled off the

line, and I could not find any evidence of an old

injury; the margins were fresh without scabs, and

it did not appear that any part of the skin flap was

missing or dried out.  I have observed the kinds of

old injuries described by , and

oftentimes a portion of the scab is freshly missing,

and sometimes there is a tear in the skin

extending from the scab.  However, none of the

injuries reported in this MOI or in previous GCP

MOIs I have written would fit into that category. 

(b) (6) (b) (6) (b) (6)
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My primary concern and focus is with fresh

injuries. Plant Manager Jody Long reported that

an investigative team would be observing the

load-out operations at a barn tomorrow, and they

will also observe unloading and hanging here at

the establishment.  The producer will be the same

source of turkeys as today’s birds.

15 P6164A Foster Poultry Farms OIJ152004

0923G

2018-04-23 04C05 Poultry Good

Commercial

Practices

Finalized This establishment utilizes both a "back-up cutter

(live person)" and a "head-puller (machine) as

back up methods to prevent live birds from

entering the scalder. On 4/5/18 at approximately

1658 hours while performing the daily GCP task, I

observed a live, conscious bird which had not

been stunned or cut, approaching the head-puller,

after being missed by the back-up cutter. I

observed that the bird was very small, and was

holding its head too high to be reached by the

head puller apparatus. I motioned to the back-up

cutter, and pointed to the live bird. He walked

over and removed it just after it had passed over

the head-puller without consequence. Without

FSIS intervention, it is reasonable to conclude this

bird would have entered the scalder alive. I

immediately addressed the concern with

This was topic discussed during the weekly

meeting with establishment management which

took place on 4/19/18.

(b) (6)
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90 P6616 Peco Foods of Mississippi IRE041302

5020G

2018-02-20 04C05 Poultry Good

Commercial

Practices

Finalized On February 20, 2018 at 1250 hours while

verifying the Plant's Good Commercial Practices in

Picking Room # 2 I, observed

one of the five hundred birds enter the scalder

while conscious. The Plant otherwise exercised

good control over their slaughter process. I

notified of the

issue. FSIS Docket No. 04-037N, Treatment of

Live Poultry before Slaughter, states that under

the Poultry Products Inspection Act and Agency

regulations, live poultry must be handled in a

manner consistent with good commercial

practices. In order to ensure that poultry is

handled and slaughtered in a manner consistent

with good commercial practices, poultry should

be treated in a way as to minimize excitement,

discomfort, and accidental injury throughout the

process. A copy of this memorandum of interview

will be forwarded to the appropriate personal in

the Jackson District Office.

(b) (6) (b) (6)
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90 P6638 Pilgrims Pride Corporation UDG04210

13703G

2018-01-03 04C05 Poultry Good

Commercial

Practices

Finalized Establishment P6638, Pilgrim’s Pride, January 2,

2018 at ~11:50am At approximately 11:50am,

while observing conditions during Ante mortem

inspection and Poultry Good Commercial practice

task, my supervisor and I observed ~10 or more

birds live and weakened lying under a pile of

approximately 1 to 2 feet of debris and dead birds

in the Live Hang area. Upon inspection of the

birds, there was one plant person clearing out the

pile of birds inside the holding bin, but it wasn’t

sufficient enough to keep up with the constant

moving of birds on the conveyor belt pushing

more loose birds into the holding bin/hopper. I

took regulatory action by instructing all live

hanging personnel to stop hanging immediately

until the live birds were removed from the holding

bin/hopper located at the end of the conveyor

belt.  I informed the 

and told him that the incident of finding

live birds cluttered and suffering in discomfort

with such conditions was not acceptable and the

area should be monitored frequently to prevent

birds from dying by any means other than

slaughter; I informed him that this will be

documented in a MOI. indicated to us

that Pilgrim’s Pride would be assigning additional

personnel to the live hang area to address high

numbers of DOAs whenever there is an

expectancy of higher numbers of DOAs.  also

said that he thought the high number of DOAs

was related to the extreme cold weather. Later in

the day, plant management and I discussed

protocols of animal welfare and procedures of

what can or cannot be allowed when handling

poultry animals from the time the birds arrive

from live receiving on toward the live hang room.

