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Code TaskName Status MOI Agenda

90 M17250 Tyson Foods, Inc. UQI062201

4004G

04JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On Friday, January 04, 2019 at approximately

2005 hours I performed a good commercial

practice verification in the picking room. I

positioned myself at a point where I can directly

view both lines entering the scald vats. On picking

line initially observed one average size bird,

still breathing with no visible neck cuts, entering

the scald vat. The bird was hanging normally with

its head straight down blinking its eyes. I stopped

the picking line as it reached the scalders because

just as I spotted this bird there was another live

bird approaching on the same line. I motioned for

the backup killer to come and retrieve the birds

that he missed and had a maintenance technician

radio for the 

 and 

arrived first and I shared my findings with them

and later with . After

discussing my findings with management I

performed an immediate retest at approximately

2011 hours; it passed. After management

assessed the situation I had a brief discussion with

 about his assessment and

his further planned actions. I informed him that I

would be documenting a GCP MOI and forwarding

it to the District Office and the District Veterinary

Specialist in case additional follow-up is

recommended. stated that he

instructed his supervisors to increase their

monitoring for the remainder of the shift. He also

stated that he consulted with his 

 about this occurrence. In

addition he noted that there may be a lighting

issue and that the team member will be

disciplined for this occurrence. I returned to the

same vantage point approximately 40 minutes

later and observed line for 10 minutes; no

deficiencies were noted. This incident appears to

be isolated; no regulatory action was taken and a

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

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

(b) (6)

(b) (4)

(b) (4)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 2

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noncompliance record was not written. FSIS

encourages establishments to abide by good

commercial practices in the production of poultry

to ensure a wholesome product is being

produced.  The PPIA and FSIS regulations require

that poultry be handled in a manner that is

consistent with good commercial practices (GCPs),

and they not die by means other than slaughter.

Management can find useful information in the

Federal Register on “Treatment of Live Poultry

before Slaughter”, published September 2005; it

contains FSIS recommendations concerning

treatment of live poultry before slaughter. 

Sincerely, 

 cc   

       

       

       Larry Davis, DVM - Jackson

District Manager

(b) (6)

(b) (6)
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Code TaskName Status MOI Agenda

90 M17250 Tyson Foods, Inc. UQI042101

3823G

23JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On Wednesday, January 23, 2019 at

approximately 1905 hours while performing a

Good Commercial Practice verification after lunch

break, I observed one live bird entering the scald

tank on picking line The bird was of average

size for birds slaughtered at this facility and was

taking deep breaths rapidly while blinking its

eyes. I took a regulatory control action and

stopped picking line since this was a repetitive

issue. Past similar issue occurred 2 weeks prior. I

left my vantage point to find supervision and to

notify them of this occurrence; Live receiving

 responded first. Upon

her arrival I notified her of my findings and of this

forthcoming MOI. A similar occurrence was

documented on 1/4/2019 in

MOI # UQI2620010804I.  After management

assessed the situation I had a brief discussion with

 about his assessment and

his further planned actions. I informed him that I

would be documenting a GCP MOI and forwarding

it to the District Office and the District Veterinary

Specialist in case additional follow-up is

recommended. stated that he

instructed his supervisors to increase their

monitoring for the remainder of the shift and the

next 4 days. Past further planned actions were

implemented but have proven to be ineffective.  I

performed a second verification for 10 more

minutes at approximately 2110 hours; no

deficiencies were noted. This incident appears to

be isolated; no regulatory action was taken and a

noncompliance record was not written.  FSIS

encourages establishments to abide by good

commercial practices in the production of poultry

to ensure a wholesome product is being

produced.  The PPIA and FSIS regulations require

that poultry be handled in a manner that is

consistent with good commercial practices (GCPs),

and they not die by means other than slaughter.

(b) (6) (b) (6) (b) (6) (b) (4) (b) (4
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Management can find useful information in the

Federal Register on “Treatment of Live Poultry

before Slaughter”, published September 2005; it

contains FSIS recommendations concerning

treatment of live poultry before slaughter. 

Sincerely, 

      – Jackson District Manager

(b) (6)
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Code TaskName Status MOI Agenda

85 M17980 Pilgrim's Pride Corporation ZBB541202

4706G

06FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0512 hours while observing

operations in the Picking Room, I observed the

following situation which resulted in

mistreatment of poultry:  There were two (2)

cadaver birds coming down the Kill line.  The birds

were very red in color with the head and necks

engorged with blood.  As I observed the two birds

coming down the line a plant employee removed

the birds from the line after they had transferred

at the auto rehanger from the Kill line to the

Evisceration line.  Those two birds were placed in

the inedible barrel in the Picking Room.  Less than

a minute after that observation, there were three

(3) more cadaver birds I observed coming down

the Kill line and then transferred onto the

Evisceration line.  They were also very red in color

with the heads and necks engorged with blood. 

Upon further examination of the birds, there was

no cervical cut on the necks.   After my

observations, I immediately notified 

 and showed

her my findings.  The birds were then placed in

the USDA condemned containers.  I then went

and observed the Kill line for several minutes after

to ensure birds were being properly cut to allow

thorough bleeding and ensure breathing stopped

prior to the birds entering the scalding tanks. 

According to regulatory requirement poultry are

required to be slaughtered in a manner that is

consistent with good commercial practices and in

a manner that results in thorough bleeding to

ensure that breathing has stopped prior to

scalding.  The establishment 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

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

25 M18866 Jennie-O Turkey Store Sales, LLC WJL30180

32821G

21MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 11:15, while verifying good

commercial practices in live hang, when trailer

number 9905 was brought into the live hang bay I

observed that there was one turkey with a hock

and a wing pinched under the coop gate, second

row down and first column forward, right behind

the driver's side of the truck cab.  As I looked

closer, I also noted that the turkey was on its

back.  I noted that the turkey was still alive, as

evidenced by intermittent struggling movements. 

The bird was unable to right itself, as the wing and

hock were both firmly trapped under the coop

gate, as if the loading personnel had closed the

coop gate while the bird was on its back, with the

two limbs still outside the coop. I notified 

 of my concern, and

he said he would pass this concern on to the

loading crew.

(b) (6)
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Code TaskName Status MOI Agenda

50 M2130 Cooper Farms Processing HEF180201

3829G

29JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On January 4th 2019 at approximately 3:40 AM, 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 were multiple live turkeys visible within the

open cage. I also observed one live turkey that

was loose directly beneath the open cage. There

was a minor observable injury on the turkey’s

right claw (caudal digit) and a corresponding small

amount of fresh blood on the concrete where the

turkey had been standing. A live hang employee

approached and caught the loose turkey, then

placed the turkey in an intact cage on the trailer

and covered the open cage by placing a board

over the row of cages. The topmost trailer cages

are not reachable without the aid of steps or a

ladder and present a significant distance from

these cages to the concrete floor of the cooling

sheds.  An incident similar to that documented

above occurred one year prior on 1/02/2018 (see

MOI #HEF3202013903I).

50 M2130 Cooper Farms Processing HEF200201

5129G

29JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At 3:15 AM on 1/16/2019 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. I spoke with about

what I observed, and she said that 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.

(b) (6)

(b) (6)

(b) (6)
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Code TaskName Status MOI Agenda

05 M27389 Pitman Farms NCO12140

14602G

02JAN2019 04C05 Poultry Good

Commercial

Practices

Open at 085hrs checked trailer at receiving area

---chickens at 0910hrs observation in live hang at

approximately 1100hrs found

trailer Lic.# 4LJ5260 had two damaged modules

(PF-672 and PF-539). Upon closer inspection 

 found what appeared to be chickens dead

inside the modules and tagged the trailer with

NO.B41202485. He informed 

of his findings. asked me to

investigate this incident due to the fact I was

performing the Poultry Good Commercial

Practices task. I spoke with 

 and requested that the two

modules be set aside to allow closer inspection.

After making my observations, I found two

chickens with their heads smashed between the

cage and the framework of the module. I found an

additional dead carcass, but was unable to

determine cause of death.

(b) (6)

(b) (6)

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

(b) (6)
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Code TaskName Status MOI Agenda

25 M32130 Dakota Provisions LLC JEB060601

4608G

08JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. 32130, Dakota Provisions, 1/8/19, 0535

hours.  Meeting Attendance:  

 and 

 On 1/8/19 at approximately

0515 hours while monitoring conditions in pick

and hang, I noticed a bird on the line before the

scalder that was arching his neck and trying to

escape the shackles.  I immediately stopped the

line and informed plant personnel of the

conscious bird about to enter the scalder.  While I

observed this bird on the line, he was able to arch

his neck and blink his eyes.  They grabbed a

portable ladder and pulled the bird off the line. 

The bird had a superficial skin cut only.  No major

vessels were severed.  The bird was then

immediately relocated back on the line before the

neck cutter to start the process over

stated that the cages were not fully loaded so

they might have been run too fast through the kill

machine.  He said they will place an employee

before the neck cutter with the back up manual

bolt stunner to effectively stun the birds that did

not achieve unconsciousness from the kill

machine.  He said they will also have maintenance

adjust the kill machine.  The incident that took

place is a concern due to the neck cut miss and its

path straight to the scalder to drown, as it was

still breathing and fully conscious. 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) (b) (6)
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25 M32130 Dakota Provisions LLC JEB081303

4004G

04MAR2019 04C05 Poultry Good

Commercial

Practices

Open Est. 32130, Dakota Provisions  3/4/19  1045

hours  Meeting attendance:  

 and

 At 0450 am while

performing ante-mortem inspection, I observed

trailer no. 26 that had just arrived and was

missing a side panel.  After a conversation with

the driver, he stated that the cage had a bent bar

which affected the installation of the panel.  I also

noted that trailer no. 14 and 24 were each

missing panels.  I notified manager, of my

findings.  Approximately 30 minutes later, 

 and I went outside again to look at the

trailers under the shed and noted the arrival of

trailer No. 4.  It was also missing a panel and the

driver stated it was because the cage was in

disrepair and one of the panel bars was missing

completely.  It was also noted at this time that

trailer No. 11 was missing 2 panels.  was

again notified of the trailers not appropriately

paneled for the current weather conditions.  Two

US Reject Tags were applied to the cages that

needed maintenance on trailer #4 and #26.   The

ambient temperature was negative 4 degrees

upon arrival to work.  The establishment’s written

procedure for Good Commercial Practices state

  Trailers arriving with missing panels was

previously discussed in a weekly meeting on Feb.

7th.  At 10:45 am, a meeting was held with

 and 

, of the items addressed

above.  The trailers I identified with panels missing

were all from Lot 2.  Lot 2 had 52 birds

condemned at the inspection station as Cadavers. 

There were also 175 DOAs for Lot 2.  Lot 2 had

11,206 birds total.

(b) (6)

(b) (6)

(b) (6)

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

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

(b) (4)
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25 M322A Pilgrim's Pride Corporation CNC48110

23801G

01FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized On 1/29/19 I arrived in the live-hang area to

perform routine ante-mortem inspection. All

trailers were tarped to protect birds during

transportation from wind and cold ambient

temperatures. It was evident on ante-mortem

inspection that there were several frozen birds on

these trailers, as observed through lack of

movement, as well as very cold, live birds. Large

muscle portions like the breast musculature were

frozen solid. Several birds had feet, feathers and

wings frozen to the plastic drawers that hold the

birds during transport in the mods. The

establishment removed the mods from the truck

trailer and opened the drawers in an effort to

remove DOA birds to prevent their entrance into

the facility. However, the concern is with the

number of birds frozen upon arrival and at the

time of slaughter. Inspection personnel perform

observations in cold weather to identify birds

frozen inside cages or to the cages themselves, to

ensure birds are being handled in accordance with

Good Commercial Practices. This issue was

discussed with 

 at 0700 when I noted the frozen birds. After

reviewing the daily totals on this day, the

establishment reported 1299 DOA birds out of a

total count of 43966 birds (3%).  The birds in the

observed trailer above (#56) had arrived at the

establishment at approximately 0123 hours but

not enter the live hang area to be slaughtered

until approximately 0700 hours.  

explained that unintended down time was the

cause of the increased holding times. Subsequent

production shifts were cancelled (the next two

night shifts and two days shifts) due to the cold

weather. The establishment is also looking into a

redesign of the tarping system designed to protect

the birds during transit.  The trailers of birds are

kept tarped in a non-temperature controlled

building, which is enclosed on 3 sides while at the

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 12

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establishment prior to being presented for

slaughter. The establishment does have a written

program with regards to Good Commercial

Practices, but does not have a copy of procedures

to follow in the case of extreme cold weather. The

temperature the night of transport of this trailer

was -15 degrees Fahrenheit before wind chill was

added.
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 13

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25 M322A Pilgrim's Pride Corporation CNC40030

35301G

01MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2330 hours on February 25,

2019, while observing conditions in the live hang

and kill and pick areas, I observed a live chicken

with its eyes open and head raised enter the

scalding tank on line while still breathing.  I

informed 

 of this finding.  

accompanied me back to the kill and pick room

and we both observed a second live bird entering

the scalding tank on line hile still breathing,

with its head raised and looking at us with eyes

open.  attempted to remove the bird

from the line before it entered the scalder, but

could not get to it in time.  There was only one

backup killer stationed after the autoknife at this

time.  Prior to the incident, the CO2 stunner had

not been working and there were awake birds

being hung in live hang.  The backup electrical

stunner was raised and turned on, per protocol. 

 said he would speak with the night

shift live receiving supervisor about having a

second backup killer stationed after the autoknife

when the CO2 stunner was down.   I reminded 

 that the PPIA and agency regulations

require that live poultry be handled in a manner

that is consistent with good commercial practices

and that they not die from causes other than

slaughter.  Later in the shift, at approximately

0400 hours on February 26, 2019, there were

again awake birds on line due to a problem with

the CO2 stunner.  I returned to the kill and pick

room at that time and noted that was

assisting the backup killer and two additional

people were stationed prior to the autoknife on

line I also observed the entrance to the scalder

for approximately 15 minutes, and did not note

any conscious or breathing birds enter the

scalding tank at that time.   I notified 

that this MOI will be forwarded to the District

Veterinary Medical Specialist (DVMS) in case

(b) (6)

(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 FOIA2019-259 12:20 Thursday, March 28, 2019 14

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additional follow-up is recommended.  

Sincerely, P322

60 M45134 Birdsboro Kosher Farms Corp. FKJ440902

3921G

21FEB2019 04C05 Poultry Good

Commercial

Practices

Open On Thursday 02/21/2019 at  approximately 0710

hours while I was walking through  killing

Department with , I

opened one of the closets located at Rabbi's

changing room and found two alive birds from

previous day. 

 was informed and placed the  birds at

a separate room and put water for them. Later

they decided to condemn them by disarticulation

(Break neck) The regulations, 9 CFR381.65(b),

require that poultry must be slaughtered in

accordance with Good Commercial Practices.. 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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60 M45134 Birdsboro Kosher Farms Corp. FKJ531402

2526G

26FEB2019 04C05 Poultry Good

Commercial

Practices

Open On February 26th while I and 

 Good Commercial

Practice task, we observed  a bird with non-Kosher

bleeding cut to the neck was rejected by a plan

employee in presence of a Rabbi. The rejected

bird was put into an inedible barrel immediately

while it was still alive. . was informed

and immediately moved the bird to the individual

bucket until stop breathing then moved it to

condemn barrel. The regulations, 9 CFR 381.65(b),

require that poultry be slaughtered in accordance

with GCP and in a manner that ensures a

thorough bleeding of the poultry carcass and that

breathing has stopped before proceeding with the

next step; the next step in this case was

placement into an inedible barrel. Slaughter must

result in thorough bleeding of the poultry carcass

(9 CFR 381.65). Compliance with these

requirements helps ensure that poultry are

treated humanely. In general, poultry should be

handled in a manner that prevents needless injury

and suffering in order to produce a commercially

marketable product. Also, there was loose bird

and was caught and put into cage immediately.

Birdsboro Kosher must ensure that all poultry are

slaughtered according to regulations, even if they

are rejected as suitable as a Kosher product. 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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25 M4653A Agri Star Meat and Poultry, LLC HRJ330902

4101G

01FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Regarding GCPs for live turkey production on

Wednesday, January 30, I 

 made the following observations: -The

temperature outside at the start of production

was -28F with a wind chill of -50F (according to

The Weather Channel and Weather Underground).

The live dock where turkeys are unloaded is a

three sided shed with no insulation. While the

establishment placed several space heaters at the

edges of the shed, these proved inadequate to

increase the air temperature beyond a two foot

radius (more and better heaters were added later

in the day, improving general conditions). -Birds

in trailers throughout the day were quiet, still, and

huddled with heads down. Some birds were

observed shivering. Mortality was slightly

increased (13 vs. one or two normally) and birds

were generally depressed. While rectal

temperatures where not taken birds felt

noticeably hypothermic. -Dumping mods are

stored outside when not in use and several mods

had accumulated several inches of snow and/or

ice. This was not removed from the lower holes,

and birds in mods were left standing on ice and

snow for 30 minutes during the lunch break.

Dumping was not witnessed so no observations

were made as to whether birds were frozen to

mods. (Management stated they would attend to

this better in the future.) -While I spoke with

management the previous day about the need to

modify trailer movement to ensure live birds were

not left sitting outside unprotected in trailers for

extended periods, the rotation of the second and

third trailers was done in a way that left a trailer

of birds outside for about 10 minutes. The

temperature at this time was -22F and wind chill

was present. (Management stated this was due to

one of the trucks freezing up, later rotations were

changed to accommodate for this.) -In the kill

room only the far line was being used, and a hole

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 17

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in the belt cover from the near line had not been

covered over, resulting in birds standing up as the

belt moved past and getting caught against the far

side of the hole.

25 M4653A Agri Star Meat and Poultry, LLC HRJ400902

3513G

13FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1033 on 2/11/19 while walking

through the poultry kill room I 

observed in the dead barrel at the far end of the

room a live bird with dead birds on top of it. The

bird was agonal and non-responsive, but still

breathing. The lunch break had just started and

no supervisor was in the immediate area. I

showed the bird to and

notified her of the issue. No other live birds in the

dead barrel were observed that day.

(b) (6) (b) (6)
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35 M5842 Tyson Foods, Inc. NPF41090

12410G

10JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized GCP Poultry Mistreatment MOI Day, Date and

Time of Meeting: Wednesday 1/9/2019 from

approximately 1055 to 1106 Place Meeting

Held: Est. M5842 Live Haul Trailer Holding Area 

Persons Attending: FSIS Attendees - 

 Tyson Foods Attendees – 

 Author(s) of this Meeting

Report: Date this Meeting Report

was Written: Wednesday 1/9/2019 Subject: GCP

Poultry Mistreatment MOI. Background

concerning this Poultry Good Commercial Practice

(GCP) Non-Regulatory Issue: On Wednesday

1/9/19 from 1030 to 1047 (CST) 

performed a station 5 Poultry Good Commercial

Practices (GCP) PHIS task by observing live, large

young chickens in cages on live haul trailers

parked outside in the live haul trailer holding area

at Est. M5842. At approximately 1034 during this

check observed 1 live bird roosting in

the space between adjacent stacks of trailer cage

modules (there are usually 8 cages per module)

on live haul trailer #91981. This young chicken

appeared to be uninjured. looked for

an open or damaged cage that this bird had

egressed through. then observed 1

open cage door on the top row of cages,

approximately 8’ above bed/floor of this trailer, in

this same space between the two adjacent

stacked cage modules. He also observed 1 DOA

carcass hanging out of this cage by its head, which

appeared be trapped/caught at the inside bottom

corner of this open cage door. 

surmised that this young chicken had got its head

trapped/caught in the corner of this open cage

before or as it egressed from this cage and

eventually died hanging there. After observing this

 continued the station 5 check. This

check was completed at 1047 with no more live (b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 19

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or dead young chickens observed out of the cages

on the total of 7 live haul trailers observed during

this station 5 check. Discussion notes for the

meeting with Plant management on Wednesday

1/9/2019 from approximately 1055 to 1106

concerning this GCP poultry mistreatment

incident: met with the establishment

PM, QA Manager, HACCP Coordinator and shift 1

Evisceration GPM at live haul trailer #91981 from

approximately 1055 to 1106 on Wednesday

1/9/2019 and showed them what he had

observed at 1034 (above). In-plant IPP and plant

management had already discussed the issue of

open live haul cage doors observed in the live haul

trailer holding area that had not resulted in

apparent/observed injury to live birds on Saturday

1/5/19, Monday 1/7/19 and Tuesday 1/8/19. So,

this issue of open live haul trailer cages had

already been discussed with plant management

and plant management was already addressing

this issue with their live haul/grow out personnel

when this incident occurred today. However, this

was the first time in-plant IPP observed a live

young chicken that appeared to have been

harmed after or else while emerging from an

unintentionally opened and/or damaged cage

door on a live haul trailer at Est. M5842.