(b) (6)

(b) (6) (b) (6)
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90 P6638 Pilgrims Pride Corporation UDG19180

15110G

2018-01-10 04C05 Poultry Good

Commercial

Practices

Finalized On January 10, 2018, at approximately 1642

hours I observed Less Than Good Commercial

Practice at establishment P-6638 Pilgrim’s in

Enterprise, AL.  While performing a Good

Commercial Practice verification task, I observed

two trailers loads of live birds open mouth

breathing.  The trailer numbers were 220893 and

294 located under the live holding shed.  The

birds had their necks stretched and were rapidly

breathing with their mouths open which are

symptoms consistent with heat stress.  The

trailers had sides present on the cages which had

been installed due to cooler temperatures in

December 2017.  The sides on these cages restrict

air flow during transport and holding.  There was

minimal wind movement and the fans installed in

the holding shed were not turned on.  The air

temperature at the time of my observation was

68 degrees.  The stocking density to the cages

based on lot information provided by the

establishment was birds per cage.  I informed

 of my findings as he

approached me in the outdoor holding shed while

I was performing my verification task.  At the

time, I asked what actions would be

taken for the birds in distress and he stated they

would turn the fans on to increase air movement.

I informed and

 of the

documentation of this Memorandum of

Information (MOI) due to my findings.  I reminded

both members of management that the PPIA and

Agency guidelines require live poultry to be

handled in a manner consistent with Good

Commercial Practices (GCPs) by making every

effort to treat poultry humanely. I strongly

encourage the establishment to review Federal

Register Notice Docket No. 04-037N dated

September 28, 2005, “Treatment of Live Poultry

before Slaughter” for recommendations

(b) (6) (b) (6) (b) (6) (b) (6) (b) (4)
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concerning treatment of live poultry before

slaughter.  A copy of this MOI will be forwarded to

the Jackson District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully submitted, cc. 

; 

(b) (6) (b) (6) (b) (6)
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90 P6638 Pilgrims Pride Corporation UDG54220

30002G

2018-03-02 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2225 hour, I entered the picking

room to monitor the head puller at line 2 as part

of a random Good Commercial Practices check. 

After monitoring for approximately 1 minute, I

saw a live bird bypass the head puller.  The bird

was hung by one leg, eyes were blinking, the

chest area was moving up and down and blood

was visible.  When I stopped the line, I

immediately notified 

who was around the corner from where I was

standing.  came immediately

looked at the bird and left.  

did not remove the bird from the line so I did and

when he returned I handed the live bird to him. 

The bird was cut across the dorsal surface of the

neck, not the ventral surface.  Had the bird been

cut on the ventral surface, the carotid arteries and

jugular veins would have been severed, leading to

the bird bleeding out prior to entering the

scalders.  The line was stopped after the head

puller but prior to the bird entering the scald tank

that was filled with water.  The first scald tank is

no longer maintained at scalding temperatures

but is filled with water which would have led to

the bird dying by means other than slaughter

causing the bird to be a cadaver. I informed 

 and 

 of the

documentation of the Less than Good Commercial

Practice Memorandum of Information (MOI). 

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

Poultry before Slaughter, states that under the

Poultry Products Inspection Act (PPIA) and Agency

regulations, live poultry must be handled in a

manner that is consistent with good commercial

practices. In order to ensure that poultry is

handled and slaughtered in a manner that is

consistent with good commercial practices,

poultry should be treated in such a manner as to

minimize excitement, discomfort, and accidental

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

(b) (6)
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injury throughout processing. A copy of this

Memorandum of Interview will be forwarded to

appropriate personnel in the Jackson District

Office. Respectfully Submitted, 

 CC: Jackson District Office,

Local file

(b) (6)(b) (6)
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90 P6666 Koch Foods of Gadsden, LLC GQH18220

10208G

2018-01-08 04C05 Poultry Good

Commercial

Practices

Finalized On January 8, 2018 at approximately 2028 hours

while performing the Good Commercial Practices

and Ante Mortem task, the following was

observed in live hang.  At the end of the belt that

feeds evisceration line three on the ground there

was a pile of approximately 60 DOAs with

feathers and filth.  I used my flashlight to observe

the pile closer due to movement seen within the

pile.  At least ten live birds were observed

throughout the pile of DOAs.  I asked an

establishment employee if he could please get a

supervisor for me.  