(b) (6)
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35 M5842 Tyson Foods, Inc. NPF20170

21719G

19FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized GCP Poultry Mistreatment MOI Day, Date and

Time of Meeting: Tuesday February 19,2019, from

approximately 1540 to 1547 (CST) Place Meeting

Held: Est. M5842 APM Office Persons Attending:

FSIS Attendees - . Tyson

Foods Attendees –

 Author of this Meeting Report: 

 Date this Meeting Report was

Written: Tuesday 2/19/2019 Subject: GCP

Poultry Mistreatment MOI. Background

concerning this Poultry Good Commercial Practice

(GCP) Non-Regulatory Issue: On Tuesday

February 19, 2019, from 1430 to 1445hrs (CST) I

performed a Poultry Good Commercial Practices

(GCP) task by observing live chickens in cages on

live haul trailers parked outside in the live haul

trailer holding area at Est. P5842. At

approximately 1442hrs during this check I

observed 1 bird lying in the space between

adjacent stacks of modules (there are usually 8

cages per module) on live haul trailer #91780.

Upon closer inspection, this chicken was

deceased.  This check was completed at 1445hrs

with no more live or dead young chickens

observed out of the cages on the total of 6 live

haul trailers observed during this GCP task.  At this

time, was brought

to the trailer cooling shed and observed the bird

described above.  attempted to

remove the bird, and the bird had had its head

crushed under a module and had an open,

dislocating cervical (neck) injury. It appeared that

this chicken was loose on the trailer when the

next module was loaded.  Upon closer inspection,

the module adjacent to the one next to this

chicken had 1 cage with no door.  In inspecting 4

previous trailers, each trailer had at least 2 cages

missing doors completely, and I identified 2 cage

doors that had severely bent corners and would

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6)
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not close completely.  Additionally, there was 1

cage on another trailer that the cage walls were

severely damaged and potentially large enough

for a chicken to get through. A similar incident

occurred on January 9, 2019, when a chicken was

found hanging by its neck from an open cage

door.   Discussion notes for the meeting with

Plant management on Tuesday Februay 19,2019

from approximately 1540 to 1547hrs concerning

this GCP poultry mistreatment incident: I met

with the establishment Plant Manager and shift 1

and 2 Assistant Plant Mangers in the APM office

from approximately 1540 to 1547hrs.  The

situation had already been explained to them by

. I explained my

observations at 1442hrs (above). I explained that

since our discussions on January 5-9, 2019 about

open cage doors and module repair, that the

situation has been greatly improved. Plant

management intended to discuss this issue with

their live haul/grow out personnel after this

incident occurred today.

(b) (6)
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35 M7100 Tyson Foods, Inc. ZHB442103

0618G

18MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. 07100P, Tyson Foods of Nashville, AR, March

18, 2019, 20:32 hours, In attendance: 

. 

At approximately 20:25 hours, while walking

around the unloading shed towards a trailer that

was being unstrapped, to perform Ante Mortem

on a trailer of Lot 4 birds, I observed 

 establishment employee and terminal

tractor driver, waving his arms and yelling at the

forklift driver, who, I noticed, was lowering an

empty cage onto a wildly flapping live bird. The

cage was set down completely on the bird. As I

ran toward the forklift, the forklift driver lifted the

cage off of the now dead bird—it was not

breathing or moving at that point. I summoned

 to notify him of this finding. I

tagged the trailer US Rejected tag # B23639865 as

I took a regulatory control action of preventing

the forklift driver from removing the dead bird

until arrived. I reminded and 

, that the PPIA and Agency regulations

require that live poultry be handled in a manner

that is consistent with good commercial practices

(GCPs) and that they not die from causes other

than slaughter. I notified that this MOI

will be forwarded to Springdale District Office and

the District Veterinary Medical Specialist (DVMS)

in case additional follow-up is recommended. 

 stated that the forklift driver would be

retrained in animal welfare. Respectfully,

 07100P Tyson

Foods of Nashville, AR

(b) (6)

(b) (6)

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

(b) (6)

(b) (6)

(b) (6) (b) (6)
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80 M7345 Butterball, LLC AGA11100

11628G

28JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On Thursday, January 24, 2019, three truck loads

of lay one breeder hens, flock “PT”, were

scheduled to be run as the last birds of the day

(day shift hours are 0946-1816).  Each truck

contained 1040 hens.  The trucks arrived at 1053,

1141, and 1242, respectively.  I observed them at

approximately 1400 and did not note any

abnormalities.  According to establishment

paperwork provided, the hens went off feed on

January 23, although they were still looking into

what time.  Due to mechanical issues with the

chiller, the establishment was unable to run the

hens that day (January 24) and elected to carry

them over to the following day (January 25). 

Normally, when birds are carried over, they are

run first thing on night shift 

; however, night shift does not run

breeder hens, so the establishment decided they

would be run first on day shift on January 25 (see

email from 

, communicating this to me). 

While making GCP observations at 1420 on

January 25, I observed that these three truck

loads of hens were still on the yard and had not

been run yet.  I also observed an increased

number of DOAs from the previous day and

numerous hens with large, exposed wounds that

the hens surrounding them were pecking into. 

Fresh blood was visible on the beaks of these

birds and splashed onto surrounding feathers.  In

two cases, the hens had managed to peck open a

wound and pull out intestines and were pecking

at the intestines splayed out in the cage of two

separate hens.  The birds were seen aggresively

pecking at each other and at the feces/eggs in the

cages.  At this point, the hens had been off feed

for approximately two days and on the yard for

26-28 hours, and had not had access to feed or

water during that time.  According to Butterball’s

“Animal Care and Well-Being Program”, 

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

(b) (4)
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  I

immediately proceeded inside and found 

.  I expressed

my concerns with the birds being held at the

establishment for a greater length of time than

normal and that it was communicated to me

yesterday that these birds would be run first on

day shift and still had not been run.  He said there

had been some miscommunication due to

changes in management/staffing and that the

decision was made to run the hens last on

dayshift, with the new breeders that had come in

today, based on ease of product flow through the

establishment.  I expressed my concerns to him

that the birds were being held without access to

food or water and bird welfare needed to be

taken into consideration.  The birds did not end

up being run until starting at 1715, or 31 hours

from their arrival at the establishment.  According

to paperwork submitted on January 28, there

were 38 DOAs (1.2%).  The “Animal Care and

Well-Being Program” states 

  A similar situation

occurred in October 2016 following Hurricane

Matthew where birds were off feed/water for 60

hours before being killed.  It was documented at

the time in a meeting MOI on October 27, 2016

that our recommendation was to look at different

options if a similar situation arose and the

establishment said that they would take each on a

case-by-case basis.

(b) (4)

(b) (6)

(b) (4)
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80 M737 House of Raeford - Wallace Div DHA50100

24421G

21FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized During the DVMS GCP assessment on

02/20/2019, made the

following observations: At the entrance to the

scalders, observed birds that were not

properly bled out and were still breathing just

prior to entering the scalders.  On Line 1, 

r observed a bird as it approached the

scalder.  The bird was showing signs of being alive

(breathing, eyes open, trying to lift itself up).  An

establishment employee who was accompanying

the group also saw the bird and retrieved it from

the line before it could enter the scald tank.  Upon

further examination, the bird was found to have

no cut to its neck. On Line observed

two (2) birds approaching the scalder.  These birds

appeared to be alive as evidenced by their

breathing, having eyes open, and showing

coordinated body movements.  The establishment

employee again was able to retrieve the birds

from the line before they could enter the scald

tank.  Upon further examination, both birds were

found to have cuts to their necks, but because

they were still alive, the cuts were determined to

be inadequate to facilitate proper bleeding. There

was no other intervention procedure in place at

the entrance to the scalder, so if the

establishment employee had not been present to

remove the birds from the line, these birds would

have entered the scalder and would have died by

means other than slaughter.  During the Exit

Meeting, reminded that

the PPIA and Agency regulations 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

 notified that his observations

would be documented in a GCP MOI and this MOI

will be retained to the District Office and the

District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended.

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

(b) (6)

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

(b) (6)

(b) (6) (b) (4)
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80 M737 House of Raeford - Wallace Div DHA39100

33720G

20MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized Mr. Cowan Johnson, Plant Manager, P-737 House

of Raeford Teachey, NC 28464: This MOI is being

issued to document the observation of two live

birds entering the scalder on 03/20/19. At

approximately 0915 while performing  a GCP, I

observed two live birds entering the scalder. The

birds at the time of my observation were side by

side on the kill line, had normal rhythmic

breathing, controlled head movement and eyes

blinking. After further observations there was no

evidence showing that the bird's neck had been

cut after going through the stunner. I immediately

stopped the line when the birds mentioned had

reached the e-stop button which is located at the

entrance of the scalder. At that time, a live hang

employee came and removed the two live birds

off the line and placed them in live hang to be

rehung.  At that time 

, arrived and he was notified of my

findings.  was notified that the birds

would have died by means other than slaughter

therefore not-being in compliance 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". If you have any

questions please review PPIA (21 U.S.C.453(g)(5)),

and 9 CFR 381.90, provide that poultry carcasses

showing evidence of having died from causes

other that slaughter are considered adulterated

and must be condemned. Mr. Johnson this MOI

will be forwarded to the District Office and the

District Veterinary Medical Specialist in case

additional follow-up is recommended. If you have

any questions or concerns regarding the above,

please feel free to contact , or

. 

Respectfully, P737

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
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80 M737 House of Raeford - Wallace Div DHA13110

33228G

28MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized 0818 - When going to performing a Good

Commercial Practice check,  I observed several

cadavers in the red barrels with no cuts on the

necks at the re-hangers on line t 0821 while

performing the Good Commercial Practice task I,

observed on Line a live bird with no cut on its

neck as evidenced by their breathing, having eyes

open, and showing coordinated body movements

was about to enter the scalder.  

, who accompanied me

when I did the task was able to retrieve the bird

from the line before it could enter the scald tank.

There was no other intervention procedure in

place at the entrance to the scalder, so if the

establishment employee had not been present to

remove the birds from the line, the bird would

have entered the scalder and would have died by

means other than slaughter.  

, was notified of the MOI

being issued. At 1145, was

performing a Good commercial Practice task on

Line 1 and observed a one legger with no cut on

its neck about to enter the scalder.  The line was

stopped to prevent the bird from drowning in the

scalder and the bird was removed from the line by

.    

, was notified of the findings and of the

MOI.  There was no other intervention procedure

in place at the entrance to the scalder, so if the

establishment employee had not been present to

remove the birds from the line, the bird would

have entered the scalder and would have died by

means other than slaughter.  

, was also notified of the findings. 

Agency Regulations require that live poultry

should be slaughtered in a manner that is

consistent with good commercial practices and

that they should not die from means other than

slaughter.  Please refer to Federal Notice Volume

70, No. 187, published September 2005 [Docket

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

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

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

(b) (4) (b) (4)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 28

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No. 04-037N] for FSIS recommendations

concerning the treatment of live poultry before

slaughter.  This MOI will be forwarded to the

District Office and District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. Respectfully,  

, P-737 House of Raeford, Wallace

Division

80 M7470 Mountaire Farms Inc. - NC Division YRA232201

1610G

10JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized This memorandum of interview (MOI) is being

issued to document what was observed and

subsequently discussed with establishment

management. At approximately 22:00 on 1-10-19

I witnessed an employee walk over to the DOA bin

and use a red squeegee to move dead birds out

the way so he could retrieve a live bird that was

trapped under the dead birds in the DOA bin.

After removing the live bird he then tossed the

bird on the other side of the bin in an attempt to

hide the bird from me. I then observed the bird

and saw that it was alert and flapping its wings. I

informed him of the violation then I went back to

live hang and notified the 

 of my findings. His response was

that he was going to go investigate. 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. A copy of this MOI

will be forwarded to the district Veterinary

Medical Specialist (DVMS) in the event additional

follow-up is recommended. I certify this MOI

contains a summary of all pertinent matters

discussed.

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 29

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15 M751 Pitman Farms Inc. (Moroni Turkey

Processing)

MMK0014

012710G

10JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview on Good

Commercial Practices as Discussed in the

weekly meeting on 1/10/19 Pitman

Farms/Norbest Turkey / Est# P1049 Meeting

Time: Thursday, January 10th, 2019 at 0900 

Attendees: USDA                                                    

    

                                Establishment 

 

 This

Memorandum of Interview is to document

concerns with Good Commercial Practice

Concerns as discussed during the weekly meeting

with establishment management on January 10th,

2019. At the weekly meeting with establishment

management I described my concerns about Good

Commercial Practices because I had witnessed a

live medium hen run over by a trailer on January

9th, 2019.  This event occurred at approximately

9:45 am.  The hen had gotten down between the

two rows of rear tires on Trailer 82.  There were

about 4-5 other hens running around in the

hanging bay at the same time and one employee

who was trying to catch them.  The hen was run

over and killed by means other than humane

slaughter when the trailer was pulled forward.  

At the weekly meeting I stated that one of my

concerns is that I have noticed that there seem to

be more loose birds running around in the

hanging bay when they are slaughtering medium

hens.  said that this has been

addressed. I said that I recommend that the

establishment train employees on how to perform

cervical dislocation on the birds so that if they

need to humanely kill a bird by means other than

slaughter, they can.  During the event described

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 30

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on January 10th, the employee did not seem to

know what to do or how to perform cervical

dislocation.  I performed cervical dislocation on

the hen after she had been run over so that she

wouldn’t continue to suffer as she died.  I stated

that this isn’t a federal requirement, but I would

recommend considering training employees on

how to humanely kill a bird if needed.  

should be able to help with this as part of a

humane handling program.  said that he

plans to have both the security employees and

the hangars trained in the event that they need to

be able to humanely kill birds.  also said

that he will follow-up on this. This memorandum

serves to document my findings on Good

Commercial Practices and what was discussed.  A

copy of this Memorandum of Interview will be

provided to establishment management, and the

signed original will be placed in the USDA files. 

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

Processing)

MMK3615

011117G

17JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized Memorandum of Interview on Good

Commercial Practices as Discussed in the

weekly meeting on 1/17/19 Pitman

Farms/Norbest Turkey / Est# P1049 Meeting

Time: Thursday, January 17th, 2019 at 0900 

Attendees: USDA                                                    

              

Establishment 

 

 

 This Memorandum of Interview is to

document concerns with Good Commercial

Practices as discussed during the weekly meeting

with establishment management on January 17th,

2019. At the weekly meeting with establishment

management I described my concerns about Good

Commercial Practices.  On two separate days I

saw birds that had died after their heads were

trapped between the side of the cage and the side

of the cage door.  On 1/11/19, I saw one hen in

Trailer 79 who was dead with her head caught

between the side of the cage and the side of the

cage door.  She had a freshly bleeding and torn

wing, evidencing her struggle after the door was

closed on her.  Another hen in Trailer 81 had had

the cage door closed on top of her head and one

wing.  She was also dead on ante-mortem exam.   

On this day there were 4 other birds with their

legs or feet caught under cage doors.  These legs

and feet were bloody and bruised. On 1/14/19, I

saw two hens in trailer 82 that had died after their

heads were caught between the side of the cage

and the side of the cage door.  In trailer 74 there

was a tom who was struggling to breath and not

doing well who had his head caught and trapped

under a cage door.  In trailer 80 one hen had had

her leg trapped between the side of the cage and

the cage door.  Three other birds on other trailers

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 32

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had had their legs caught and trapped under cage

doors.  These legs and feet were bloody and

bruised. said that

the establishment would discuss these issues and

see what they could do to prevent them.  This

memorandum serves to document my findings on

Good Commercial Practices and what was

discussed.  A copy of this Memorandum of

Interview will be provided to establishment

management, and the signed original will be

placed in the USDA files. 

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 33

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60 M9977 Tyson Foods Inc. YBL311901

4215G

15JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized MOI January 15, 2019 At approximately 1630

hours on January 15, 2019 I went to explore the

alarm sound I heard coming from receiving area at

the feather collection basin.  I found the water

level at the feather area is up triggering the sound

alarm.  There was the 

 with a maintenance personnel

working with the issue.  When coming back I

noticed that the back-up head puller is off and

heads were dropping on the floor making a big

pile.  I also noticed that some of the heads

attached to the carcasses past the puller.  I

showed this to and I saw him

instructing the receiving Supervisor to address the

issue.  I went past the feathers basin to the door

leading to the trucks receiving area.  I found the

door broken although we talked about this door

in our weekly meeting January 8, 2019.  I also

noticed that the pipe-joint near the stunning area,

and the dripping of the sink at the receiving door

were not fixed although we mentioned that in the

weekly meeting. Furthermore, when I returned

back to the hanging area I saw the birds were

piled up at the hanging belt and already 2 birds

were loose on the floor.  The cart at the end of

belt was full with DOA and the DOA barrel was

75% full.  The hanging associates were working

feverishly to relieve the belt but the number was

too large.  I immediately ran to evisceration

department to get hold of but I

found and showed him the

overcrowded belt and the dead carcasses.  At that

moment the receiving showed

up and I asked him to stop the dumber. 

told me that he had already stopped the dumbing

and I pointed out that he should have stopped the

dumber earlier. The receiving area should have

been monitored more closely because there was

no shortage of hanging personnel and I counted 8

associates hanging birds.  I will be monitoring the

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 34

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Code TaskName Status MOI Agenda

receiving area till these issues are addressed as

quickly as possible. 

50 P1209 Whitewater Processing Co. FFG191201

1615G

15JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P1209 Whitewater Processing Co. At 1310

hours while observing birds entering the scald

tank as part of a routine GCP task, 

observed the following. One old breeder turkey

 was observed to be breathing and raising

it's head on the production line just before the

scald tank. stopped the line and alerted

Plant personnel of the finding, Plant personnel

removed the birds from the line. An establishment

employee, rehung the bird prior to the stunner.

The line was then restarted. went

immediately to the office and discussed the

finding with  .. I explained that this issue

continues to occur. The last one occurred

eighteen days ago (12/28/2018). I again explained

that public perception of this could lead to

problems for the plant and further corrective

actions need to be implemented. She stated he

would take immediate corrective measures which

included reviewing findings with plant personnel. I

again stressed that it is not a condition that the

birds are not cut but that only one carotid is cut

and the birds are regaining consciousness without

bleeding out.

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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50 P1209 Whitewater Processing Co. FFG090802

4414G

14FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P1209 Whitewater Processing Co. At 0855

hours while observing birds entering the scald

tank as part of a routine GCP task, 

observed the following. One old breeder turkey

(Hen) was observed to be breathing and raising

it's head on the production line just before the

scald tank. stopped the line and alerted

Plant personnel of the finding, Plant personnel

removed the birds from the line. An establishment

employee, rehung the bird prior to the stunner.

The line was then restarted. went

immediately to the office and discussed the

finding with  .. I explained that this issue

continues to occur. The last one occurred Thirty

days ago (01/15/2019), but not all these days

were production days. I again explained that

public perception of this could lead to problems

for the plant and further corrective actions need

to be implemented. He stated he would take

immediate corrective measures which included

reviewing findings with plant personnel. I again

stressed that it is not a condition that the birds

are not cut but that only one carotid is cut and

the birds are regaining consciousness prior

to bleeding out.

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 36

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50 P1209 Whitewater Processing Co. FFG100802

1315G

15FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P1209 Whitewater Processing Co. At 0855

hours while observing birds entering the scald

tank as part of a routine GCP task, 

observed the following. Two young tom turkeys 

were observed to be breathing and raising their

heads on the production line just before the scald

tank. stopped the line,  the first bird

expired prior to plant personnel arriving so 

 restarted the line. observed a

second bird and stopped the line again,

and alerted Plant personnel of the finding, Plant

personnel removed the birds from the line. An

establishment employee, rehung the bird prior to

the stunner. The line was then restarted. 

 went immediately to the office and

discussed the finding with .. I explained

that this issue continues to occur. The last one

occurred yesterday (01/14/2019). I again

explained that public perception of this could lead

to problems for the plant and further corrective

actions need to be implemented. He stated he

would take immediate corrective measures which

included reviewing findings with plant personnel. I

again stressed that it is not a condition that the

birds are not cut but that only one carotid is cut

and the birds are regaining consciousness prior to

bleeding out.

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

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

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 37

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Task

Code TaskName Status MOI Agenda

50 P1209 Whitewater Processing Co. FFG160802

1120G

20FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P1209 Whitewater Processing Co. At 0855

hours while observing birds entering the scald

tank as part of a routine GCP task, 

observed the following. Two old Breeder turkeys

(Hens) were observed to be breathing and raising

their heads on the production line just before the

scald tank. stopped the line and alerted

Plant personnel of the finding, Plant personnel

removed the birds from the line. An establishment

employee, rehung the birds prior to the stunner.

The line was then restarted. went

immediately to the office and discussed the

finding with .. I explained that this issue

continues to occur. The last one occurred last

Friday (02/15/2019). I again explained that public

perception of this could lead to problems for the

plant and further corrective actions need to be

implemented. He stated he would take immediate

corrective measures which included reviewing

findings with plant personnel. I again stressed that

it is not a condition that the birds are not cut but

that only one carotid is cut and the birds are

regaining consciousness prior to bleeding out.

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 38

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Task

Code TaskName Status MOI Agenda

50 P1209 Whitewater Processing Co. FFG230802

0222G

22FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P-1209 Whitewater Processing Co. At 0905

hours while observing birds entering the scald

tank as part of a routine GCP task, 

observed the following. Two old Breeder turkeys

(Hens) were observed to be breathing and raising

their heads on the production line just before the

scald tank. stopped the line in both

cases and alerted Plant personnel of the finding,

Plant personnel removed the birds from the line.

An establishment employee, rehung the birds

prior to the stunner. The line was then restarted.

 went immediately to the office and

discussed the finding with  .. I explained

that this issue continues to occur. The last one

occurred Wednesday (02/20/2019). I again

explained that public perception of this could lead

to problems for the plant and further corrective

actions need to be implemented. She stated she

would  discuss  this with management and they

would take immediate corrective measures which

included reviewing findings with plant personnel. I

again stressed that it is not a condition that the

birds are not cut but that only one carotid is cut

and the birds are regaining consciousness prior to

bleeding out.

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 39

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Task

Code TaskName Status MOI Agenda

50 P1209 Whitewater Processing Co. FFG150803

0307G

07MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized Est. P-1209 Whitewater Processing Co. At 0855

hours while observing birds entering the scald

tank as part of a routine GCP task, 

observed the following. Three old Breeder turkeys

(Hens)  in a row were observed to be breathing

and raising their heads on the production line just

before the scald tank. stopped the line 

and alerted Plant personnel of the finding, the

birds had expired prior to the arrival of plant

personnel. The line was then restarted.  

went immediately to the office and discussed the

finding with  .. I explained that this

issue continues to occur. The last one occurred

Friday (02/22/2019). I again explained that public

perception of this could lead to problems for the

plant and further corrective actions need to be

implemented. He stated he would discuss this

with management and they would take

immediate corrective measures which included

reviewing findings with plant personnel. I again

stressed that it is not a condition that the birds

are not cut but that only one carotid is cut and

the birds are regaining consciousness prior to

bleeding out.

(b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 40

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rict EstNbr EstName MOINbr Date

Task

Code TaskName Status MOI Agenda

50 P1241 Tyson Foods, Inc. MGJ07190

15114G

14JAN2019 04C05 Poultry Good

Commercial

Practices

Open Poultry Mistreatment MOI January 14, 2019 

Establishment 1241-P, Tyson Foods, Inc, January

14, 2019, 6:15 pm.  In attendance:

 Nathan Henry, Tyson Plant

Manager; At

approximately 4:08 pm while performing a

Poultry Good Commercial Practices task at a point

just before where the chickens enter the scalding

tank, I observed a live chicken enter the scalding

tank while still breathing.  The chicken had no

visible knife cut on its neck and was exhibiting

voluntary movement of the head and neck as it

entered the scalding tank.  I immediately

proceeded to the point on the kill line directly

after the last picking machine and waited for the

chicken carcass in question to pass by me.  When

the carcass appeared, I removed it from the kill

line and examined it.  The carcass was red in color

and had a small, superficial cut on the back of the

neck.  This cut did not sever any major blood

vessels and was insufficient to allow proper

bleeding out of the carcass.  I immediately

showed the chicken carcass to 

, and informed her of

the impending MOI.  Members of the

maintenance team examined the stunner and kill

machine and made the necessary adjustments. At

approximately 6:15 pm, I met with 

, Nathan Henry, Tyson

Plant Manager, and 

to discuss my findings.  9CFR 381.65(b) requires

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.  assured me that he and other

members of management would thoroughly

investigate the issue and take measures to

prevent its reoccurrence.  He also stated that he (b) (6)

(b) (6)

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

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 41

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Task

Code TaskName Status MOI Agenda

would provide written documentation of the

corrective actions and preventive measures taken

to address this issue.  

, Est. 1241-P Corydon, IN

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 42

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Code TaskName Status MOI Agenda

50 P1241 Tyson Foods, Inc. MGJ59200

21501G

01FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Establishment 1241-P, Tyson Foods, Inc, February

1, 2019, 7:30 pm.  In attendance: 

 and 

 At approximately 5:08 pm while

performing a Poultry Good Commercial Practices

task at a point just before where the chickens

enter the scalding tank, I observed a live chicken

enter the scalding tank while still breathing.  The

chicken had no visible knife cut on its neck and

was exhibiting voluntary movement of the head

and neck as it entered the scalding tank.  I

immediately proceeded to the point on the kill

line directly after the last picking machine and

waited for the chicken carcass in question to pass

by me.  When the carcass appeared, I removed it

from the kill line and examined it.  The carcass

was small, red in color, and had no knife cut on

the neck.  I immediately showed the chicken

carcass to or, and

informed him of the impending MOI.  At

approximately 7:30 pm, I met with to

discuss my findings and his planned corrective

actions.  I informed that 9CFR 381.65(b)

requires 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.  informed me

that he plans to have a meeting with all live hang

employees to instruct them not to hang small cull

birds that may miss the stunner water and the kill

machine.  also informed me that he plans

to verbally counsel the employee who was

working as the back-up killer at the time of this

incident, stressing to him that no chickens should

go past him that have not been properly cut. 

, Est.

1241-P Corydon, IN

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

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 43

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Task

Code TaskName Status MOI Agenda

80 P1243 Perdue Foods, LLC. XLB151302

3005G

05FEB2019 04C05 Poultry Good

Commercial

Practices

Open On 02/05/2019, at approximately 0942 hours,

while I was observing operations in evisceration

prior to providing relief breaks to the USDA

inspectors, the evisceration line #1 stopped

running at the transfer station.  After providing

the USDA relief breaks, at approximately 1010

hours, I proceeded to observe the conditions at

live hang, since line #1 still was not in operation.  I

observed birds in the stunner with their heads

under the water and birds hanging on the line

before reaching the stunner.  Perdue has an

animal welfare program that has included a

procedure for this event.  I asked 

, if they were following their

procedure of removing the birds if the line was

down for a certain amount of time.  He stated no,

they were not.  The birds in the stunner were

allowed to drown during this time, thus dying

otherwise than by slaughter.  About this time, the

evisceration line was restarted so no actions were

taken to follow the procedures at this time.  I

asked for the animal welfare program and was

told they would provide it to me today.  As of the

writing of this report, I have not been provided

with the procedure. I prepared this report on

02/05/2019 and I certify that this report has

recorded in it a summary of all pertinent matters

discussed.

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 44

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Task

Code TaskName Status MOI Agenda

60 P1304 Farmers Pride Inc. YVB450201

0805G

05JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1230 while performing a routine

Poultry Good Commercial Practices task I was

observing live receiving at the point where the

cages of chickens are loaded with the fork lift

onto the conveyor belt to enter the CO2 chamber.

While one of the cages was being placed on the

conveyor belt one of the lower blue plastic crates

was protruding out of the main cage structure on

the side the plant employee was standing. The

plant employee pushed the crate in to realign it,

but it then protruded approximately 6-10inches

out the other side of the cage structure. At that

point the space crated allowed approximately 2-3

chickens to stick their heads out of the crate. All

the chickens then retracted their heads back into

the crate except for one that kept its head sticking

out of the crate. The establishment employee

then pulled the crate back into place without

looking at the opposite side of the cage and the

chicken with his head sticking out had its neck

trapped between the blue plastic crate and the

metal support of the cage structure. I informed

the establishment employee immediately of what

had happened, and he tried to free the chicken,

but was not able to free the chicken before it

moved further down the conveyor belt. This

resulted in the chicken being suffocated, therefore

dying by a means other than slaughter. This same

chicken was identified by plant personnel at the

live hang belt and was condemned before it

entered any further into the plant.   I

immediately found 

 and informed him what had

occurred. He acted immediately to speak with the

employee and give him verbal counseling. He also

informed me that because the employee had not

harmed the chicken with any malicious intent

that the employee would be receiving

documented retraining from plant management

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 45

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Task

Code TaskName Status MOI Agenda

to prevent an occurrence like this from happening

in the future.

90 P1307 Mar-Jac Poultry-AL KIL011402

0712G

12FEB2019 04C05 Poultry Good

Commercial

Practices

Open At approximately 13:05 on February 12, 2019, I

observed less than Good Commercial Practices

(GCP) while performing

Antemortem/GCP/Mishandling verification at

Mar-Jac Poultry in Jasper, AL.  I observed five

chickens in the DOA dumpster that were still

breathing, and partially covered by chicken paws

and chicken litter.  None of the chickens had been

decapitated.  I immediately notified 

 and 

 of this finding.  The

chickens were euthanized by cervical dislocation

and decapitation. cc: 

 Dr. Greg

Brookhouser, Deputy District Manager 

90 P1307 Mar-Jac Poultry-AL KIL340403

5221G

21MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0400 while near the cage dump

area, I observed a forklift driver trying to remove

one of the top cages containing live chickens from

a live haul trailer.  As the driver was removing the

cage, one of the cage doors popped open and got

caught on another cage which caused the entire

cage of live chickens to plummet to the

ground.  The cage hit the ground with such force

that the remainder of the cage doors opened and

the chickens were scattered on the ground.  I

observed over 100 chickens grossly mangled and

killed as a result of the fall.  I notified 

 of my observations.   Respectfully

submitted on March 21, 2019, 

 Cc:  Dr. Gregory Brookhouser, DDM   

        

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

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

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 46

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Task

Code TaskName Status MOI Agenda

80 P146 Tyson Foods, Inc, EJJ451601

5517G

17JAN2019 04C05 Poultry Good

Commercial

Practices

Open The following MOI documents my concerns

regarding the practices of P-146 associates in

Antemortem: On January 16, 2018 at

approximately 1718 when and I

started a Poultry Good Commercial Practices task

we observed a nonconformance. As we

approached the area where birds are retrieved

from the trucks and conveyed to the cage dumper

we observed a bird fall out of a cage directly onto

the ground. The driver was moving the birds

rapidly and backed over the bird as we were

yelling to him and waving our hands in the air

trying to get his attention. He saw us as we got

closer and stopped. I took Regulatory Control

Action. The actions of the driver resulted in the

breaking of one of the bird’s legs and it was

partially eviscerated. The bird died 10-15 seconds

later. As I was verifying the bird had died, the

jack driver tried to remove the carcass and I asked

that he stop all actions until further notice. He

replied, “What do you want to do play with it!” I

responded, “I have stopped the process, leave the

bird here, I need you to get your supervisor.” 

When he left, and

 arrived to the area at about 1720. I

described the sequence of events and that I had

stopped the process due to the inhumane

treatment of a bird having been killed by being

run over. During this time the jack driver again

made comments such as, “What does me picking

up the bird have to do with anything? I can’t pick

it up?” Another driver made comments stating,

“Birds are falling out of the cages all the time”.   

This establishment and all Tyson Foods are

committed to the proper handling of all animals

used to produce meat and poultry according to

their Animal Welfare Program. I did not see this

mission expressed in the actions and comments of

the associate moving the birds. I told all members

of management and the driver that a bird should

(b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 47

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Code TaskName Status MOI Agenda

not die by means other than slaughter and

establishments are to handle and treat live birds

humanely in the loading and live hang areas as

dictated by FSIS Directive 6100.3, VII, A, (b). The

establishment has a plan in place for handling

animals from the time they enter the premises. 

On another note, Tyson’s plan states that for

Escaped birds, movement of trucks in the

immediate area will be stopped to prevent injury

to the escaped bird , contain it, recage or placed

on the line or notify the Yard supervisor. The

driver was speeding about moving too fast and

not being vigilant enough to make this

observation.  Furthermore, I stopped production

because the driver retrieved the bird from the

ground and started carrying him to DOA bin prior

to the bird dying. The bird did not die until I asked

the driver to return it and get his supervisor. This

person did not try to kill the bird prior to

disposing of the carcass. He did not communicate

what he was doing he just headed in the direction

of the DOA bin. That bird would have needed to

be humanely euthanized in my presence then

placed in the DOA bin. went to get

,

who arrived around 1723. I explained the series of

events and told him I would need a plan of action

from the establishment to bring themselves back

into compliance before they could start their

process again. listed the following: 

-Coaching the jack driver -Doing a retraining of all

team members -A supervisor monitoring the yard

hourly doing a visual inspection It will be

documented. -He also started to locate the

damaged cage that had the bird I accepted

preventative measures and released Regulatory

Control Action at 1727. During the sequence of

events 

, reiterated that the cages that have

been damaged and removed from production

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 48

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Task

Code TaskName Status MOI Agenda

however current efforts to make cages safe for the

transport of birds have been ineffective. On

1/17/19 I requested the Animal Welfare check of

this establishment. It shows that a weekly Chicken

Yard Audit was performed on 1/16/19, it

completed at 1430 and inspection of the yard

found no Loose birds/Escaped birds on the yard. 

MOIs regarding deviation from Good Commercial

Practices have been written in the last 90 days on

November 9, 2018 and December 27, 2018 citing

that the establishment failed to slaughter poultry

in accordance with Good commercial practices.

Should an ongoing pattern develop where birds

are not being slaughtered in a manner that results

in thorough bleeding of the carcasses in

accordance with FSIS Directive 6110.1, II, B an NR

for noncompliance with 9 CFR 381.65(b) (failure

to handle birds in accordance with GCP) will

result.
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 49

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Task

Code TaskName Status MOI Agenda

40 P165H OK Foods, Inc. DAF00230

22311G

11FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2041 hours on 2-10-2019, while

performing Ante Mortem inspection on Lot 1 and

Good Commercial Practices at the back-dock area,

I observed the fork lift driver place a cage onto the

cage dumper dock. I immediately noticed that

one of the cage doors was wide open and 4

chickens were sitting on top of the door. The fork

driver never looked to see if the cage was

acceptable or not before leaving to get another

cage. One of the chickens fell off the door and

landed on the edge of the dumper dock. The

employee operating the cage dumper moved the

line forward which caused the open door of the

cage to be forced back upward. This resulted in 3

birds being caught at mid body between the door

and the cage. The employee on the fork lift

returned with a full cage and was about to place

the cage on the dock, when I stopped him from

doing so. I motioned to the cage dump employee

to stop the moving line. After he stopped the line,

he walked around the equipment stand and saw

the birds that were caught in the cage door. He

quickly moved the cage backwards to release the

pressure on the door so that he could free the 3

chickens. After he removed the caught chickens,

he tried to shut the door and realized that the

door was broken and would not stay shut. He had

a nearby employee utilize a long rod to hold the

cage door shut while he moved the cage up to the

dumping station. He also flagged the cage so that

it would be sent to the repair shop. USDA’s

concerns are that live chickens are being injured

and caught in broken cage doors. The

establishment has a program in place for the

humane handling of the chickens. Each of the

employees are given this training when they are

hired and again when issues arise. The failure of

the fork lift employee to notice that the cage door

was open or noticed that it was open and failed to

notify the cage dump employee indicates that the
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 50

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Task

Code TaskName Status MOI Agenda

establishment’s program may not be effective in

preventing injury to the live chickens. USDA has

written several MOIs for open cage doors on

trailers and/or broken cage doors. These MOIs

were written on 11-14-18, 9-18-18, 7-31-18,

5-15-18, and 5-11-18. USDA strongly recommends

that the establishment respond to this MOI and

address this issue of concern.

35 P165S OK Foods, Inc. LWA55120

14223G

23JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized This MOI is to document my conversation with

. At

0531 hours, while performing a PHIS GCP task, I

observed 2 live birds on Kill line #1 that would

have entered the scalders alive, if I had not

instructed the second back-up killer to stop the

line. stated that he was calling the

Maintenance department to check the kill

machine on line #1. He was monitoring the line.

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 51

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Task

Code TaskName Status MOI Agenda

90 P17766 Southern Hens, Inc SSN081602

5112G

12FEB2019 04C05 Poultry Good

Commercial

Practices

Open At approximately 1210 hours, the following less

than Good Commercial Practices in Poultry

(GCPIP) incident was observed at P17766,

Southern Hens Inc., Moselle, MS while performing

the routine PHIS Poultry Good Commercial

verification task.  Two (2) live chickens were

observed in the Dead on Arrival (DOA) bin along

with 2 DOAs.  The live birds were blinking, looking

around, and were vocal. The transfer belt from the

live hang to the DOA bin was operating

unattended.  

 was notified. Allowing live bird(s) to

enter the DOA bin and comingle with DOAs can

lead to entrapment, suffocation and death.  Live

birds may accidentally enter the offal chute and

be carried by the flowing water into offal pit,

through the augers, and into the offal trailers. 

This can cause needless suffering and death.  

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. Ms Tia Horton Plant Manager and

 discussed briefly the less

than GCPIP incident in the management office at

approximately 1930  hours. No response to the

less than GCPIP 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

(b) (6)

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

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 52

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Code TaskName Status MOI Agenda

industry guidelines. Respectfully, 

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 53

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Code TaskName Status MOI Agenda

90 P17766 Southern Hens, Inc SSN071703

2426G

26MAR2019 04C05 Poultry Good

Commercial

Practices

Open At approximately 1123 hours, the following less

than Good Commercial Practices in Poultry

(GCPIP) incident was observed at P17766,

Southern Hens Inc., Moselle, MS while performing

the routine PHIS Poultry Good Commercial

verification task.  Upon walking around to the

back-dock area, 

 observed approximately 8-9 employee

workers unloading from two separate trailers

parallel to the conveyer belt on either side. The

employees were transferring bird cages from the

unloading truck to the conveyer belt. Some were

working in groups of two, and there were

employees who were individually tossing crates

from approximately six feet in a stacked position

onto the conveyer belt. This action was observed

from either trailer. As some of the crates were

hitting the conveyer belt, with failed attempts, it

would land on its side causing the birds to all

tumble to one side of the crate stacking in an

un-natural position onto one-another. The birds

were vocal and this point and some even escaped

to where they fell approximately five feet to the

ground under the unloading truck to the concrete

in watery feces. 

 who was present at the time was

informed of the GCP MOI. 

S, and  

, discussed briefly the less than GCPIP

incident in the management office at

approximately 1310  hours. said that

they would implement some form of training to

the employees and emphasize that crates under

no circumstances should be thrown. 

 was advised a GCPIP Memorandum of

Interview would be issued to management

pending review by . 

Respectfully, 

(b) (6)

(b) (6)

(b) (6)

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

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 54

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90 P192 Pilgrims Pride Corporation OOB29170

20612G

12FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized On Friday, February 8, 2019 at 2120 while

performing a good commercial practices task, I

observed a pile of approximately seven DOA birds

in the hanging pen.  Upon closer examination, I

observed a live bird partially covered by the pile of

DOAs.  The bird's chest was exposed and it was

breathing heavily.  I immediately notified the live

receiving supervisor who then promptly removed

the live bird from the pile.  He then instructed an

employee working the floor to pick up and

decapitate the remaining DOAs.  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.

40 P19688 Sanderson Farms, Inc. KJA540901

0708G

08JAN2019 04C05 Poultry Good

Commercial

Practices

Open Tuesday Morning on 01/08/2019 I was

performing a good commercial practice (GCP) task

at approx. 0645 hrs. I was standing between the

bleeding tunnel and the scalder for kill line 1. I

observed a bird on the line that passed by and

seemed not had been slaughtered. I immediately

stopped the kill line 1 and asked the plant

employee to remove the bird from the line.

 also came and I

explained to him of my observations, we looked

at the bird that had been just removed from the

line only inches before it had entered the scalder.