arrived to see the pile of birds and was notified

that live birds were amongst the DOAs and that

these findings would be documented in a GCP

MOI.  Some of the birds were placed back into

production and the weaker ones were humanely

euthanized.  At approximately 2033 I arrived at

the belt in live hang that feeds evisceration lines

one and two.  At the end of this belt there were

approximately 40 DOAs with 4 live birds

intermingled in the pile.  The same establishment

employee that was present and working with

 arrived to retrieve the live birds

once they were notified and place them back into

production.  These birds were in imminent danger

of becoming crushed/suffocating/death by means

other than slaughter.  The establishment is

responsible for ensuring that birds under their

control on the official premises are treated in a

humane manner that will minimize excitement,

discomfort, injury and/or death by means other

than slaughter. As per Federal Register Notice

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

“Treatment of Live Poultry before Slaughter,” the

Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the

slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good

Commercial Practices (GCPs) as described by

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

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90 P6666 Koch Foods of Gadsden, LLC GQH05040

12911G

2018-01-11 04C05 Poultry Good

Commercial

Practices

Finalized On January 10, 2018 shortly after production

resumed following the official USDA dinner break

at approximately 0240 seven cadavers were

observed hanging off to the side of the rehang

belt that feeds evisceration line  Due to

these observations I went to the entrance of the

scald vat that feeds that evisceration line.  At

approximately 0249 the first live bird entered the

scald vat.  This bird was much smaller than the

other birds in the lot (approximately 1⁄2 the size), it

had no cut to the neck, was blinking, had an

uplifted head, pupillary reflexes, rhythmic

breathing and controlled movements.  I asked an

establishment employee in live hang if he could

please get a supervisor for me as I could not

locate one in the area.  Once 

 arrived he was informed of my

observations and that documentation would

occur.  Verification of a 500 bird sample set was

started immediately following notification and at

approximately 0252 a second live bird entered the

scald vat.  This bird had a superficial abrasion to

the side of the neck that did not penetrate any

major vasculature; otherwise it appeared the

same as the first bird described above.  The third

and fourth live birds entered the scald vat at

approximately 0257 and 0259.  These birds

appeared physically just as the second live bird

did.  The fifth live bird entered the scald vat at

approximately 0304.  This bird was average size

compared to the remainder of the birds in the lot,

but had been hung by one leg in the shackle.  The

side of its neck had a superficial piece of skin

missing, no vasculature was penetrated, it was

blinking, breathing rhythmically and had

controlled movements.  After this bird entered the

scald vat verification of 500 birds was completed

with no additional birds entering alive.    Live

bird(s) entering the scald system live is a less than

Good Commercial Practices and results in

(b) (6)

(b) (4)
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adulterated product. The establishment is

responsible for ensuring that birds under their

control on the official premises are treated in a

humane manner that will minimize excitement,

discomfort, injury and/or death by means other

than slaughter. As per Federal Register Notice

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

“Treatment of Live Poultry before Slaughter,” the

Food Safety Inspection Service (FSIS) strongly

encourages all establishments engaged in the

slaughter of poultry to make every effort to treat

poultry humanely and abide by the Good

Commercial Practices (GCPs) as described by

industry guidelines.   My observations are

consistent with less than Good Commercial

Practices. A copy of this Memorandum of

Interview will be forwarded to appropriate

personnel in the District Office.  Respectfully

submitted on January 10, 2018 

 Cc: Dr. David Thompson, DDM 

(b) (6) (b) (6)
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90 P6666 Koch Foods of Gadsden, LLC GQH55080

14831G

2018-01-31 04C05 Poultry Good

Commercial

Practices

Finalized On January 31, 2018 at approximately 0656 hours

while performing the Good Commercial Practices

and Ante Mortem task, the following was

observed in live hang.  At the end of the belt that

feeds evisceration line there was a pile of

approximately 20 DOAs with feathers and filth.  I

used my flashlight to observe the pile closer due

to movement seen within the pile.  There were

two live birds observed throughout the pile of

DOAs.  I remained in the area for several minutes

with my light on the pile looking for an

establishment employee to come to the area to

separate the birds, there were also approximately

15 loose birds on the floor, up the stairs and three

other live birds sitting on top of a pile of dead

birds in another area of the belt.  After

approximately three minutes an employee came

to the area and began separating the birds and

returned the live birds to production.  No

Supervisor could be found anywhere in live hang. 