The bird was fully conscious with both eyes open

and was breathing. There were no signs of any cut

made to the neck of the bird, hence the

establishment failed to prevent a live bird

entering the scalder. The line was allowed to start

back up immediately and 

 was verbally informed of the upcoming

MOI. I expanded my check but didn’t notice any

evidence of process control as this was just an

isolated incident. The findings were later

discussed with the 

 and the plant Manager Allen Laughlin

(b) (6)

(b) (6) (b) (6) (b) (6)
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35 P208 George's Processing, Inc. XIC191201

4015G

15JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On Tuesday, January 15, 2019, at approximately

11:18 hours, 

met with .  The

following is a synopsis of the events and

discussion regarding a bird that appeared to have

been damaged by a module. At 11:15 hours while

performing Good Commercial Practices, I

observed a module that was full of birds on the

dumper for Kill Line 1 (It is important to note that

the module had already been conveyed prior to

my observation). The dumper operator lifted the

cage tilt cradle to dump the birds onto the metal

slide. At this point, I observed that a bird

underneath the module which appeared to be

aware and had intentional flapping motion of its

wings. The bird’s legs were also not visible and the

dumper operator lowered the cage down onto the

bird. The dumper operator lifted the cage tilt

cradle again to dump any remaining birds. I

observed the bird appeared to be aware and still

had intentional flapping of its wings. The dumper

operator lowered the cage down again onto the

bird. The dumper operator attempted to convey

the module from the dumper/tilt cradle section to

the first outgoing conveyor but the module would

not convey backwards. At this point, there was

still a single bird in the module that had not been

dumped from the initial two lifting and tilting of

the modules and the dumper operator looked

toward the mirror and appeared to observe the

bird left in the module. Then, the dumper

operator lifted the cage tilt cradle a third time. I

observed the bird that had been trapped under

the cage had fallen under the dumper section. The

bird did not appear to be breathing, aware, or

have any intentional movement. I immediately

went to retrieve R

. He was not in his office and so I

proceeded to office and

requested that meet me at the dumper

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

(b) (6)

(b) (6)
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area to inform him of my observations. After

informing of my observations, the

carcass was retrieved by the establishment which

demonstrated that approximately 2-3 inches of

the skin over the breast had been avulsed. I also

observed blood present on the head/neck.  I

informed that this is not consistent with

good commercial practices. I also discussed that a

similar MOI had been issued on December 28th

(MOI number XIC3410125228G) for similar

observations in which a bird was injured on the

dumper section of Kill Line 1. informed

me that actions to prevent future occurrence

would include corrective training/disciplinary

action on the employee. The meeting was

adjourned at approximately 11:25 hours.

(b) (6) (b) (6) (b) (6)
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35 P208 George's Processing, Inc. XIC151301

1929G

29JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On Monday, January 28, 2019, at approximately

11:35 hours, ,

and 

, met with 

  The following is a synopsis of the events

and discussion regarding dead birds in live hang.

At approximately 11:30 hours, 

informed me, , that the

establishment was switching to Lot 3 on Line

and that a leukosis check and antemortem had

not been performed on that lot. I proceeded back

to the receiving area to perform antemortem on

Lot 3. Upon entering Live hang and looking

toward the live hang belts and DOA auger, I

observed two condemn barrels full of dead birds.

In addition, I also observed a pile of dead birds

approximately 4 feet wide by 8 feet long and

approximately 1-3 layers deep on the floor. Based

on my observation, I would estimate that there

were at least 150-200 carcasses on the floor.  I

observed that was working on disposing

of the carcasses via the DOA auger. I inquired

about the reason for the increased number of

dead birds. informed me that the

hanging belt malfunctioned in which the live hang

belt was not working but the dumper belt was.

This resulted in carcasses piling up in the tunnel

between the dumper and the first live hang

personnel. I informed him that allowing birds to

pile up and smother is not consistent with

slaughtering birds in accordance with Good

Commercial practice. requested that I

discuss the issue with Smith who was

observing the live hang personnel. I proceeded

over to and informed him of my

observations and that this practice was not

consistent with the slaughtering of birds in

accordance with Good Commercial Practices. The

establishment was still considering the optimal

method to prevent future recurrences at the time

(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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of the discussion. Therefore, no measure was  to

prevent recurrence was provided by the

establishment. The meeting was adjourned at

approximately 11:45 hours.

85 P211 Palmetto Pigeon Plant, Inc. DJK140903

0711G

11MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized On March 7, 2019, at approximately 1000 hours

while performing a Poultry Good Commercial

Practices (GCP) task in the Kill Area, I made a few

observations while slaughtering Poussin.  There

were approximately three (3) loose birds in the

blood trough under the cones that are used for

placement of the birds prior to the cut being

applied.  Some appeared to have shallow cuts and

were still alive walking around.  I also noticed that

there were several cones missing and as I

continued to watch the kill step in the process, I

observed the cuts being applied but the birds

were not being bled properly.  After only about

thirty seconds from applying the cut to the birds

they were then moved from the cones and placed

in a barrel.  The birds appeared to still be

breathing and exhibited body movement and

wing movement.  They were not thoroughly bled

prior to being placed in the barrels.  After my

observations of this practice, I notified Ms. Sandy

Benenhaley, Plant Supervisor and explained to her

my observations and concerns. 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 with Good Commercial

Practices.  I notified Ms. Benenhaley that this MOI

will be forwarded to the District Office and the

District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended.
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85 P21234 Perdue Foods LLC XGI241202

0126G

26FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Perdue Farms P-21234 Date: 2/26/2019 Time:

1:21 PM On Tuesday, February 26, 2019, at

approximately 12:11pm, I, observed

the following: while performing Good Commercial

Practices Verification, there were approximately

30 birds piled up on the DOA table. Mixed with

these birds were 2 visibly live birds. The DOA birds

were falling on top of the live birds, smothering

them and causing them to have trouble breathing.

I informed the cage dumper that when

the floor attendant is on break, he is responsible

for managing the DOA table. I told him that the

live birds needed to be retrieved immediately and

the DOA birds needed to be appropriately

condemned. We cannot allow the DOA birds to

pile up on top of live birds. It causes the birds to

be significantly stressed. This is mistreatment and

it is not consistent with good commercial

practices. I informed of the

mistreatment of the live birds I had observed, and

told him that I would be documenting my findings

in an MOI. This MOI will be forwarded to my

and the in

case additional follow-up is recommended. 

Respectfully, 

(b) (6)

(b) (6)

(b) (6)(b) (6)(b) (6)(b) (6)
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40 P218 Pilgrim's Pride Corporation WOD5622

030021G

21MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized On March 20, 2019 at approximately 1940 hours

while performing a PHIS Poultry Good

Commercial Practices task USDA 

 observed the following while outside at

the establishment’s dumping operations. There

were five birds stuck, by their neck, between the

conveyor belt and a newly installed Teflon board

at the junction where the two belts meet on line

Regulatory control was taken, and the dumper

operator was instructed to stop dumping live

birds onto the belt. 

 was called to the area, shown the birds

and notified maintenance and

 Further

inspection of the birds and the belt showed that

there was a gap between the belt and the new

Teflon board that allowed the birds’ neck to get

caught up, trapping it between the belts. The

birds were all dead and had matted dirty feathers

with generalized bruising. The Teflon board was

removed, the belt was inspected and dumping

operations resumed at 2020 hours. Plant

Management is asked to consider these USDA

concerns of good handling practices particularly

to the design/setup of the conveyor belt

equipment as well as 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 MOIs for

GCPs when finalized are posted for public review

on the FSIS website and that the information

associated with NRS and MOIs can be FOIA

requested by individuals from the general public.  

Documented by 

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

(b) (6)

(b) (4)
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50 P286 Perdue Foods LLC MOB05100

11830G

30JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1040 hours on Wednesday,

January 30, 2019, met with

establishment 

 and 

, to discuss poultry good commercial

practices during the upcoming cold weather. 

 informed 

that the outside temperatures over the next

couple of days are going to be extremely cold and

their plans should be in place to make sure that

the incoming turkeys are handled in a way that

conforms to poultry good commercial practices. 

 stated that they decreased the

number of turkeys to be slaughtered on today,

Wednesday, January 30, by 6000 birds which will

result in a daily total of 28,962 turkeys will to be

slaughtered. stated all

turkey cages have plywood barriers on sides and

backs of cages. Plywood barriers should help keep

the wind off of the turkeys while they are in

transit or at the establishment shade and should

also help keep the body heat of the turkeys inside

the cages. The establishment shade has sturdy

canvas curtains to prevent direct cold wind to the

shades. also stated that the

farms that are scheduled to be slaughtered on

today are not too far from the establishment,

which should also diminish the amount of

environmental stress on turkeys. Also, there

should not be long holding time for the turkey

slaughter at the establishment till weather comes

back to normal. informed 

 that we will be closely monitoring

handling of the turkeys from the time they enter

the establishment premises until slaughtered to

make sure that they are handled with poultry

good commercial practices. Also, monitoring DOA

counts for potential increased numbers from

colder than normal ambient temperatures. 

(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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 IIC Perdue Foods Inc., Est. 286P

Washington, IN 47501

(b) (6)
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50 P286 Perdue Foods LLC MOB08160

33601G

01MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized February 28, 2019 FROM:            

 SUBJECT:      Good Commercial Practices

(GCP) Memorandum of Interview (MOI), Perdue

Foods, Inc., Establishment Number P286 As part

of a routine GCP assessment, observations were

being conducted at the live hang bay, the point on

the process after which the crates of young

turkeys had been subject to controlled

atmosphere stunning. The stunned birds are

manually removed from stacked poultry crates

located on semi-trailers. The intent is the birds are

irreversibly stunned at this stage, so the birds may

be inverted easily, and the feet placed into the

shackles on the moving line as it proceeds to the

neck cutting area. Although not directly related to

the establishments slaughter process, the

establishment has allowed a company to harvest

feathers at a point on the line prior to neck

cutting. Occasionally, a live bird is observed on

the line and the backup cutter employee is

required to identify and cut the neck to ensure no

live birds enter the scalder.  However, it is also

important that the employee of the feather

harvesting company recognize an unstunned bird

that remains conscious to avoid plucking feathers

from a live bird. At approximately 1430 hours, a

live turkey was observed on the line.  As the bird

was observed and followed through the process,

the feather harvesting company employee was

observed to disregard the state of consciousness

of the bird and grab a fistful of feathers from the

conscious bird hanging in the shackles. 

 who was present in

the area, was immediately notified of the

observation and that it was inconsistent with

Good Commercial Practices. 

immediately contacted the supervisor and relayed

the observed incident. At approximately 1432,

another unstunned bird was observed and

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

(b) (6)

(b) (6) (b) (6)
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followed through the process to the point of the

feather picking company employee.  The

employee was again observed to disregard the

state of consciousness of the bird and grab a

fistful of feathers from the live bird.  

was immediately notified of the second

observations and the supervisor removed the

feather picking company form the line at that

time. was informed that a GCP MOI

would be generated to document the

observations and subsequent conversation

regarding the obligation for implementation of

Good Commercial Practices for all individuals

handling live poultry on the official premises, to

include those that may not be directly employed

by the establishment.

(b) (6) (b) (6)
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85 P32 Mar-Jac Poultry, Inc. CAA44010

12525G

25JAN2019 04C05 Poultry Good

Commercial

Practices

Open The meeting was held in USDA office between

plant management P32 and USDA IPP.  In

attendance: ; 

; 

 Mistreatment of

Poultry: At approximately 0350 hrs on 1/24/19

, CSI day shift inspector witnessed a

live bird being mistreated. was parked

in the USDA parking lot and saw out of his car

window  a fork lift driver carrying a dumpster. He

saw the driver stop and step off the vehicle to

retrieve a live bird that fell from the dumpster. 

The driver than stomped on the live bird's  head

and placed the carcass back inside the dumpster

to resume  toward the offal department. Based on

the isolated finding, the establishment is

mistreating a live bird else where other than

slaughter operation. immediately

reported the incident to . 

discussed the mistreatment with the

establishment in the upcoming meeting Friday

morning 0200 hrs. Plant Management response: 

was concerned about the poultry mistreatment.

He immediately went outside with 

soon after he heard of the mishandling of the live

bird and investigated where the bird have died.  It

was raining outside during the time they were at

the location.  In the meeting between USDA and

plant management, stated that he didn't see

any evidence of blood or feathers on the ground

at the location of the mistreatment but said he

would look further into the matter with the fork

lift driver.

(b) (6)(b) 

(b) (6)

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

(6)

(b) (6)
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40 P325 Tyson Foods, Inc. YDM23190

31913G

13MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized On March 13, 2019 at approximately 1520 while

conducting a GCP task observed

the following conditions in the Live Hang

department.  Nine DOA birds were on the floor to

the side of the metal DOA bin.  The metal DOA bin

at the end of the live hang belt was three birds

deep and no one was removing the birds from the

bin.  asked the live hang supervisor to

remove the birds from the bin.  Upon closer

inspection there were a total of three live birds

mixed in with the DOAs in the bin.  Those birds

were underneath the other layer of dead birds. I

notified GPM William Beck of the concern with

live bird humane handling.    GPM William Beck

stated that the team member operating the

dumper was dumping the cages too frequently

and the birds became piled on top of each other

causing the smothering of the birds and the

increased number of DOA birds in the Live Hang

department.  He also stated that he had placed

two team members to dispose of the DOA birds in

the DOA bin, but when 

arrived there was no one removing the heads and

disposing of carcasses in the condemn barrels. 

The mixing of live birds with dead birds in the

DOA bin can suffocate the live, weak birds and is

not consistent with the Agency expectations for

handling of live poultry. Allowing the DOA bin to

fill two three layers of birds deep with overflow

onto the floor is indicative of a loss of process

control and is not acceptable.  The establishment

is asked to ensure establishment employees

handling live animals are aware of company

policies regarding live bird handling. 

Employing humane methods of handling

consistent with Good Commercial Practices can

help produce an unadulterated product.  Copies

of this Memorandum of interview will be

distributed to the establishment, inspection file

and the District Veterinary Medical Specialist per

(b) (6) (b) (6) (b) (6)
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FSIS Directive 6100.3.  The issue will also be

discussed at the next weekly meeting.

40 P33900 Foster Poultry Farms, A California

Corporation

NHH57090

12730G

30JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0820 hours while verifying

poultry Good Commercial Practices requirements

four live chickens were observed falling through

two large holes in the bottom of a cage while the

cage was in the process of being dumped.  The

cage was lowered onto the birds crushing one. 

 and

were notified of the issue and took control.   At

approximately 0830 hours, inspection met with

Mr. Matt Ottinger, plant manager, and 

  As a corrective measure 

elected to put extra personnel in place to make

sure poultry were properly dumped and none

were trapped under cages.  Also, live receiving

personnel would tag cages to make sure they

were repaired prior to being returned to use.

50 P34287 Huismann's Poultry THU45060

35922G

22MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized Establishment P- 34287 On 03/21/2019 at the

end of slaughter operations noted that

there were multiple coops containing young

broiler chickens being held in the live receiving

area. On 03/22/2019 while performing a Good

Commercial Practices task noted that

these same coops where still in the live receiving

area meaning that these birds were being held in

excess of 18 hours in the receiving area. I

immediately went to the office and discussed this

with . I explained that according

to good commercial practices that young broiler

chickens should not be held in excess of 16 hour

in coops or on trucks and these birds had clearly

exceeded that. stated that she

would discuss this with Plant Management.

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

(b) (6)
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25 P34668 Simply Essentials Poultry, LLC SFJ361102

4111G

11FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized On February 8, 2019 lot 2 was slaughtered at the

plant.  Each of the loads had a large number of

dead on arrivals.  The total number from the loads

was 12815 head weighing 59619 pounds.  The

birds were cold and stiff.  The dead birds were

spread evenly among and throughout the trucks. 

All trucks were affected.   Please investigate this

incident and advise the inspection staff of the

cause and any preventive measures.

40 P46374 Sanderson Farms, Inc. Tyler Processing

Division

AQI210702

2418G

18FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Poultry Mistreatment Meeting at Est. P-46374,

Sanderson Farms - Tyler in February 18, 2019 at

0545 hours. In attendance: 

 and 

 At approximately 0510

hours, while performing Poultry Good Commercial

Practices observed pile up of

birds in the conveyor belt at the live hang room. 

Approximately 200 dead or bewildered birds were

pulled out.  The confirmed dead birds were

promptly rendered and few birds that recovered

are hanged back. According to , piling

up of birds is due to inappropriate and untimely

belt adjustment by the lead man. I

recommended to to review the Federal

Register Notice Vol. 70, No. 187, published

September 2005 (Docket No. 04-037N). I also

notified PM Harris that this Memorandum of

Interview (MOI) will be written which will be

forwarded to the District Office and the District

Veterinary Medical Specialist (DVMS) in case

additional follow up is recommended. 

Respectfully, of Est.

P46374 – Sanderson Farms at Tyler

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

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

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80 P510 House Of Raeford Farms RHB44130

33204G

04MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized Ms. Nicole Reynolds, Plant Manager, P-510 

House of Raeford Rose Hill, NC 28458 Ms.

Reynolds At approximately 1352 while

performing the Good Commercial Practices

Verification task, I observed a live bird about to

enter the scalder.  The bird at the time of my

observation had normal rhythmic breathing, eyes

open and blinking with the head elevated.  I

immediately pointed out the bird to 

, who stopped the line

before the bird could enter the scalder and

removed the bird from the line.  After removing

the bird from the line, it was observed that there

was no cut on the neck which would not have

allowed the bird to bleed out properly. 

took the bird back to live hang to show

it to   

 placed the bird back onto the kill line to

allow it to go back through the stunner and the

kill blade to allow proper bleeding. 

, instructed the

backup cutter to pay more attention to the

smaller birds going through.  I discussed my

finding with and and

notified them of the pending MOI and the

establishment’s failure to comply with 9 CFR

381.65 (b) which states: Poultry must be

slaughtered in accordance with good commercial

practices in a manner that will result in thorough

bleeding of the carcasses and ensure that

breathing has stopped prior to scalding.   

, was also notified my findings.   

 this MOI will be forwarded to the

District Veterinary Medical Specialist (DVMS) in

case additional follow-up is recommended.  If

you have any questions or concerns regarding the

above, please contact 

Respectfully, P510

(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 P510 House Of Raeford Farms RHB05080

35828G

28MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized Ms. Nicole Reynolds, Plant Manager 

Establishment P510 House of Raeford Farm, Inc. 

Rose Hill, NC 28458 Ms. Reynolds, On

03/28/2019, at approximately 0721 hours, while

performing a Good Commercial Practices task in

the Live Hang Room, I noted 5 live birds in the

span of 1-2 minutes about to enter the scalder.  At

the time of my observations, each bird had

normal rhythmic breathing, eyes open and

blinking with the head elevated.  A team member

was in the area who stopped the line and

removed each bird from the line before they could

enter the scalder.  On further observation of each

bird, 3 did not have a cut on the neck to allow the

birds to bleed out properly.  The remaining birds

had incomplete cuts on the neck which did not

allow the birds to bleed out completely before

entering the scalder.  Each bird was placed back

on the line to go through the proper slaughter

process.    was made aware of my

findings and was notified that a GCP MOI would

be written and sent to the DVMS as a result.  He

reported that a new back up killer is currently

being trained.  stated that the trainer

was not paying attention and had stepped away

from the platform.  Following this incident, the

trainer was instructed to pay more attention and

to stay at the platform while the new team

member is being trained.  Following this

conversation, I repeated my Good Commercial

Practices task and verified that the trainer was

present on the platform in a location closest to

the automatic kill blade.    A previous

memorandum was written on 03/04/2019 for

similar findings.  In this memorandum (MOI#

RHB1412035404I), a live bird was found at the

scalder entrance without a cut on the neck.  The

incident was attributed to the back-up cutter not

paying attention and the preventive measure

cited was to instruct the back-up cutter to pay

(b) (6) (b) (6)
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more attention to the smaller birds as they pass

the kill blade.      The plant’s preventative

measures must be proactive and effective to

ensure that birds entering the establishment do

not die from causes other than slaughter.  PPIA

and Agency regulations require that live poultry

be handled in a manner that is consistent with

good commercial practices (GCP), and that they

do not die from causes other than slaughter.  It is

the establishment’s responsibility to ensure that

birds are slaughtered in accordance with 9 CFR

381.65(b). A copy of this MOI will be forwarded to

the District Veterinary Medical Specialist (DVMS)

in the event that an additional follow-up is

recommended. If you have any questions or

concerns regarding this MOI, please feel free to

contact myself or 

. Respectfully,   

Tyson Foods, Inc., Monroe

(b) (6)

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

90 P517 Mar-Jac Poultry-MS QOO36010

20009G

09FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Mar-Jac Poultry,

MS 1301 James Street Hattiesburg, MS 39401 

 At approximately 2145 hours on

February 8, 2019, the following less than Good

Commercial Practices (GCP) incident was observed

at Mar-Jac Poultry in Hattiesburg, MS. Two (2) live

young chickens with uplifted heads, 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.

 was verbally

notified of the incident at approximately 2200

hours. A second verification check of an

approximate 500 bird random subgroup sample

on the north picking line at approximately 2215

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 GCP

and causes needless suffering and death and

results 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. 

 was advised a GCP Memorandum of

Interview would be issued to management

pending review by . 

Respectfully, ,

Hattiesburg, MS 39401 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 QOO08030

23819G

19FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized Mar-Jac Poultry,

MS 1301 James Street Hattiesburg, MS 39401 

 At approximately 2030 hours on

February 18, 2019, the following less than Good

Commercial Practices (GCP) incident was observed

at Mar-Jac Poultry in Hattiesburg, MS. 

 observed five (5) live birds (bright, alert,

and responsive) being pulled from a pile at the

end of the line onveyer belt in live hang where

they were comingled with DOA birds.

Additionally, upon

arrival to live hang at approximately 2035,

observed an additional (1) bird (bright, alert, and

responsive) pulled from the same pile where it

had been comingled with dead birds. 

 was verbally

notified of the incident at approximately 2100

hours. Comingling live birds with DOAs can cause

suffocation and death by means other than

slaughter resulting in adulterated product. The

establishment must ensure that birds under their

control on the official premises are treated in a

manner that will minimize discomfort, injury,

and/or death by means other than slaughter. 

 was advised a GCP Memorandum of

Interview would be issued to management

pending review by 

Respectfully, 

(b) (6)

(b) (6)

(b) (6)

(b) 

(6)

(b) 

(6) (b) (6)

(b) (6)

(b) (6) (b) (4)
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90 P517 Mar-Jac Poultry-MS QOO28000

35305G

05MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized Manager Mar-Jac

Poultry, MS 1301 James Street Hattiesburg, MS

39401 At approximately 2045 hours

on March 4, 2019, the following less than Good

Commercial Practices (GCP) incident was observed

at Mar-Jac Poultry in Hattiesburg, MS. 

 observed a bird trapped in a

hole in the flooring of an otherwise empty cage

on a truck being prepared to leave the

establishment. The hole in flooring was between

the upper two chambers of the cage and

measured approximately 15 cm by 15 cm. The

bird was trapped in a position in which one leg

and one wing were in the lower of the two

chambers, one wing was in the upper chamber,

and the other leg was wedged against the body in

such a way that the foot was in the upper

chamber and the hock was in the lower chamber.

Additionally, the neck was in a distorted position

and wedged against the body in such a way that

the base of the neck was in the lower chamber

and the head was in the upper chamber. 

, was notified

immediately of the incident, the cage was

removed from the truck, and the welfare situation

was corrected. 

, was verbally notified of the incident at

approximately 2250 hours. This is a predictable

consequence of the state of repair of the cages

used for transporting the live birds. The condition

of the cages has been a consistent talking point at

night shift weekly meetings for 11 months.

Additionally, the establishment was specifically

warned at the most recent night shift weekly

meeting (0400 on 3/1/19) that the condition of

the cages increased the likelihood of an animal

welfare issue after a truck almost backed over a

loose bird (only intervention by FSIS personnel

prevented that occurrence). Birds trapped in

such a way as this one are in obvious discomfort

(b) (6)

(b) 

(6)

(b) 

(6)

(b) (6)

(b) (6)
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and at increased risk of injury. Had the bird made

the return trip to a chicken house, it would have

seen additional exposure to the elements. The

establishment must ensure that birds under their

control on the official premises are treated in a

manner that will minimize discomfort, injury,

and/or death by means other than slaughter. 

Respectfully, . 

________________________________________ 

 Hattiesburg,

MS 39401 cc: 

90 P522 Sanderson Farms, Inc. (Processing Div) IKB070701

0303G

03JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On January 3, 2019 at approximately 0520 hours

while conducting a Good Commercial Practice

check with Dr. , and

 8, in the Picking Room of

establishment P-522, the following was observed. 

One live bird entered the scalder on the outside

Picking Line. The bird was consciously alert,

blinking its eyes, and looking around at its

surroundings as it hung on the Picking Line. There

was no blood or cut on the neck of the bird. 

 was notified of

the pending 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

Practices. Respectively, 

 

(b) (6)

(b) (6)

(b) (6)

(b) 

(6) (b) (6)

(b) (6)
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90 P522 Sanderson Farms, Inc. (Processing Div) IKB200703

1308G

08MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized On March 8, 2019 at approximately 0509 hours

while conducting a Good Commercial Practice

check in the Picking Room of establishment

P-522, I observed the following: I observed one

(1) live bird enter the scalder on the inside Picking

Line.  The bird was alert, blinking its eyes, and

moved its head back and forth as it looked

around.  No blood or cut was observed on the

neck of the bird.  No additional live birds were

observed entering the scalding system.  

 was notified of

the observation and pending MOI. Respectively, 

60 P533 Hain Pure Protein Corporation - FreeBird

East

AKB550301

4724G

24JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1110 hours while in Live

Receiving I was observing birds as they exited the

blood tunnel immediately before they enter the

scalder. During my observation I witnessed a bird

leave the blood tunnel that was still moving it

head and beak and was also flapping its wings. I

observed the bird enter the scalder water in this

condition which resulted in the chicken being

drowned, therefore dying by a means other than

slaughter. I immediately found 

, and informed him what

had occurred. He informed me that he would act

immediately to prevent it from happening again.

(b) (6)

(b) 

(6)

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

East

AKB081203

0326G

26MAR2019 04C05 Poultry Good

Commercial

Practices

Open On Tuesday 3/26/19 in the time frame of 0600 to

0620 I observed the following conditions in the

picking area. Upon entering the department, I

could see immediately the establishment

employee positioned between the wash cabinet

and the scalder hanging the dropped leg of birds

back into the shackle. While I did not get an exact

count, I estimate this to be between 4 to 6 birds. I

observed the birds in the blood tunnel and during

my observation of the birds at this time I observed

between 7-10 additional birds hanging by one leg

in the shackle. I went into the hanging area and

watched the hangers for a few minutes. Their

hanging didn’t seem to be impeded or obstructed

and the birds were being hung correctly in my

presence. I returned to the blood tunnel and

waited a few minutes. I observed 2-4 more birds

hanging by one leg. Correct shackling is critical

for proper stunning.  Birds must be hung by both

legs.  Pre-shocks may result from parts other than

the head coming in contact with the electrified

water.  This can lower stunning percentages as the

birds flap their wings and lift their heads out of

the bath.  Flapping wings may also result in

broken wings.  Improper hanging also can result in

improper cutting at the kill blade or by the

backup which could result in incomplete

bleed-out.   I informed 

 of what I had seen. The

establishment brought some additional

employees into the area to help prevent the birds

being hung by one leg. I spoke with 

about ten minutes after this incident and he told

me that the hanger responsible is going to be

disciplined and possibly removed from the

department.  The issue was raised previously at

the following weekly meetings: On 2/8/19 - 4 or

5 birds around 1145 yesterday went through kill

blade hanging by one leg in the shackle. On

3/1/19 - Numerous live birds were seen hanging

(b) (6)

(b) (6)
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by one leg on Monday and Tuesday(2/25-26.) I

spoke with on the 26th and he stated

there is one live hanger who they are working

with to make sure he understands the legs of the

bird must be fully hung into the shackle. On

3/15/19 - Continued observation of birds hanging

on the kill line by one leg. Though the amount

observed by USDA has decreased it is still an issue.

 stated they are actively training the

hangers with the importance of hanging two legs

firmly on the shackle.

(b) (6) (b) (6)
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25 P544A Jennie-O Turkey Store Sales KXJ570701

5303G

03JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 20:45, after I had finished the

TOC diagnostic test on the first lot of Turkeys, the

food inspector at outside 2 summoned my

attention and showed me a turkey carcass that

was bruised in the hip and thigh.  The femur was

broken and there was frank blood between the

skin and the muscle, indicating that the injury had

occurred before death.  The inspector brought it

to my attention that two other inspectors had

found similar carcasses at their station.  Thus, it

appeared that there was a cluster of three or four

such carcasses within a short amount of time.  I

went looking for the evisceration room supervisor

and found .  When I told him

about it, he said that he had already taken

photographs of all the birds and sent it to 

, night superintendent. 

 said he would get back to me with

what he finds out. Later, I met with

 (day production superintendent).  I

explained to him that , who has

experience with loading crews, has explained to

me how the loading crew operator(s) can, if not

careful, operate the machinery in such a way that

pinch points are created between the loading

machine and the frame of the cage on the truck,

resulting in injuries to the birds.  said that he

was going to have the loading crew manager look

into it and see how this can be prevented in the

future.  I asked him to look into whether it could

be the loader operator, not just the loader itself.

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

(6)

(b) 

(6)

(b) 

(6)
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35 P550 Simmons Prepared Foods, Inc. XWN44050

31006G

06MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized 0745 hours I found 3 carcasses on Kill Line 1 at

the dumper that were stuck on a piece of bent

metal in the corner closes to the 

employee that was operating the dumper and was

just above the belt than conveys the

carcasses into live hang area. I inform the lead in

RKP management about the carcasses and watch

the lead stop the equipment to remove the

carcasses. I observed the operation of the

equipment for approximately 3-5 more minutes

after management resumed processes and

noticed another chicken got caught in the piece of

bent metal by its foot. Although, the 

employee that was operating the dumper did stop

the machine and removed the chicken again from

the bent piece of metal it was going to be an issue

during processing. I then Notified 

 at approximately 0758 hours, about

my issue that I had with the piece of bent metal

catching birds and not properly being handle. I

notified my and was

informed to go discuss my issues and findings

with the 

 asked me to show him the exact area of

the piece of bent metal that was causing the birds

to be affected or mishandled.

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

(b) (6) (b) 

(6) (b) (6)
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90 P559 Tyson Foods, Inc. UWC14150

14323G

23JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At 15:00 hours during the performance of a Good

Commercial Practices task, I observed a pile of

15 - 20 birds at the DOA end of the rehang belt.

There were three small, live birds on the periphery

of the pile which I handed to one of the live hang

personnel. As I removed more birds from the pile,

I found two live birds at the bottom of the pile.

This puts live birds in a position to be suffocated. 

I took a regulatory control action by directing the

live hang personnel to stop hanging birds on the

kill line. I found a QA technician with a radio to

call the 

 Before her arrival, I spoke

with and

explained the problem. Once the GPM arrived, I

explained the situation to her and told her I

needed a corrective action from her before I

would allow the operation to resume. Her

immediate corrective action was to place a person

at the end of the belt to watch for small birds

coming off the belt through out the remained of

the flock. Since there was only one flock

scheduled for second shift, that person should be

there for the rest of the shift. Down time was

approximately 7 minutes. I have repeatedly

stressed to management the need to prevent pile

ups at the end of the belt in order to prevent such

an occurrence.

(b) (6)

(b) (6)
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO230802

3211G

11FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 9:25 am this morning,

02/09/19, I observed (1) live loose turkey on the

south side upper walkway and (2) live loose

turkeys on the north side upper unloading

walk-way. These birds were allowed to roam

freely as establishment employees continued to

unload birds from the coops. Additionally, I

observed live loose turkeys on the lower level

walkways of the truck unloading bay/lift area, (2)

birds on the north side and (2) on the south side

of the truck. These birds had either been left

unattended to roam on the upper walkway and

then fall or had immediately fallen during the

unloading process from the upper platform to the

floor below. The (2) live birds on the north side

of the lower walkway were both found on the

walkway. On the south side of the truck unloading

bay/lift area (near the driver’s side door) there

was (1) bird under the truck lift and (1) bird

standing in an uncovered area of the feather

trough. I also observed that the truck lift was

continually being lowered without the birds being

addressed by establishment personnel. I noted

that there was a green plastic grate that had been

pulled exposing the trough at the end of the

feather trough (near the turn to the feather

separator). A bird was observed standing in the

open part of the trough. The observed bird was

standing in approximately a 1⁄2 “of water and was

not under stress. The establishment did have a

red cone placed on the floor near the open

trough/trench cautioning employees to be careful

of the area, but, this didn’t prevent access for the

bird to the trough/trench. I went to notify a live

hang employee/supervisor of the loose birds

including the one under the lift and the one in the

feather trough, but, was not able to find anyone

at the time. When I turned around the bird that

was observed in the trough was gone. I went to

see where the bird had gone and when I got to
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 84

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the area I observed that the trough was over (3⁄4

full of fast flowing water and feathers) and there

was no sign that the bird had removed itself or

had been removed from the trough by an

establishment employee because I only saw 1 of

the 2 birds present in the area. I then suspected

the bird must have gotten washed away by the

increased volume of water and feathers and

managed to get caught up in the feather

separator, pulled up the conveyor and deposited

in the feather tanker. I immediately went up on

the walkway on top of and next to the feather

tanker and noted (2) motionless intact birds in the

tanker in addition to the feathers. (1), clearly had

been cut at the neck and was not of concern the

others injuries were not readily apparent, but, did

look like the bird that I had observed in the

trough. I immediately went to find a live hang

employee with a radio to call ,

so, that I could bring my observations and

concerns to their attention. When they both

arrived I explained the situation, my observations,

and my conclusions to both .

All (3) of us then went on the walkway to look at

the birds that I had observed earlier in the feather

tanker. were able to pull the

bird in question from the feather tanker, so, that

we could inspect the bird. I was able to confirm

that the injuries observed to this bird were

consistent with injury due to being caught up by

the feather separator. The bird was wet, intact,

feathered and exhibited signs of acute trauma

secondary to having being crushed by the

separator. Additionally, I observed water exit the

birds mouth (after it had been removed from the

feather tanker) suggesting that it had taken on

water and drowned as well. This is consistent with

what would be expected if a bird had entered the

feather separator after being swept away by fast

flowing water and feathers from the trough. 

(b) (6) (b) (6) (b) (6)
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While speaking with in front of

the truck I noted that there were 2-3 loose live

birds on the north side upper walkway and 2 birds

on the south side upper walkway. I did not see

unloading employees addressing these birds

which were allowed to roam the platform.

 and I then observed (1) of the

birds on the south side upper walkway fall of the

walkway onto the truck lift in front of the truck.

Josue removed this bird from in front of the truck

and Mustafa directed unloading employees to

address the loose birds on the upper walkway,

lower walkway, under the truck and on the floor. 

The bird that died by from causes other than

slaughter was cut and condemned by

establishment personnel at direction. 

USDA has concerns that establishment employees

are not addressing loose birds, early, and are

allowing them to roam freely increasing the risk

that they could be injured or injure themselves. 

Establishment employees should not continue to

unload birds with loose birds observed on upper

platforms or allow those that had fallen to the

floor to roam unattended longer than necessary. 

These birds are being put at risk of injury,

unnecessarily, due to improper handling and

monitoring by establishment personnel during the

unloading process. I am documenting my

observations and findings in this MOI dated

02/09/19.   

(b) (6) (b) (6) (b) (6) (b) (6)
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO552002

0921G

21FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 19:51 hours on 2/20/2019, I

observed an establishment employee removing a

turkey from under the truck lift.  I directed the

employee to lay the bird in the light so I could

inspect it.  The bird was dead; it was

disemboweled with a significant length of

intestine prolapsed outside the body cavity. 

Given the condition and location, the turkey had

mostly likely been crushed to death by the truck

lift. I notified , who said

he would hold a meeting to discuss the incident.

(b) (6)
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25 P579 Jennie-O Turkey Store Sales, Inc. UIO501803

0322G

22MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 16:35 while observing

operations in the live-hang area, I found a number

of turkeys with extensive injuries.  Four of the

more severely injured turkeys are described here,

and there were at least six more that I observed

on the line with injuries. Turkey #1: extensive

tissue damage over an approximately 12 x 18 inch

area over the middle back to the base of the

neck.  Exposed muscle tissue was mutilated and

hemorrhagic, and pieces of muscle tissue

appeared to be missing.  Feathers surrounding the

wound were bloody. Turkey #2: an

approximately 6 x 8 inch skin de-gloving injury

over the lower back; the underlying tissue was

moist but intact.  In addition there was an

approximately 4 x 6 inch skin de-gloving injury

over the left thigh; the exposed thigh muscle was

intact and dry. Turkey #3: massive tissue damage

to the left drum; the muscles of the drum were

pulled apart and the underlying bones were

exposed.  In addition, there was a compound

fracture of the left humerus. Turkey #4: massive

tissue damage to the neck; the skin was

completely peeled off for most of the length of

the neck, and the underlying vessels, trachea,

esophagus and other tissues were destroyed.  In

addition, there was an approximately 6 x 8 inch

hematoma over the left thigh and an

approximately 4 x 4 inch skin de-gloving injury

over the left elbow.  I later spoke with

.  reported

that one of the conveyor belts in the CO2

stunning system had stopped moving, resulting in

a clog of turkeys inside the enclosed system.  The

belt in question is located in the system upstream

from the CO2  stunning chamber, so the turkeys

involved in the clog would not yet have received a

stunning dose of CO2 gas.  The extensive and

widespread injuries I observed are consistent with

similar incidents have occurred in the past. A

(b) (6) (b) (6)
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new system installed in the last few months is

supposed to shut down the entire system of

conveyors if one malfunctions, so I asked 

 to investigate why it appears that this did

not work.  I notified that I would be

documenting this incident.

(b) (6)

(b) 

(6)
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90 P6504 Peco Foods, Inc. CHK22000

12411G

11JAN2019 04C05 Poultry Good

Commercial

Practices

Open P-6504 Peco Foods, Inc. Tuscaloosa, AL 

Meeting Date:  6 Jan 2019         Mtg. Time:  0400

hours Meeting Participants:     

                               

 

                                    

                                     

                                    

 At

approximately 0015 hours on 3 January 2019 I

witnessed that most of the poultry in the trailers

under the holding sheds (6 trailers total) out on

the back lot were very wet from the rainfall that

night and also witnessed that the cooling fans

were on and functional.  The temperature was

approximately 50F and the birds were shivering,

eyes closed, and all huddled together seemingly

trying to keep warm.  They were quiet or

comatose due to these conditions.  I met shortly

thereafter with , the

evisceration superintendent, and told him about

the conditions of the birds.  He then contacted the

, and told

him to turn the fans off.  The fans, by company

policy, are supposed to be turned off at 49F. 

However with the added moisture I believe it was

making the chickens very cold and should be

defined as mistreatment.  A significant number of

DOAs were observed in the trailers as well, more

than the usual number.  A record review of the

DOAs for that night indicated that the

percentages were high for this plant at

approximately 0.5% per trailer.  The Lot DOA

(each grower is a separate lot) was nearly 0.5%. 

The series of events was discussed at the weekly

meeting 6 Jan 2019.

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6) (b) (6)
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90 P6504 Peco Foods, Inc. CHK42000

13611G

11JAN2019 04C05 Poultry Good

Commercial

Practices

Open P-6504 Peco Foods, Inc. Meeting Date:  9 Jan

2019 Meeting Time:  0400 hours Meeting

Participants: 

 

 On 7 Jan 2019 at the live hang table

on the back dock at P-6504 at approximately

0400 hours I witnessed , one of the

hangers, slamming chickens down into the

shackles with force far in excess of what is needed

to secure the birds into the shackle slots.  

 was also there

and witnessed the event.  I told that

this was unacceptable and he spoke with 

  I then went directly to the evisceration

office and spoke to 

.  I informed that I

have complained about this individual for the past

12 months and nothing has been done.  

 then made moves to terminate the

employee.  Apparently at a later time the

management of P-6504 reviewed video footage

and reversed the termination, turning into a

short-term suspension.  is now back at

work in the same position performing the same

duties.  He has not been witnessed using excessive

force as of yet.