I went to an office where Supervisors are often at

and found an establishment employee in there

and asked him to please get the Live

Receiving / Live Hang Supervisor for me.  At

approximately 0705 

arrived and was notified of the issues observed in

live hang and that a Good Commercial Practice

MOI would be issued due to the live birds

comingling with DOAs and those birds were in

imminent danger of becoming

crushed/suffocating/death by means other than

slaughter.  The establishment is responsible for

ensuring that birds under their control on the

official premises are treated in a humane manner

that will minimize excitement, discomfort, injury

and/or death by means other than slaughter. As

per Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live

Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all

(b) (6) (b) (4)
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establishments engaged in the slaughter of

poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

Practices (GCPs) as described by industry

guidelines.  My observations are consistent with

less than Good Commercial Practices. A copy of

this Memorandum of Interview will be forwarded

to appropriate personnel in the District Office.  

Respectfully submitted on January 31, 2018 

 Cc: 

 Dr. David Thompson, DDM Dr. Lorraine

Dozier, acting DDM 

(b) (6) (b) (6) (b) (6)
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90 P6666 Koch Foods of Gadsden, LLC GQH55000

23706G

2018-02-06 04C05 Poultry Good

Commercial

Practices

Finalized On February 5, 2018 at approximately 2353 while

performing the Good Commercial Practice Task

the following was observed at the entrance to the

scald vat that feeds evisceration line   A live

bird was seen entering the scald vat that was

hung by one leg, had an abrasion only penetrating

the skin to the right side of the neck.  The bird

was blinking, had an uplifted head, pupillary

reflexes, rhythmic breathing and controlled

movements.  Verification of a 500 bird sample set

was started immediately following this

observation with no additional birds entering

alive.  and

 were notified of the

above findings and that they would be

documented in a GCP MOI.   Live bird(s) entering

the scald system live is a less than Good

Commercial Practices and results in adulterated

product. The establishment is responsible for

ensuring that birds under their control on the

official premises are treated in a humane manner

that will minimize excitement, discomfort, injury

and/or death by means other than slaughter. As

per Federal Register Notice Docket No. 04-037N

dated September 28, 2005, “Treatment of Live

Poultry before Slaughter,” the Food Safety

Inspection Service (FSIS) strongly encourages all

establishments engaged in the slaughter of

poultry to make every effort to treat poultry

humanely and abide by the Good Commercial

Practices (GCPs) as described by industry

guidelines.  My observations are consistent with

less than Good Commercial Practices. A copy of

this Memorandum of Interview will be forwarded

to appropriate personnel in the District Office.  

Respectfully submitted on February 6, 2018 

 Cc: Dr. David Thompson,

DDM Dr. Loraine Dozier, acting DDM 

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

(b) (6)

(b) (6)

(b) (4)
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85 P687 House of Raeford XRA511302

0328G

2018-02-28 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 12 PM on 2/20/18, I met with

Plant Manager – Randy Crapps regarding recent,

recurrent GCP concerns. I discussed the fact that

kill cuts were being seen occasionally through the

head rather than the neck and that some birds

were entering Evisceration with heads completely

attached. There were associated times when birds

were seen that did not bleed out properly. Some

of the birds had macerations of the heads to no

kill cuts. Later, at approximately 15:15 hour, I

observed a bird that had not been properly bled

out on the Evisceration Line at the 

(evisceration) machine before the sorters. During

further system check, I observed 10 birds that had

not been properly bled out in the picking room

after the pickers, head puller, and before entering

Evisceration. There was an employee standing in

the picking room at the entry into evisceration

removing birds that had not been properly bled

out and throwing them into the open drain

underneath the head puller instead of placing

them in condemn barrels to be counted per

customary practice. I followed the line backwards

towards live hang and kill area. It was in that area

I notified and

 They immediately went to the backup

cutting/blood tunnel area. I resumed my system

check in the picking room, where I found six (6)

more birds that had not bled out properly. My

examination of the six birds revealed the cuts

were variable in locations and depth: from no

neck cut to poor or superficial neck cuts to

macerations. I observed other birds that had not

bled out properly with heads attached past the

head puller. I observed one larger size than usual

bird that was a very dark red to purple bird that

had not bled out properly and it had superficial

maceration to the (dorsum) back of attached head

and did not have a neck cut. This one was shown

(b) (6)

(b) (6)

(b) (4)
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to In total, I observed 15

to 16 birds that had not bled out properly within

15 minutes time. Subsequently I conveyed to

Plant Manager – Randy Crapps the findings would

be documented and forwarded to the Atlanta

District Office and the District Veterinary

Specialist (DVMS) in case additional follow-up is

recommended. Additionally, on 2/21/2018 at

approximately 12:30, the plant was stopping and

starting the picking line due to re-hanger issues.