(b) (6)

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

(6)

(b) 

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

(b) (6) (b) 

(6) (b) (6)
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85 P6505 Norman W. Fries, Inc. BBA330701

2325G

25JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized While observing conditions in the live hang area

at 0650 hours, I observed approximately 10 birds

that appeared to be all dead on the floor at the

exit end of the live hang conveyor belt identified

as "LIVE HANG CONVEYOR, SYSTEM #2".  The

10 birds were commingled in a pile along with

excrement and extraneous material making a

mass approximately 2 foot by 1 1/2 foot by 10

inches in beveled height.  As I watched operations

in this area, I observed an employee remove a

couple of birds from the top of this pile at this

location and dispose of them into a condemn

barrel.  As the employee was removed the top

carcasses, I observed three of the birds under

these dead birds to still be alive.  I observed the

employee remove these live birds from the pile

and hang two of them on the kill/pick line.  I

observed him pull the head off the other live bird

and toss it on the floor beside the wall.  I

notified designated 

 whom had just entered

the area.  Also, I notified 

of these observations.     I reminded

 that the PPIA

and Agency regulations require that live poultry

be handled in a manner that is consistent with

good commercial practices and that they not die

from causes other than slaughter. I recommended

that they 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 and

provided him a copy of this document. I notified

these establishment contact personnel 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)
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90 P6638 Pilgrims Pride Corporation UDG04230

13616G

16JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On January 16, 2019, at approximately 2239

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

one (1) live bird in the DOA (Dead on Arrival)

dumpster by the cage dump in the Live Receiving

Area of the establishment.  The bird had its eyes

closed but was taking agonal breaths.  I notified

 because she was

standing on the dock next to me at the time of

observation to call for .  As

we waited for also witness

the bird take additional agonal breaths.  The beak

was open and closing each time for a total of 5

breaths prior to being removed from the

dumpster.  I then examined the bird after removal

from the dumpster and the bird continued to take

agonal breaths by opening and closing the beak. 

The bird was small in frame and cold to touch. 

The bird moved slightly when stimulated by

touch.  The bird had already been sprayed with

red colored denaturant.  Previous corrective

actions for live birds previous found in the DOA

dumpster consisted of removal of all heads prior

to being placed in the dumpster.  The

establishment failed to implement this corrective

action.  I informed and

 of the

documentation of this Memorandum of

Information (MOI).  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 concerning treatment of live

poultry before slaughter.  Respectfully

Submitted, cc: 

 cc: 

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 93

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Task

Code TaskName Status MOI Agenda

40 P7044 Tyson Foods, Inc. GJJ242303

4329G

29MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2139 on March 29, 2019, 

 was doing an ante-mortem and good

commercial practices check.  Upon entering the

hanging pen there was approximately 16 live birds

walking around the hanging pen and in adjacent

rooms.  There were at least nine DOAs that were

on the floor adjacent to the belt in the hanging

pen.  stopped the line from hanging and

then the team members picked up all the DOAs

and live birds on the floor.  As the GCP task was

continued, there were two live birds under the

stunner and in the corner adjacent to the backup

cutter.  Outside under the dumper there were

three live birds walking around within and outside

of the wire fencing under the dumper. 

 was informed of

the non-regulatory concerns and the forthcoming

MOI.   There was no supervisor or floor person

working the area.  Employing humane methods

of handling consistent with Good Commercial

Practices can help produce an unadulterated

product.  Plant Management is asked to 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)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 94

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Code TaskName Status MOI Agenda

35 P727 Simmons Prepared Foods, Inc. VCF340201

0816G

16JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On 01/14/19 at 0325 hours, while performing a

GCP task I, with ,

observed 14 chickens inside the top row of a cage

in the cage rebuild area.  10 of the chickens were

dead, 2 of these had their heads stuck under the

damaged door to the cage and 4 birds were alive.

I also observed 1 dead chicken laying on the

ground next to these cages.  

, was present at the time of this finding. I

also observed that several of the cages on the

trailers in the dumping area were missing covers.

We then proceeded to verify the birds on the

trailers in the holding shed. There were 6 trailers

in the holding shed and each trailer had multiple

covers missing from the cages. The fans in bay 8

and 3 were blowing onto the uncovered cages.

When was asked why the fans were

on when the temperature was 30 degrees he

stated the fans are automated. We then observed

the DOA tank and observed a live bird partially

buried with the DOA carcasses. The tank was

approximately 1⁄2 full and no denaturant was

visible. , removed the

live bird from the tank and returned it to the live

hang area.

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
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35 P727 Simmons Prepared Foods, Inc. VCF390201

2221G

21JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On 01/15/19, at approximately 2127 hours, while

verifying GCP/Ante mortem, I, , observed

trailer # 092399 staged in the live dock/dumper

area with cages full of waiting birds.  I noticed,

behind this trailer sat a cage on the ground.  I

asked live hang supervisor, , why

the cage was on the ground.  He stated that the

cage was empty so the fork lift driver had

removed it from the trailer so he could get to the

full one below it.  I looked inside the cage at this

time and observed multiple dead carcasses on one

of the shelves inside the cage.  I showed the dead

carcasses to and evisceration

superintendent, .  I asked 

why there were dead carcasses in a cage sitting on

the ground.  spoke with the fork lift

driver who was removing cages from the trailer. 

 then came back and told me that the

fork lift driver was going to take the cage to the

dumper area so that it could be emptied.  At this

moment the driver picked up the cage and placed

it back on the trailer with the dead carcasses still

in it.  I notified that the cage had

been placed on the trailer not in the dumper area

as he had stated they would do.  and

 went to the driver and spoke with him. 

The cage was removed from the trailer and sent to

the dumper area where I observed the

establishment remove 57 dead carcasses from the

cage and dispose of them in the DOA tank. At

approximately 2349 hours, while verifying

GCP/Ante mortem, I, , while observing

the empty trailer holding lot, I noticed a live

chicken inside one of the cages.  The chicken was

on the bottom row of the cage located at the back

of the trailer.  I showed the live chicken to

.  I noted to 

 that the live chicken was located on the

same trailer, #092399, as the one from earlier

that night.  had the trailed pulled

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

(6)

(b) 

(6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 96

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back to the live dock where plant personnel

removed the chicken.

80 P764 Perdue Foods, LLC CUA39200

30926G

26MAR2019 04C05 Poultry Good

Commercial

Practices

Finalized At 1857 hours while performing the Poultry Good

Commercial Practices task in the kill room, I

observed on kill line number two several birds

with neck cut have intense body and wings

motion entering the scalder. This might indicate

that the bleeding equipment was not properly

adjusted, and the neck cuts were inadequate to

achieve thorough bleeding of the birds. Also, I was

able to remove a live bird with no neck cut from

the line before it enters the scalder.  

Immediately, I  notified the

poultry welfare officer and the 

 shift leader of the incident, he

inspected kill line number two and evaluated the

bleeding equipment. Then he indicated that the

kill machine was not properly set up and that

adjustments had to be made to it to get it to

perform at acceptable levels. I reminded 

that live poultry must be treated in a manner

consistent with Good Commercial Practices. I

notified him that this Memorandum of Interview

would be forwarded to the District Veterinary

Medical Specialist (DVMS).

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 97

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Code TaskName Status MOI Agenda

35 P768 Tyson Foods, Inc. BFC080401

4328G

28JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized On Monday, 1-28-2019 morning, at

approximately 2:45 AM, I, 

 was notified by 

that she had just found a dead chicken in the

holding shed that had been run over and crushed.

It was located underneath the parked trailer and

in front of the tires and appeared to have been

accidentally backed over while the trailer was

being parked. The carcass in question was in good

flesh and portions of the viscera and bones were

expelled and located adjacent to the carcass.

There was no obvious dependent blood pooling or

deterioration of the viscera as would be expected

with a bird that is dead on arrival (DOA). This is

an unacceptable finding that is not in accordance

with Good Commercial Practices. Repeated

incidents may indicate damaged caging that is

allowing birds to escape, however, at the time of

the finding there were no significantly damaged

or opened cage banks observed. In addition, there

were no other birds loose in the holding area or

other GCP violations to indicate a loss of process

control and warranting documentation of a

noncompliance record. This is the first known

incident of this type since my arrival in 2017, and

I was unable to locate any documentation of any

similar incidents from prior to my arrival. At

approximately 2:50 AM, CSI Deaton and myself

notified both 

 the finding and explained that it

would be documented under a Good Commercial

Practices MOI. 

acknowledged and informed us that he would

speak with the live haul crew as well as see to it

that the carcass was condemned appropriately.

(b) (6)

(b) (6)

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 98

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Code TaskName Status MOI Agenda

80 P7903 Perdue Foods, LLC UYN06050

10914G

14JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0536 hours, two large piles of

dead and live birds comingled together were

observed on the belt at the end of the two live

hang belts.  The piles of birds were approximately

three to four feet in width, spanned the width of

the sorting belt, and approximately two feet high. 

was informed in the receiving office of these

conditions and we went to the hanging room to

see these conditions together.  

indicated that the person who normally takes care

of this part of the process was not present at work

today.  I indicated that these conditions are not

acceptable under any circumstance and that

either the establishment personnel manage the

area, or the operations would be halted.  I

informed that an MOI would be

issued for the incident.  Upon my arrival to the

evisceration department, I informed 

 of these

conditions and he immediately went to the area

to address the concern.  When we arrived at the

live hang room, 

 was already there and we discussed

these processes and conditions.  

immediately stopped both live hang belts and

kept them off until the two piles of birds were

sorted and handled appropriately.  I informed 

 and that an MOI for GCP

issues would be issued. At approximately 0620

hours, a live bird was observed in the DOA truck

parked outside the receiving area.  In addition,

there was no denaturant present on any of the

carcasses in the truck, numbering approximately

75 – 100 carcasses.  I informed that

these conditions were not acceptable and to stop

hanging live birds until the appropriate

adjustments were made.  I met and

 in the evisceration department

and/or main hallway and notified them of these

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

(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) 

(b) (6) (6) (b) (6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 99

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Code TaskName Status MOI Agenda

findings.  indicated that the conditions

would be rectified immediately and that he would

be spending more time in the receiving area to

retrain employees and emphasize the importance

of proper handling of the birds being processed. 

 removed the live bird from the DOA

truck and applied denaturant to the dead birds

contained within.  Operations were permitted to

resume once these corrections were made and

verified. All the aforementioned statements are

true and correct to the best of my knowledge, as

indicated by my electronic signature below.

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 100

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Task

Code TaskName Status MOI Agenda

80 P843 Pilgrims Pride Corporation PZA071202

0804G

04FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 0914 hours, while performing a

Good Commercial Practice (GCP) Task in Live

Hang, I observed a pile of apparently dead

carcasses on top of the far DOA table.  On closer

observation, I noted three live birds among a pile

of 15 dead carcasses.  One bird was resting at the

top of multiple dead birds and a second bird was

resting directly on the table at the periphery of

the pile.  A third bird was on its back, breathing

with half closed eyes and was observed to be

caught underneath two dead bird carcasses. At

the time, there were no team members on the

floor monitoring the situation and there was no

supervisor in the area.  I moved the two dead

birds from the live bird on its back and the bird

immediately moved to a normal resting position. 

I had the floor lead call Mr. Kevin

r. Sydney

Daigle, Plant Manager, called to the area to show

him my observations.  The live birds were deemed

suitable for slaughter and were returned to the

line.  USDA had discussed similar concerns with

Plant Management on previous occasions.  These

concerns were documented in a Weekly

Establishment MOI on 12/18/2018(See

#PZA3607125818G) and on 11/21/2018 (See

#PZA2505114921G).

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 101

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Code TaskName Status MOI Agenda

90 P912 Wayne Farms, LLC SVF591201

5317G

17JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized Good Commercial Practices MOI: On January 17,

2019 at approximately 1250 hours, I observed a

less than good commercial practice while

performing an Ante-mortem and Good

Commercial Practices (GCP) check at  Wayne

Farms (P-912). While performing the GCP, I

noticed a bird with shallow breathing trapped

beneath several DOAs in the DOA bin near live

receiving.  The bird's head was buried in the pile

of DOAs.  was informed

of this finding.  Upon retrieving the bird from the

pile, the bird was exhibiting open mouthed

breathing.  immediately euthanized and

decapitated the bird in my presence.  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)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 102

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Code TaskName Status MOI Agenda

80 P9197 Perdue Foods, LLC. UAB23060

10718G

18JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At 0615 hrs, I was informed that a cadaver was

hung on line 1 station 1 by FI Ann Hutsell. On

observation, the carcass was red in color and dark

red from the neck to the head with a blood

engorged head still attached and a small 1/4 inch

laceration on the top of the head. No major

vessels were lacerated to allow for proper

bleeding of the carcass. 

was immediately notified and shown the carcass

before it was disposed in the USDA condemn

barrel. At 0630 hrs, I was notified by 

 that she had received a cadaver carcass

and that had already

been notified of the deficiency. I confirmed the

carcass was a cadaver. It was seemingly normal

from the hocks to the apex with a dark red neck

and blood engorged head with no visible cut to

the neck. The carcass was disposed in the USDA

condemn barrel. According to 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. Blood from the killing operation must be

confined to a relatively small area." USDA expects

the establishment to follow FSIS policies for good

commercial practices at all times to ensure no

carcass enters the scalders breathing. Failure to

comply with FSIS regulations and policies will

result in further actions being taken by USDA.

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 103

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Code TaskName Status MOI Agenda

80 P9197 Perdue Foods, LLC. UAB33100

22407G

07FEB2019 04C05 Poultry Good

Commercial

Practices

Open At 0710 hrs, was performing

poultry good commercial practices in the hanging

room for lines 2 and 3. While performing the task,

she observed 3 live birds directly under dead birds

on the DOA belt. A plant associate in the hanging

room was immediately notified and they removed

the birds from the DOA belt. 

 was notified of the issue as well. This issue

was brought up previously in the 1/29/19 USDA

HACCP meeting, specifically regarding the

increase in DOA carcasses being allowed to pile up

on the DOA belt and the increased chances of live

birds being covered by dead birds on the belt.  

USDA expects the establishment to follow FSIS

policies for good commercial practices at all times

to ensure no carcasses die by means other than

slaughter. Failure to comply with FSIS regulations

and policies will result in further actions being

taken by USDA. With regards, 

(b) (6)

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 104

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Task

Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA171801

0704G

04JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 2007 hours while performing

antemortem and Good Commercial Practice (GCP)

verification task I observed a live medium bird,

head raised, breathing, eyes blinking and looking

around enter the scalder.  

 was notified of a bird dying other

than by slaughter. At approximately 2012 hours

I performed GCP verification by observing 200

carcasses enter the scalder and 200 carcasses at

the kill blade.  There were no further observation

of live birds entering the scalder and the back-up

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

by the kill blade. stated that the back up

kill personnel will receive disciplinary action. It is

recommended that establishment management

review the Federal Register on “Treatment of Live

Poultry before Slaughter”, published September

2005 for FSIS recommendations concerning

treatment of live poultry prior to slaughter.  

 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. )-935

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

(b) 

(6) (b) (6) (b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 105

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Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA111901

2622G

22JAN2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1814 hours, I was notified that

the inspector on line station 3 had hung back 2

birds for Veterinarian disposition.  Upon arrival I

observed the 2 birds had heads intact which were

red to purple in color and had not received a cut

to the neck.  There was a small cut to the side of

the heads of the each cadaver.  

 was notified of the

observation of birds dying other than by

slaughter.  The inspector on line tation 4 then

notified me that he had condemned a cadaver as

well.  Upon investigation, this bird had the head

intact which was red to purple in color and had a

small cut to the left side of the neck however,

both carotid arteries had not been cut.  At

approximately 1825 hours I went to perform

Good Commercial Practice verification however

there were no birds on line ue to the lunch

break.  At approximately 1943 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 birds dying other than by slaughter.  

 stated that the responsible establishment

employee would receive disciplinary action and

the back up kill personnel for line will be

monitored for 3 days. 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, ,

(b) (6)

(b) (6)

(b) 

(6) (b) (6) (b) (6) (b) (4) (b) (4) (b) (4) (b) (4)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 106

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Task

Code TaskName Status MOI Agenda

 Allen Harim Foods, LLC. P-935 

Harbeson, DE. 19951

(b) (6)
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80 P935 Allen Harim Foods, LLC. YXA511602

1605G

05FEB2019 04C05 Poultry Good

Commercial

Practices

Open At approximately 1340 hours on February 5, 2019

while performing ante mortem verification I

observed a loose live bird on trailer 6862, in the

4th bay of the cooling shed; a loose live bird on

trailer 5777, in the 1st bay of the cooling shed

and a live bird roosting in an approximate 6 inch

by 6 inch hole in one of the coops directly above

the loose bird on trailer 5777.  In the 3rd bay of

the cooling shed I observed a bird that had been

run over by a trailer and lying partially under the

back tire of the trailer. 

 was notified of a bird dying

other than by slaughter and birds being handled

in a way that could result in their dying other than

by slaughter.  stated that he would

discuss this issue with 

 prior to providing a preventive

measure. It is recommended that establishment

management review the Federal Register on

“Treatment of Live Poultry before Slaughter”,

published September 2005 for FSIS

recommendations concerning treatment of live

poultry prior to slaughter.  was notified

that this MOI will be forwarded to the District

Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is

recommended. Respectfully, 

 Allen Harim Foods, LLC. P935 

Harbeson, DE. 19951

(b) (6)

(b) (6)

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

(b) (6)
Table: MOIs in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 108

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Code TaskName Status MOI Agenda

80 P935 Allen Harim Foods, LLC. YXA552202

3613G

13FEB2019 04C05 Poultry Good

Commercial

Practices

Finalized At approximately 1445 hours while performing

inspection verification, I was informed by

inspector on Line that there was 1 carcass

 hanging on the Veterinary disposition shackles

behind line station 3.  The carcass’s head and

neck were dark red to purple and had not

received a cut to the neck.  

 was notified of the

observation of bird dying other than by slaughter. 

 informed me that he would take the

carcass for the relevant Supervisor to observe and 

investigate the cause. I was later informed by 

 that the Back Up Killer was reprimanded.  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)
Table: Noncompliance Reports in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 1

EstNbr EstName NR# Date Task TaskName Regs Description Status

P4734 New Lee's Live

Poultry Market

Inc.

XKD420

601053

0N-1

01/24/2019 04C05 Poultry Good

Commercial

Practices

On Thursday, 01/24/2019, at approximately

10:40 am, while performing a directed Good

Commercial Practice PHIS task in order to verify

the establishment was following GCP guidelines as

written in 9CFR 381.65(b), I observed the

following: In the live holding /killing floor area,

three young chickens were in a barrel, however,

they were still moving and had not been fully bled

out. Retain tag #B42078601 was placed on the

barrel. 

, was immediately notified of this

non-compliance with 9 CFR 381.65(b) both

verbally and in writing with this NR. 

ordered the workers to place the chickens into the

cones so they would bleed out appropriately. The

retain tag was removed and slaughter proceeded.

CLOSED

P727+V727 Simmons

Prepared

Foods, Inc.

VCF592

102411

2N-1

02/11/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) On 01/28/2019, at approximately 1130 hours

while verifying process control, 

had observed two condemn barrels at the rehang

table and found in excess of 30 cadavers.  

 informed ,

who placed two extra backup killers in the live

hang room to assist.  At approximately 2010

hours, on 01/29/2019, informed 

 that he would continue to keep the

extra backup killers in the live hang area for the

current days production.  At approximately 2048

hours I observed four chickens (responsive, eyes

alert, and no visible cut on the neck) entering the

kill line two scalder.  I observed five chickens in

the same condition entering the parallel kill line

one scalder.  This occurred in an approximate

three-minute time interval for each respective kill

line.  I discussed the situation with 

who went to the live hang area and ensured that

there were two backup killers placed on each kill

line and placed a supervisor to monitor them. 

 was notified of

the forthcoming noncompliance.  The

establishment is noncompliant with 9 CFR

381.65(b).

CLOSED

(b) (6)

(b) (6)

(b) (6)

(b) 

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

(b) 

(6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 2

EstNbr EstName NR# Date Task TaskName Regs Description Status

P325 Tyson Foods,

Inc.

YDM57

050355

28N-1

03/22/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) On 3-22, 2019 at approximately 0800 hours while

performing my GCP task, I observed a bird laying

on the ground underneath the roller bed where it

meets the bird dump.  The bird was obviously

dead due to it being almost completely transected

at the mid-section of its carcass.  The skin and

associated musculature on both sides of the

transected carcass were macerated.  Mascerated

viscera was present and still adhered to the

central celiac cavity.  I immediately contacted

,

and advised him of the forthcoming enforcement

action.  ,

was also contacted and advised of the situation. 