When production resumed as usual at

approximately 13:00, I observed several birds that

had not bled out properly in a condemn barrel.

The birds had no neck cuts to poor or superficial

neck cuts to macerations. I physically showed my

findings to Plant Manager – Randy Crapps. The

corrective actions and preventative measures of

plant management are not preventing

reoccurrence of the GCP findings.

35 P7101 Tyson Foods, Inc. LUC532201

2631G

2018-01-31 04C05 Poultry Good

Commercial

Practices

Open Birds are being slaughtered in accordance with

good commercial practices. Although no birds

were observed being harmed unintentionally or

dying from means other than slaughter at this

time, the current system setup would allow that

to occur. Approximately 15-20 live birds were on

the floor in the live hang area under the conveyer

belt that moves the birds into the live hang area.

These birds are left here during plant breaks as

well and not gathered and hung until the end of

the shift to kill out. Given the amount of birds on

the floor, there is the possibility of stepping on

the birds, injuring or killing them. Albeit small,

there is also the possibility for the birds to wander

back into the other area of the live hang and

outside to where the conveyor belt enters the

building. I discussed this with the 

 and he stated that he

would begin working on a solution. 

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

(b) (6)
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90 P7487 Koch Foods, LLC SPG470704

3111G

2018-04-11 04C05 Poultry Good

Commercial

Practices

Open On Tuesday, April 10, 2018, 

 Jackson District, and 

 visited the P-7487 Koch Foods of Chattanooga

facility. At approximately 11:55 A.M, I 

 accompanied 

 and as

we performed the good commercial practices

check and observed the following in the live

hanging area: There were an estimated amount

of more than one hundred birds piled up on the

floor between 140 picking line carousel and wall.

We observed three live birds in and around the

pile up.   For several minutes, we observed as the

number of live and dead birds accumulating on

the floor continued to increase, with no

establishment personnel visibly observed

addressing the deficiencies. When the live

entered into live hanging area, he started picking

the DOAs off the floor. We asked the

 to stop hanging the

birds. They Quit hanging the birds at 12:02 P.M.,

to 12:10 P.M., and resume hanging the birds after

the process got under control. We had an exit

meeting with the plant manager Mr. Gary Tallent,

, and

, and

explained to them about the finding. As per

Federal Register Notice docket No 04-037N, dated

September 28, 2005,"Treatment of live poultry

before slaughter" the USDA food safety inspection

service strongly encourages all establishments

engaged in slaughter of poultry to make every

effort to treat poultry humanely abide by good

commercial practices. Sincerely, 

P7487 Koch Foods of Chattanooga cc:

 , Jackson District       

, Jackson District       

Dr. Thompson David, DDM, Jackson District

(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)
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80 P764 Perdue Foods, LLC CUA08130

14706G

2018-01-06 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1228 hours, while touring the

receiving department and live hang area, I

observed an enormous pile of chickens, both dead

and alive, at the DOA sorting tank for kill line

number two.  The pile of carcasses was so high

that the birds could no longer fall off of the end of

the five-foot-high conveyor.  The stack of birds

numbered in the hundreds and estimated to be

around five-hundred or so.  There were live birds

observed gasping for breath and attempting to

free themselves from the pile of dead birds on top

of them.  The slaughter operations were halted

until the live birds could be freed from pile the

dead birds.  I immediately informed and

showed 

of these conditions.  I reminded

 that the PPIA and Agency regulations do

require that live poultry be handled in a manner

that is consistent with Good Commercial Practices

(GCPs), and that they not die from causes other

than slaughter. I spoke to 

concerning this issue.  He indicated that the

conditions that existed were unacceptable and

that the persons responsible would be counseled

and disciplined, as per company policy. I printed

a copy of the Federal Register entry on Treatment

of Live Poultry Before Slaughter, published

September 2005, and attached it to this MOI. I

notified that this MOI will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow-up is recommended. 