At approximately 0830 hours, t

communicated to me that the Establishment had

discovered an opening in the floor of the roller

bed interface with the dump bin.  This bird may

have escaped from its cage during the dumping

process, then killed by a rolling cage crossing the

surface of the roller bed and dragged through the

previously mentioned opening.     Plant

management is encouraged to investigate,

address, and prevent the root cause of this

occurrence and is expected to employ proper

handling methods consistent with good

commercial practices.  It is important for the

establishment to treat poultry in a manner that

prevents needless injury and suffering in order

that a commercially marketable, unadulterated

product may be produced as described in 9 CFR

381.65.  Establishment response to this

noncompliance, including corrective and

preventative measures, will be attached to this

entry in PHIS. 

OPEN

(b) (6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 3

EstNbr EstName NR# Date Task TaskName Regs Description Status

P206+V206 Pilgrim's Pride

Corporation

KCC062

103461

5N-1

03/15/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) On March 15, 2019 at approximately 2005 hours

while performing a routine PHIS Poultry Good

Commercial Practices task 

observed the following noncompliance. At the

entrance of the stunning equipment there were

two dead birds lying on the ground in a puddle of

blood with both their legs ripped off. I proceeded

to inform a 

 was in the area. I showed him the

dead birds and asked him to call the Live hang

supervisor and management to find out what

happened to these birds. As we were examining

the birds, overhead on the west picking line a live

bird was caught by its neck between the support

bar and belly beam with both legs ripped off and

its intestines hanging out. The bird

instantaneously fell to the ground and 

 immediately euthanized the bird by

performing cervical dislocation. At this time, I then

looked back up at the picking line and a bird was

entering the stunner with both feet and its neck

hung in a shackle loop. 

immediately ran over to stop the line to remove

the bird’s neck from the shackle loop. 

 and .

 came to the area and observed the

birds. At this time, there were no more birds hung

on the line. Failure to implement procedures for

preventing accidental injury and/or death

inconsistent with 9CFR 381.65(b) in regards to

birds presented for slaughter, resulted in a GCP

failure, and birds died by means other than

slaughter. FSIS encourages establishments to

develop and implement a systematic approach to

ensure poultry presented for slaughter are treated

in a manner that minimizes excitement,

discomfort, and accidental injury.  The initial

component of the approach is to assess the areas

where problems may occur.  The second

component asks that establishments determine if

their facilities are designed and maintained to

OPEN

(b) 

(6) (b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 4

EstNbr EstName NR# Date Task TaskName Regs Description Status

prevent excitement, discomfort, and accidental

injury to poultry the entire time that live poultry

are held in connection with slaughter.  Finally,

establishments should periodically evaluate their

handling methods to ensure that their employees

are treating animals in a manner that minimizes

injury, excitement and discomfort prior to

slaughter and that their methods ensure all

poultry are slaughtered in accordance with 9 CFR

381.65 (b). The establishment was notified that

the 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

noncompliance will be distributed to the

establishment, inspection file and District

Veterinary Medical Specialist per FSIS Directive

6100.3. The establishment is also reminded that

NRs and MOIs documented for GCP issues can be

FOIA requested and made available for viewing. 

Documented by 

(b) (6)
Table: Noncompliance Reports in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 5

EstNbr EstName NR# Date Task TaskName Regs Description Status

P218 Pilgrim's Pride

Corporation

WOD06

220225

05N-1

02/05/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) On February 5, 2019 observed

the following GCP noncompliance. At

approximately 1925 hours evisceration line 1 was

stopped due to a maintenance issue on picking

line entered the live hang area

around 1955 hours to verify live birds were being

handled appropriately. In the live hang room, the

employees had already removed all the birds hung

on the line prior to the stunner as well as

humanely euthanized the birds after the stunner

and before the blade. then observed

the birds in the stunner and approximately all 15

birds were dead. 

 was notified and shown the

noncompliance. The dead birds had drowned in

the stunner and were pulled off the line to be

properly disposed of. Failure to implement

procedures for preventing accidental injury and/or

death inconsistent with 9CFR 381.65(b) in regards

to birds presented for slaughter, resulted in a lack

of response to a known GCP failure, and birds

were allowed to die by a means other than

slaughter. The establishment was notified that

the 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

noncompliance will be distributed to the

establishment, inspection file and District

Veterinary Medical Specialist per FSIS Directive

6100.3. The establishment is also reminded that

NRs and MOIs documented for GCP issues can be

FOIA requested and made available for viewing by

FSIS. Documented by 

(b) (6)

CLOSED

(b) (6)

(b) (6)

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

(b) (4)
Table: Noncompliance Reports in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 6

EstNbr EstName NR# Date Task TaskName Regs Description Status

P533 Hain Pure

Protein

Corporation -

FreeBird East

AKB170

201381

4N-1

01/13/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) On January 13th, 2019 at approximately 2345hrs

the following noncompliance was observed. 

 and I went down to the evisceration

department to give breaks, at that time we

observed that between the three inspection

stands 16 birds had been marked as cadavers on

the poultry inspection lot tally sheets. After

speaking to the 

birds were DOA’s (Dead on

Arrival). While I was still down in evisceration I

was presented two birds from one of the

inspectors and was able to determine that one

was a DOA bird and the other was a cadaver. 

 informed 

, of the situation while I was examining

the birds and informed 

. I then went up to live

receiving and saw approximately 20 birds piled on

the DOA table and the floor next to the live hang

belt. Upon further examination I saw that two of

the birds were still alive and informed the plant

employee that had started disposing of the DOA’s

when I entered the area of this; the plant

employee placed the two live birds back on the

live hang belt and disposed of the rest of the

DOA’s. I spoke with 

, and told him about the two live birds

in the DOA pile and the large number of DOA’s

getting hung for processing; he immediately

counseled the employees on the live hang belt

about being vigilant for DOA’s as well as

reminding them to double check that all birds are

actual DOA before disposing of them. I then spent

approximately 10-15 mins observing the blood

tunnel and observed 4 birds that had made it past

the kill wheel and the backup killer without being

properly slaughtered. was standing

with me and removed all the improperly

slaughtered birds before they entered the scalder

and placed them back on the live hang line to be

properly slaughtered.  I informed 

CLOSED

(b) (6) (b) 

(6)

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

(6) (b) (6)

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6)
Table: Noncompliance Reports in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 7

EstNbr EstName NR# Date Task TaskName Regs Description Status

of the noncompliance and the loss of process

control. Three other birds, one a DOA and two

Cadavers, where pulled off the line by an inspector

at approximately 0215, January 14, 2019. At

approximately 0330 while giving breaks I pulled 1

DOA and 2 cadavers off of the line. I informed

Randy Hertzog of this. This is a non-compliance

with regulation 381.65(b).

P44947 Two Brothers

for Wholesale

Chicken, Inc.

TRR471

102051

8N-1

02/15/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) On 02/15/19 at 1:15pm hours approximately, The

 heard a noise on the killing

room after the killing process was finished. When

we verified the area, we found a live chicken in

the boiler room. If we would not find the chicken,

provably it would have died by the cold weather

during the weekend. The Plant manager 

 was informed about this

noncompliance. The chicken was brought to

other establishment of custom sales. The

establishment failed with 9CFR 381.65(b). 

381.65(b): Good commercial practices for poultry

slaughter

CLOSED

(b) (6)

(b) 

(6)
Table: Noncompliance Reports in Response to FOIA2019-259 12:20 Thursday, March 28, 2019 8

EstNbr EstName NR# Date Task TaskName Regs Description Status

P44947 Two Brothers

for Wholesale

Chicken, Inc.

TRR021

502022

6N-1

02/26/2019 04C05 Poultry Good

Commercial

Practices

381.65(b) On 2/26/2019 at 0210 hours approximately, in

response at line speed violation, I made a GCP

task and observed on the killing area one edible

container with young chickens . The chickens still

moving into the container because not had the

properly bleeding process in the metal cones.

Also, I was observed employees that not using the

metal cones and skip that step and throw the

chickens direct into the barrel. I stopped the

operation and inform immediately the Plant

Manager about this noncompliance. US. Retained

Tag #B39598353 was applied on the barrel with

young chickens. The plant failed to comply with

9CFR 381.65(b) Poultry must be slaughtered in a

manner that will result in thorough bleeding of

the carcasses. condemned

the 130 chickens and was present on the denature

process. One previous NR's was associated about

this non compliance.

CLOSED

P45939+V4

5939

Petersburg

Poultry

Processing

CZJ481

102242

8N-1

02/28/2019 04C05 Poultry Good

Commercial

Practices

On February 28, 2019 at Petersburg Poultry

Processing, during slaughter operations around

11:00a.m. the observed a

cadaver chicken come through the picking

machine which demonstrated that the bird was

still breathing upon entering the scalding tank.

This is a violation of 381.65(b) , Plant Manager

Mike Brockman was notified of the condition,

who then instructed an employee to condemn the

bird.

OPEN

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

U.S. Department of Agriculture

Food Safety and Inspection 

Service

1. CASE NUMBER:

2. EST. NUMBER: 3. EST. ID:

4a. ESTABLISHMENT NAME:

4b. ESTABLISHMENT ADDRESS/ P.O. BOX

4c. CITY, STATE, ZIP CODE

5b. NAME OF PHV 5c. NAME OF IIC

6. DATE(S) OF VISIT (MM/DD/YY)

FROM: TO:

7. CIRCUIT VISITED (4-

digit no.)

8. PLANT SIZE

9. SPECIES SLAUGHTERED

11. STUNNING USED:

BXL3213021725CP $/$0('$ '2 *&3

843 Davis St.

5a. NAME OF DVMS

same

2/19/2019 2/20/2019 0508

M6137+P6137 5308

Foster Farms

X Chicken

Other

X Large Small Very Small

District Office Direction

X Routine Visit

Repetitive NonCompliance

Data-Driven Visit

Suspicion of Violations

Special Correlation/Other

12. REASON FOR VISIT



GOOD COMMERCIAL PRACTICES

CORRELATION VISIT REPORT

YES NO

 STUNNING METHOD: Controlled Atmosphere Stunning

X Electric Stunning

Livingston, California 95334

10a. LINE SPEED:

 / Minute

10b. NUMBER OF LINES:

Page 1 of 4 P6137 FOSTER FARMS LIVINGSTON

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

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Page 3 of 4 P6137 FOSTER FARMS LIVINGSTON


13. SYSTEMATIC APPROACH USED?

IF YES, CHECK ITEMS BELOW THAT HAVE BEEN IMPLEMENTED; NUMBERS CORRESPOND TO THE THREE 

STEPS OF THE SYSTEMATIC APPROACH

X Yes No IMPLEMENTATION NOT ASSESSED PER THIS DATE

X 1. Assessing under what circumstances poultry may experience excitement, discomfort, or 

accidental injury while being handled in connection with slaughter. 

X 2. Taking steps to minimize the possibility of such excitement, 

discomfort, and accidental injury.

X 3. Evaluating periodically how poultry are being handled and slaughtered to ensure 

 (a) that excitement, discomfort, or accidental injury is being minimized;

 (b) that poultry are slaughtered in a manner that results in thorough bleeding 

 of the poultry carcass; and 

 (c) that breathing has stopped before scalding. 

14. RECOMMENDATIONS

X No Action

NR by IIC

NOIE

Suspension/Withdrawal

Other

Letter of Concern

15. FINDINGS / Narrative Report:

Correlated With:

Summary of Data Assessment Prior to Visit:

USDA/FSIS: 

Establishment:

Correlation with IPP was conducted separately and included pre-assessment findings, 

as well as a review of 9 CFR 381.65(b).

(b) (6)

(b) (6)
Systematic Approach Comments:

Summary of Reason(s) for Recommendation:

Findings Narrative Report:

Information was reviewed from 9/1/2018 to 3/1/2019. This 

is a small poultry slaughter and processing establishment 

that operates one (1) shift five (5) days per week. No 

issues or concerns by the IPP or a third party. There have 

been no Good Commercial Practices (GCP) 

Noncompliance Reports (NRs) and/or Memoranda of 

Interviews (MOIs) documented during the reviewed time 

frame.

Systematic Approach Observed

No Action. The establishment¶s live poultry handling met 

the requirements of the Poultry Products Inspection Act; 9 

CFR 381.65(b) and other related regulations and 

directives.
 accompanied me during the walk-thru of the area where 

live young chickens are received, housed, and moved. The live bird 

receiving/staging area is covered, and fans and misters are available 

for use during warm weather months. The birds were evenly 

distributed in the coops and appeared comfortable. I observed three 

coops sedately moved by the forklift driver from the staging area to 

the coop dump conveyor.

I observed facilities structures, equipment, and live-bird handling 

procedures/techniques. All facilities and equipment being used 

appear to be in good working order to prevent injury of live birds 

prior to them being stunned. I observed the dumping of four coops 

with the establishment employee handling trapped birds 

appropriately. I observed that all employees who handled live birds 

used appropriate handling techniques to minimize excitement and/or 

injury to the birds. There were no live birds loose in the staging or 

live hang areas.

During my observation, I found that all birds were properly stunned, 

appropriately cut, and appeared to have been properly bled out by 

the time they reached the scald tank. I observed that no birds were 

breathing when they entered the scalder.

EXIT MEETING:

During the meeting, I discussed my observations and findings. I 

concluded that the handling and slaughter of live young chickens is 

being performed with minimal stress, discomfort and injury, and 

results in thorough bleeding of the carcasses. The establishment 

complied with 9 CFR 381.65(b) and performed live bird handling and 

slaughter in accordance with the GCP.

I reiterated that my recommendation for the day¶s visit would be 3No 

Action Taken ́

When no other questions or concerns were raised, the meeting was 

adjourned.

Respectfully,

District Veterinary Medical Specialist

Denver District Office

Findings:

The establishment¶s live poultry handling met the requirements of the Poultry 

Products Inspection Act; 9 CFR 381.65(b) and other related regulations and 

directives.

FSIS FORM 6000-32 

(08/27/2007)

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





From:

To:

Cc:

Subject: Fw: GCP MOI at P-146

Date: Monday, January 21, 2019 12:38:53 PM

Attachments: MOI Report.pdf revise 21jan19.pdf

This MOI was revise because corrected name change.

From:

Sent: Friday, January 18, 2019 11:26 AM

To:

Cc:

Subject: GCP MOI at P-146

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
From:

To:

Cc:

Subject: GCP MOI

Date: Thursday, January 24, 2019 6:11:10 PM

Attachments: GCP MOI dated 12-28-18 and Establishment Response.pdf

Attached is an MOI written on 12/28/18, the establishment's response and supporting

documents.

(b) (6) (b) (6) (b) (6)
From:

To:

Cc:

Subject: GCP MOI

Date: Friday, January 4, 2019 10:06:37 PM

Attachments: GCP MOI 12-6-18 and Establishment Response.pdf

Attached is a GCP MOI and the establishment's response

(b) (6) (b) (6) (b) (6)
From:

To:

Cc:

Subject: GCP

Date: Friday, January 25, 2019 5:48:31 PM

Attachments: GCP MOI 1-22-19 and Establishment Response.pdf

Attached is the GCP MOI dated 1/22/19 and the establishment's response.

(b) (6) (b) (6) (b) (6)
From:

To:

Cc:

Subject: GCP

Date: Tuesday, March 5, 2019 6:31:28 AM

Attachments: Live bird 3-4-19.docx

On 3/4/19 I observed a live bird entering the scalder at P-510. I have attached a copy of the

MOI (RHB4413033204G) that was written. 

Raleigh District

USDA/FSIS/OFO

House of Raeford- P510

3333 US Highway 117 South

Rose Hill, NC 28458

(910) 289-6967

@usda.gov

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

Office of Field Operations

Food Safety and Inspection Service, USDA

c/o House of Raeford, P-737

253 Butterball Road

Teachey, NC 28464

(910) 463-7082

@usda.gov

(b) (6)

(b) (6)

On Thursday, January 24, 2019, three truck loads of lay one breeder hens, flock “PT”, were scheduled to be run as the last birds of the day (day 

shift hours are 0946-1816). Each truck contained 1040 hens. The trucks arrived at 1053, 1141, and 1242, respectively. I observed them at 

approximately 1400 and did not note any abnormalities. According to establishment paperwork provided, the hens went off feed on January 

23, although they were still looking into what time. Due to mechanical issues with the chiller, the establishment was unable to run the hens 

that day (January 24) and elected to carry them over to the following day (January 25). Normally, when birds are carried over, they are run first 

thing on night shift (night shift hours are 0116-0946); however, night shift does not run breeder hens, so the establishment decided they would 

be run first on day shift on January 25 (see email from communicating this to me). While making 

GCP observations at 1420 on January 25, I observed that these three truck loads of hens were still on the yard and had not been run yet. I also 

observed an increased number of DOAs from the previous day and numerous hens with large, exposed wounds that the hens surrounding them 

were pecking into. Fresh blood was visible on the beaks of these birds and splashed onto surrounding feathers. In two cases, the hens had 

managed to peck open a wound and pull out intestines and were pecking at the intestines splayed out in the cage of two separate hens. The 

birds were seen aggresively pecking at each other and at the feces/eggs in the cages. At this point, the hens had been off feed for 

approximately two days and on the yard for 26-28 hours, and had not had access to feed or water during that time. According to Butterball’s 

“Animal Care and Well-Being Program”, “Time in holding area will not exceed 24 hours from time of on farm feed withdrawal. Any deviation 

from this maximum should be documented.” I immediately proceeded inside and found . I expressed 

my concerns with the birds being held at the establishment for a greater length of time than normal and that it was communicated to be 

yesterday that these birds would be run first and still had not been run. He said there had been some miscommunication due to changes in 

management/staffing and that the decision was made to run the hens last on dayshift, with the new breeders that had come in today. I 

expressed my concerns to him that the birds were being held without access to food or water. The birds did not end up being run until starting 

at 1715, or 31 hours from their arrival at the establishment. A similar situation occurred in October 2016 following Hurricane Matthew where 

birds were off feed/water for 60 hours before being killed. It was documented at the time in a meeting MOI on October 27, 2016 that our

recommendation was to look at different options if a similar situation arose and the establishment said that they would take each on a case-bycase basis. 

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



Food Safety and 

Inspection 

Service

1400 

Independence 

Avenue, SW. 

Washington, 

D.C. 20250

From:

Date: 1/28/2019

Subject: Poultry Good Commercial Practices / AGA1010013828I

Meeting Date: 1/28/2019

Meeting Time: 11:00 AM

Establishment: M7345+P7345 - Butterball, LLC

Reason Code:

Other Reason 

Code:

GCP

Comments:

On Thursday, January 24, 2019, three truck loads of lay one breeder hens, flock ͞PT͕͟ were 

scheduled to be run as the last birds of the day (day shift hours are 0946-1816). Each truck 

contained 1040 hens. The trucks arrived at 1053, 1141, and 1242, respectively. I observed 

them at approximately 1400 and did not note any abnormalities. According to establishment 

paperwork provided, the hens went off feed on January 23, although they were still looking 

into what time. Due to mechanical issues with the chiller, the establishment was unable to 

run the hens that day (January 24) and elected to carry them over to the following day 

(January 25). Normally, when birds are carried over, they are run first thing on night shift 

(night shift hours are 0116-0946); however, night shift does not run breeder hens, so the 

establishment decided they would be run first on day shift on January 25 (see email from 

Billy Davis, first processing superintendent, communicating this to me). While making GCP 

observations at 1420 on January 25, I observed that these three truck loads of hens were still 

on the yard and had not been run yet. I also observed an increased number of DOAs from 

the previous day and numerous hens with large, exposed wounds that the hens surrounding 

them were pecking into. Fresh blood was visible on the beaks of these birds and splashed 

onto surrounding feathers. In two cases, the hens had managed to peck open a wound and 

pull out intestines and were pecking at the intestines splayed out in the cage of two separate 

hens. The birds were seen aggresively pecking at each other and at the feces/eggs in the 

cages. At this point, the hens had been off feed for approximately two days and on the yard 

for 26-28 hours, and had not had access to feed or water during that time. According to 

Butterball͛s ͞Animal Care and Well-Being Program͕͟ ͞Time in holding area will not exceed 24 

hours from time of on farm feed withdrawal. Any deviation from this maximum should be 

documented.͟ I immediately proceeded inside and found 

. I expressed my concerns with the birds being held at the establishment for a 

greater length of time than normal and that it was communicated to me yesterday that these 

birds would be run first on day shift and still had not been run. He said there had been some 

miscommunication due to changes in management/staffing and that the decision was made 

to run the hens last on dayshift, with the new breeders that had come in today, based on 

ease of product flow through the establishment. I expressed my concerns to him that the 

birds were being held without access to food or water and bird welfare needed to be taken 

into consideration. The birds did not end up being run until starting at 1715, or 31 hours 

from their arrival at the establishment. According to paperwork submitted on January 28, 

there were 38 DOAs (1.2%). The ͞Animal Care and Well-Being Program͟ states that DOAs 

should not exceed 1% and if they do, cause will be determined, actions reviewed, and new 

procedures put in place. A similar situation occurred in October 2016 following Hurricane 

Matthew where birds were off feed/water for 60 hours before being killed. It was 

documented at the time in a meeting MOI on October 27, 2016 that our recommendation 

was to look at different options if a similar situation arose and the establishment said that 

they would take each on a case-by-case basis.