Respectfully, 

________________________________________ 

(b) (6)

 P-764, Salisbury, MD

(b) (6)

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 250

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P764 Perdue Foods, LLC CUA53120

13431G

2018-01-31 04C05 Poultry Good

Commercial

Practices

Finalized At 1329, while performing a poultry good

commercial practices check in the receiving area,

there was a flapping and kicking bird observed on

top of the bird pile in the DOA dumpster bin.  The

bin was 90% full of birds (approximately 200

birds) and they were all denatured with blue dye,

including the bird exhibiting signs of life. 

was immediately notified (since she had been

accompanying me during the check) and

addressed the live bird immediately. 

 was also notified shortly thereafter.

80 P764 Perdue Foods, LLC CUA30060

20907G

2018-02-07 04C05 Poultry Good

Commercial

Practices

Finalized At 0643, while conducting a poultry good

commercial practices check in the receiving area,

the following observations were made: While

inspecting the large metal dumpster of DOA birds,

there were some birds which were denatured and

others which had yet to be denatured 

,

was in the process of transferring dead birds from

the sorting bins to the dumpster and would

denature upon finishing the transfer).  Amidst

the birds in the dumpster which were not

denatured was a small bird that was observed to

be moving on occasion.  Its leg would move,

observed multiple times within a minute or two. 

, who

was accompanying me during the inspection,

removed the bird from the bin and we observed it

separately on a flat surface.  Slow breathing could

be observed in the flank region, and its leg would

move from time to time.  This bird was obviously

still alive.  The bird was observed for several

minutes, and I had to request it be euthanized. 

The bird's wings were flapping after the

euthanasia (cervical dislocation method).  

was also notified of this finding, about

10 minutes later when I found him on the

production floor.

(b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 251

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA031203

0427G

2018-03-27 04C05 Poultry Good

Commercial

Practices

Open At approximately 0905 hours, one of the Food

inspectors on Evisceration Line#1 identified a

cadaver. She held that carcass for Veterinary

disposition and immediately notified me. Upon

arriving at her station I observed that head of the

carcass was intact with no bleeding cut on neck.

The facial area was swollen; skin around the neck

area was purple in color while rest of the carcass

was bright red in color. 

 and 

) were

notified of USDA findings. I reminded 

that the PPIA and Agency regulations do require

that live poultry be handled in a manner that is

consistent with good commercial practices (GCPs),

and that they not die from causes other than

slaughter. I recommended that 

review the Federal Register on Treatment of Live

Poultry before Slaughter, published September

2005 for FSIS recommendations concerning

treatment of live poultry before slaughter, and

provided her a copy of this document. I notified

 that this MOI will be forwarded to

the District Office and the District Veterinary

Medical Specialist (DVMS) in case additional

follow-up is recommended. Respectfully, 

 P-935 Allen Harim Foods,

LLC

(b) (6)

(b) (6)

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

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 252

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA361803

3930G

2018-03-30 04C05 Poultry Good

Commercial

Practices

Open At approximately 1723 hours while performing

ante-mortem and Good Commercial Practice

verification I observed a bird’s neck caught

between the side edge of the closed cage door

and the cage frame.  Upon further investigation,

the bird’s head was limp and hanging with saliva

hanging from its mouth. 

 was notified of the observation of a

bird dying other by slaughter.  and

 stated that

a picture was taken and was forwarded to 

 and that live haul would be

notified of the observation. 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 Harem Foods, LLC. P-935 Harbeson, DE.

19951

(b) (6)

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

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 253

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA261804

1906G

2018-04-06 04C05 Poultry Good

Commercial

Practices

Open At approximately 1630 hours as I was traveling

between Evisceration Lines 2 and and inspector

called for me and had 2 carcasses hanging on the

Veterinary disposition shackles behind line ,

station 4.  Both carcass bodies and necks were red

in color, and the visceras were blood engorged. 

At approximately 1710 hours I was notified and

observed a cadaver hung on the Veterinary

disposition shackle behind line station 1.  This

carcass’s head and neck were dark red to purple

and had not received a cut to the neck.  At

approximately 1715 hours I observed line

station 2 inspector hang a carcass on the

Veterinary disposition shackle.  This carcass body

and neck were red in color and the viscera were

blood engorged. At each occurrence

 was notified of the cadavers and he

contacted the live hang supervisor of each

observation of cadavers on line I then

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.  

was notified of the observation of bird

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.  

 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) (b) (b) (4 (b) (4) (b) (4
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 254

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA141704

4926G

2018-04-26 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1734 hours, while verifying

Good Commercial Practice verification I observed

both establishment back-up kill personnel on the

same side of the medium bird line just past the

kill blade.  I then walked around to the area where

a second back-up kill employee is usually

stationed and observed 1 bird with its head up,

looking around and breathing.  I then traveled to

the entrance end of the scalder and observe 1 live

bird with its head up, looking around enter the

scalder.  This bird had a small nick to the left side

of the neck.  

and Evisceration Supervisor were notified of

the observation of a bird dying other than by

slaughter.  stated that the employee

would receive disciplinary action.  I then

observed 200 carcasses enter the scalder, and 200

hundred 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 the 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.

(b) (6)

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

(b) (6)
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 255

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA221804

3727G

2018-04-27 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1703 hours while traveling

between Evisceration lines 2 and an inspector

called for me and had 1 carcass hanging on the

Veterinary disposition shackle behind line 

station 1.  The carcass had the head intact which

was red to purple in color and had not received a

cut to the neck.  

was notified of the cadaver

notified 

of the observation of a bird dying other than

by slaughter. I then 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.  was

notified of the observation of a bird 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.  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) (4) (b) (4
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 256

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA401804

3030G

2018-04-30 04C05 Poultry Good

Commercial

Practices

Open At approximately 1509 hours on April 27, 2018

while performing antemortem and GCP

verification I observed 1 loose live bird on trailer

#62 located in the cooling shed.  At approximately

1521 hours I observed 1 loose live bird on trailer

#6886 and 1 loose live bird on trailer #5780 (3

cage doors were open).  These trailers were

located just outside the dumping area in a high

traffic area for trucks and forklifts.  As I was

waiting for the live hang supervisor I observed a

forklift come around the 2 trailers at a very high

speed.  As he rounded the trailers a cage door

flew open and 2 live birds were thrown to the

concrete approximately 6 feet below.   

 and 

 were notified the observation in

which poultry may have experienced excitement,

discomfort or accidental injury while being

handled in connection with slaughter.  

addressed driving speed with the fork

lift drivers especially when making sharp turns.   

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 FOIA2018-328 10:22 Wednesday, May 30, 2018 257

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA352105

4601G

2018-05-01 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1600 hours while traveling

between Evisceration lines 2 and I observed 1

carcass hanging on the Veterinary disposition

shackle behind line station 3.  The carcass had

the head intact which was red to purple in color

and had not received a cut to the neck.  I also

observed 3 carcasses hanging on the Veterinary

disposition shackles behind line station 4. 

The necks of these carcasses were bright red, the

viscera were blood engorged and was petichiation

was observed on the breast meat. I was informed

by the inspector that, at approximately 1507

hours, he had hung back a bird with the head

intact, red to purple in color and had not received

a cut to the neck. 

 confirmed this observation and stated

that he had taken the bird to the Live Hang

Supervisor so that action could be taken.  At

approximately 1655 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.  

was notified of the observation of birds dying

other than by slaughter. stated that as a

preventive he placed a second back-up killer on

line for the rest of the week. 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) (b) (4 (b) (4 (b) (4 (b) (4
Table: MOIs in Response to FOIA2018-328 10:22 Wednesday, May 30, 2018 258

Dist

rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA122105

0514G

2018-05-14 04C05 Poultry Good

Commercial

Practices

Open At approximately 2136 hours while performing

Good Commercial Practice verification I observed

the back up killer for medium birds miss a cut to

the neck of a bird that was not cut by the kill

blade. The establishment employee then

attempted to pull the stunned bird's head off

which failed.  He then removed the bird from the

line and threw it into a condemn barrel used to

put heads into.  Upon further investigation, I

observed two live birds in this condemn barrel

that was approximately one quarter full of heads. 

 and

 were

notified of the observation in which poultry may

have experienced excitement, discomfort or

accidental injury while being handled in

connection with slaughter.  stated that

the employee will be coached and the condemn

barrel will be removed from the area. 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)