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








From:

To:

Cc:

Subject: GCP MOI at P-146

Date: Friday, January 18, 2019 12:26:45 PM

Attachments: MOI Report.pdf

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



From:

To:

Cc:

Subject: GCP MOI establishment response

Date: Monday, February 11, 2019 11:39:38 AM

Attachments: GCP MOI 1.28.19.pdf

GCP MOI 1.28.19 establishment response.pdf

HiAttached is the GCP MOI I wrote a few weeks back and the establishment's response, which I

received today. They are saying they did not verify the actual delivery time, which I think is a

very poor excuse. Breeders are generally delivered later in the day then super toms due to

traveling from a farther distance, but their arrival time of between 1053-1242 that day is very

typical and not different from when they normally arrive. So there is really no reason for them

to have even needed to verify a delivery time. Even if they had arrived later in the day, they

were not run until starting at 1715 the following day, so it would have been very unlikely they

could have run them within their supposed 24-hour period. The shift ends at 1816 and it

would be very rare for birds to arrive close to the end of the shift. Also, they did not address

that I was originally told (per email) that the birds would be run first on night shift and then

their minds were changed due to plant needs and "product flow." They are saying it is their

priority to operate all carry-overs within a 24-hour period but their "Animal Care and WellBeing Program" says that time in holding area will not exceed 24 hours from time of on farm

feed withdrawal. By not running them on night shift, there is no way they could comply with

that. This is the main issue at hand- they will not run breeders on night shift so if they have to

carry them over, there is no way they could run them within that 24-hour period. That was

not at all addressed in their response. I plan on verbally presenting these concerns in the

weekly meeting this week and documenting them in the weekly meeting MOI. I wanted to see

if you would like me to pursue this any further or close it out once I present my concerns at

the meeting this week. Thanks.

Supervisory Public Health Veterinarian

OFO

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 

Fax Number: 919-658-5575

Email: @usda.gov

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
From:

To:

Cc: Williams, Phillip - FSIS

Subject: GCP MOI for 5 birds almost entering the scalder

Date: Thursday, March 28, 2019 9:30:26 AM

Attachments: MOI DVMS GCP Live Bird Entering Scalder.pdf

Good morning ,

Please see the attached MOI that I have issued to House of Raeford Farms Inc., P510, Rose Hill.

During my GCP task today, I identified 5 live birds almost entering the scalder. Three of the birds

were uncut and 2 birds were improperly cut and still alive. The plant has been in the process of

training a new back up killer and they attribute it to the trainer not paying attention. A similar

incident was documented by on 3/4/2019 for a single bird without a cut on the

neck. The preventive given by the supervisor on 3/4/19 was to have the back up killer pay more

attention, which is very similar to the response I received today.

Thank you,

Relief Supervisory Public Health Veterinarian

Office of Field Operations

Food Safety Inspection Service/USDA

Tyson Foods, Inc. P-622

2023 Hasty St.

Monroe, NC 28110

704-296-1933

704-282-4400 (Fax)

@usda.gov

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
From:

To:

Cc:

Subject: GCP MOI P-146

Date: Thursday, January 17, 2019 6:07:24 PM

Attachments: Scan0012.pdf

Good evening,

Please find attached a mistreatment of poultry MOI at Glen Allen, Va.

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


From: Roling, Mark - FSIS

To:

Subject: GCP question

Date: Wednesday, February 13, 2019 4:38:10 PM

Can one of you call me on a question please

Mark Roling

Deputy District Manager

Raleigh District

Office of Field Operations, FSIS, USDA

6020 Six Forks Road

Raleigh, NC. 27609

Phone: 919-208-2935

mark.roling@usda.gov

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

Ms. Nicole Reynolds, Plant Manager, P-510

House of Raeford

Rose Hill, NC 28458

Ms. Reynolds

At approximately 1352 while performing the Good Commercial Practices Verification task, I observed a 

live bird about to enter the scalder. The bird at the time of my observation had normal rhythmic 

breathing, eyes open and blinking with the head elevated. I immediately pointed out the bird to 

, who stopped the line before the bird could enter the scalder and

removed the bird from the line. After removing the bird from the line, it was observed that there was 

no cut on the neck which would not have allowed the bird to bleed out properly. took the 

bird back to live hang to show it to placed the bird 

back onto the kill line to allow it to go back through the stunner and the kill blade to allow proper 

bleeding. , instructed the backup cutter to pay more 

attention to the smaller birds going through. I discussed my finding with and 

and notified them of the pending MOI and the establishment’s failure to comply with 9 CFR 381.65 (b) 

which states: Poultry must be slaughtered in accordance with good commercial practices in a manner 

that will result in thorough bleeding of the carcasses and ensure that breathing has stopped prior to 

scalding. , was also notified my findings. 

 

Ms. Reynolds this MOI will be forwarded to the District Veterinary Medical Specialist (DVMS) in case 

additional follow-up is recommended. 

If you have any questions or concerns regarding the above, please contact or 

Respectfully, 

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

(6)

(b) (6)(b) 

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



Food Safety and 

Inspection 

Service

1400 

Independence 

Avenue, SW. 

Washington, 

D.C. 20250

From:

Date: 1/24/2019

Subject: Poultry Good Commercial Practices

Meeting Date: 1/24/2019

Meeting Time: 5:49 PM

Establishment: M56+P56 - PILGRIMS PRIDE CORPORATION

Reason Code:

Other Reason 

Code:

Comments:

On 01/24/2018 at approximately 5:49 pm, while performing the Poultry Good 

Commercial Practices Task. I was observing the birds go into the scalder when I 

noticed a live bird go into the scalder. The bird had its head raised up, eyes open and 

very alert. I immediately alerted the , of my 

observation. At approximately 7 minutes after bird entered scalder, 

removed said bird from the line. 

My above findings are noncompliant with 9 CFR 381.65(b): "Poultry must be 

slaughtered in accordance with good commercial practices in a manner that will result 

in thorough bleeding of the carcasses and ensure that breathing has stopped prior to 

scalding. Any deviation from Good Commercial Practices is unacceptable. Since this 

is an isolated incident, it will not be registered as a noncompliance record because 

the establishment¶s process appears to be in control, and no further birds were 

observed entering the scalder.This MOI serves as a written notice that future 

deviations may result in the taking of additional administrative actions. 

-8 at Est. P-56

cc:

(b) (6)

(b) (6)

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

Inspection 

Service

1400 

Independence 

Avenue, SW. 

Washington, 

D.C. 20250

From:

Date: 3/28/2019

Subject: Poultry Good Commercial Practices / RHB1605034728I

Meeting Date: 3/28/2019

Meeting Time: 7:31 AM

Establishment: P510 - House Of Raeford Farms

Reason Code:

Other Reason 

Code:

Comments:

Ms. Nicole Reynolds, Plant Manager

Establishment P510

House of Raeford Farm, Inc.

Rose Hill, NC 28458

Ms. Reynolds, 

On 03/28/2019, at approximately 0721 hours, while performing a Good Commercial 

Practices task in the Live Hang Room, I noted 5 live birds in the span of 1-2 minutes 

about to enter the scalder. At the time of my observations, each bird had normal 

rhythmic breathing, eyes open and blinking with the head elevated. A team member 

was in the area who stopped the line and removed each bird from the line before they 

could enter the scalder. On further observation of each bird, 3 did not have a cut on 

the neck to allow the birds to bleed out properly. The remaining birds had incomplete 

cuts on the neck which did not allow the birds to bleed out completely before entering 

the scalder. Each bird was placed back on the line to go through the proper slaughter 

process. 

 was made aware of my findings and was notified that a GCP MOI would 

be written and sent to the DVMS as a result. He reported that a new back up killer is 

currently being trained. stated that the trainer was not paying attention 

and had stepped away from the platform. Following this incident, the trainer was 

instructed to pay more attention and to stay at the platform while the new team 

member is being trained. Following this conversation, I repeated my Good 

Commercial Practices task and verified that the trainer was present on the platform in 

a location closest to the automatic kill blade. 

A previous memorandum was written on 03/04/2019 for similar findings. In this 

memorandum (MOI# RHB1412035404I), a live bird was found at the scalder entrance 

without a cut on the neck. The incident was attributed to the back-up cutter not 

paying attention and the preventive measure cited was to instruct the back-up cutter 

to pay more attention to the smaller birds as they pass the kill blade. 

The plant¶s preventative measures must be proactive and effective to ensure that 

birds entering the establishment do not die from causes other than slaughter. PPIA 

and Agency regulations require that live poultry be handled in a manner that is 

consistent with good commercial practices (GCP), and that they do not die from 

causes other than slaughter. It is the establishment¶s responsibility to ensure that 

birds are slaughtered in accordance with 9 CFR 381.65(b). A copy of this MOI will be 

forwarded to the District Veterinary Medical Specialist (DVMS) in the event that an 

additional follow-up is recommended.

(b) (6) (b) (6) (b) (6)
If you have any questions or concerns regarding this MOI, please feel free to contact 

myself or .

Respectfully,

 

Relief SPHV-Tyson Foods, Inc., Monroe

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

Food Safety and 

Inspection 

Service

1400 

Independence 

Avenue, SW. 

Washington, 

D.C. 20250

From:

Date: 3/26/2019

Subject: Poultry Good Commercial Practices / CUA3720032026I

Meeting Date: 3/26/2019

Meeting Time: 7:00 PM

Establishment: P764 - Perdue Foods, LLC

Reason Code:

Other Reason 

Code:

Comments:

At 1857 hours while performing the Poultry Good Commercial Practices task in the kill 

room, I observed on kill line number two several birds with neck cut have intense 

body and wings motion entering the scalder. This might indicate that the bleeding 

equipment was not properly adjusted, and the neck cuts were inadequate to achieve 

thorough bleeding of the birds. Also, I was able to remove a live bird with no neck cut 

from the line before it enters the scalder. 

Immediately, I notified the poultry welfare officer and the Night Shift 

1st Processing shift leader of the incident, he inspected kill line number two and 

evaluated the bleeding equipment. Then he indicated that the kill machine was not 

properly set up and that adjustments had to be made to it to get it to perform at 

acceptable levels. I reminded that live poultry must be treated in a manner 

consistent with Good Commercial Practices. I notified him that this Memorandum of 

Interview would be forwarded to the District Veterinary Medical Specialist (DVMS). 

(b) (6) (b) (6) (b) (6)
From:

To:

Cc:

Subject: MOI

Date: Tuesday, March 26, 2019 10:13:51 PM

Attachments: MOI Report.pdf

Hello ,

I trust all is well with you; I have enclosed a copy of a Good Commercial Practices MOI for your

review.

Thanks,

Office of Field Operations

Food Safety and Inspection Service, USDA

Perdue Foods LLC, P-764

521 Willow Street

Salisbury, MD 21801

Phone: 

@usda.gov

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

(b) (6)

(b) (6) (b) (6)
From:

To:

Cc:

Subject: P-146 GCP MOI update

Date: Friday, January 18, 2019 1:00:45 PM

Attachments: Scan0013.pdf

Good afternoon,

I have updated the MOI, the establishment pointed out a factual error on their GCP check.

Their welfare check actually found no loose birds on the yard and in the DOA bin the day the

bird was run over.

Thank you,

(b) (6) (b) (6) (b) (6) (b) (6)
From:

To:

Cc:

Subject: Please find attached GCP MOI for your review.

Date: Thursday, February 14, 2019 3:48:26 PM

Attachments: Scan 0022.pdf

(b) (6) (b) (6) (b) (6)
From:

To:

Subject: Question

Date: Tuesday, February 26, 2019 9:34:36 AM

If we go do a GCP and the plant is in front of us and takes off birds only when we are doing our

check, should we write MOI stating like you did on the one from your visit? We had been told

previously that if they remove the birds that we don’t write one.

Thanks!

Supervisory Public Health Veterinarian

Office of Field Operations

Food Safety and Inspection Service, USDA

c/o House of Raeford, P-737

253 Butterball Road

Teachey, NC 28464

@usda.gov

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
From:

To:

Cc:

Subject: Re: GCP concern

Date: Monday, January 28, 2019 9:56:50 AM

They told me that night shift "cannot handle" running the breeder hens (they generally only

run super toms on night shift) and based on product flow in the plant it made more sense to

run them last thing on day shift grouped with the other breeder hens that had come in that

day.

OFO

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 

Fax Number: 919-658-5575

Email: @usda.gov

From:

Sent: Monday, January 28, 2019 9:33:16 AM

To:

Cc:

Subject: RE: GCP concern

Good morning 

I agree that a GCP MOI is the best way to document this issue. Did the plant give any

reason/justification as to why they decided to go against their own program by not running the birds

first?

District Veterinary Medical Specialist

919.208.2946 office

844.839.6360 fax

@usda.gov

From: - FSIS 

Sent: Sunday, January 27, 2019 7:06 PM

(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)
To:

Cc:

Subject: FW: GCP concern

Hello DVMS’s,

Please review attached document from /P-7345 Butterball LLC. I believe we can

move forward with a GCP MOI on this. According to the facts described on the information

described by . Your feedback/correlation will be appreciated.

Wilson Circuit

Raleigh District Office

Food Safety and Inspection Service- OFO

Office : 919-208-2952

From:

Sent: Friday, January 25, 2019 5:58 PM

To: - FSIS < @fsis.usda.gov>

Subject: GCP concern

For your review.

OFO

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 x

Fax Number: 919-658-5575

Email: @usda.gov

(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)
From:

To:

Cc:

Subject: RE: GCP concern

Date: Monday, January 28, 2019 10:00:28 AM

Still they failed to consider GCP/Poultry Welfare practices in order to accommodate a better

product flow resulting on the observations /facts that you described. That is my concern and

something they will need to consider in the future. This support a GCP MOI.

Wilson Circuit

Raleigh District Office

Food Safety and Inspection Service- OFO

Office : 919-208-2952

@fsis.usda.gov

From:

Sent: Monday, January 28, 2019 9:57 AM

To:

Cc:

Subject: Re: GCP concern

They told me that night shift "cannot handle" running the breeder hens (they generally only

run super toms on night shift) and based on product flow in the plant it made more sense to

run them last thing on day shift grouped with the other breeder hens that had come in that day.

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 x

Fax Number: 919-658-5575

Email: @usda.gov

(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)
From:

Sent: Monday, January 28, 2019 9:33:16 AM

To:

Cc:

Subject: RE: GCP concern

Good morning 

I agree that a GCP MOI is the best way to document this issue. Did the plant give any

reason/justification as to why they decided to go against their own program by not running the birds

first?

District Veterinary Medical Specialist

919.208.2946 office

844.839.6360 fax

@usda.gov

From:

Sent: Sunday, January 27, 2019 7:06 PM

To:

Cc:

Subject: FW: GCP concern

Hello 

Please review attached document from /P-7345 Butterball LLC. I believe we can

move forward with a GCP MOI on this. According to the facts described on the information

described by . Your feedback/correlation will be appreciated.

Wilson Circuit

Raleigh District Office

(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)
Food Safety and Inspection Service- OFO

Office : 919-208-2952

From:

Sent: Friday, January 25, 2019 5:58 PM

To: - FSIS < @fsis.usda.gov>

Subject: GCP concern

For your review.

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 

Fax Number: 919-658-5575

Email: 

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

(6)

(b) (6) (b) (6) (b) (6) (b) (6)(b) (6) (b) (6)
From:

To:

Cc:

Subject: RE: GCP concern

Date: Monday, January 28, 2019 10:47:29 AM

Yes. Go ahead.

Wilson Circuit

Raleigh District Office

Food Safety and Inspection Service- OFO

Office : 919-208-2952

From:

Sent: Monday, January 28, 2019 10:40 AM

To:

Subject: Re: GCP concern

I agree. Should I go ahead and submit the GCP MOI?

OFO

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 

Fax Number: 919-658-5575

Email: 

(b) (6)

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

(b) (6)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
From:

Sent: Monday, January 28, 2019 10:00:25 AM

To:

Cc:

Subject: RE: GCP concern

Still they failed to consider GCP/Poultry Welfare practices in order to accommodate a better

product flow resulting on the observations /facts that you described. That is my concern and

something they will need to consider in the future. This support a GCP MOI.

Wilson Circuit

Raleigh District Office

Food Safety and Inspection Service- OFO

Office : 919-208-2952

Mobile: 

@fsis.usda.gov

From:

Sent: Monday, January 28, 2019 9:57 AM

To:

Cc:

Subject: Re: GCP concern

They told me that night shift "cannot handle" running the breeder hens (they generally only

run super toms on night shift) and based on product flow in the plant it made more sense to

run them last thing on day shift grouped with the other breeder hens that had come in that day.

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 

(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)
Fax Number: 919-658-5575

Email: @usda.gov

From:

Sent: Monday, January 28, 2019 9:33:16 AM

To:

Cc:

Subject: RE: GCP concern

Good morning 

I agree that a GCP MOI is the best way to document this issue. Did the plant give any

reason/justification as to why they decided to go against their own program by not running the birds

first?

District Veterinary Medical Specialist

919.208.2946 office

844.839.6360 fax

@usda.gov

From:

Sent: Sunday, January 27, 2019 7:06 PM

To:

Cc:

Subject: FW: GCP concern

Hello DVMS’s,

Please review attached document from /P-7345 Butterball LLC. I believe we can

move forward with a GCP MOI on this. According to the facts described on the information

described by . Your feedback/correlation will be appreciated.

(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)
Front Line Supervisor

Wilson Circuit

Raleigh District Office

Food Safety and Inspection Service- OFO

Office : 919-208-2952

Mobile: 

@fsis.usda.gov

From:

Sent: Friday, January 25, 2019 5:58 PM

To:

Subject: GCP concern

For your review.

OFO

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743

Fax Number: 919-658-5575

Email: @usda.gov

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
From:

To:

Cc:

Subject: Re: GCP concern

Date: Monday, January 28, 2019 11:32:33 AM

Attachments: GCP MOI 1.28.19.pdf

GCP concern email.pdf

Please see attached GCP MOI. A copy was provided to the establishment.

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743

Fax Number: 919-658-5575

Email: @usda.gov

From:

Sent: Monday, January 28, 2019 10:47:27 AM

To:

Cc:

Subject: RE: GCP concern

Yes. Go ahead.

Wilson Circuit

Raleigh District Office

Food Safety and Inspection Service- OFO

Office : 919-208-2952

Mobile: 

@fsis.usda.gov

From:

Sent: Monday, January 28, 2019 10:40 AM

To:

Subject: Re: GCP concern

(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)
I agree. Should I go ahead and submit the GCP MOI?

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743

Fax Number: 919-658-5575

Email: @usda.gov

From:

Sent: Monday, January 28, 2019 10:00:25 AM

To:

Cc:

Subject: RE: GCP concern

Still they failed to consider GCP/Poultry Welfare practices in order to accommodate a better

product flow resulting on the observations /facts that you described. That is my concern and

something they will need to consider in the future. This support a GCP MOI.

Wilson Circuit

Raleigh District Office

Food Safety and Inspection Service- OFO

Office : 919-208-2952

@fsis.usda.gov

From:

Sent: Monday, January 28, 2019 9:57 AM

To:

Cc:

Subject: Re: GCP concern

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They told me that night shift "cannot handle" running the breeder hens (they generally only

run super toms on night shift) and based on product flow in the plant it made more sense to

run them last thing on day shift grouped with the other breeder hens that had come in that

day.

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 x

Fax Number: 919-658-5575

Email: @usda.gov

From:

Sent: Monday, January 28, 2019 9:33:16 AM

To:

Cc:

Subject: RE: GCP concern

Good morning 

I agree that a GCP MOI is the best way to document this issue. Did the plant give any

reason/justification as to why they decided to go against their own program by not running

the birds first?

District Veterinary Medical Specialist

919.208.2946 office

844.839.6360 fax

@usda.gov

From:

Sent: Sunday, January 27, 2019 7:06 PM

To:

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Cc:

Subject: FW: GCP concern

Hello 

Please review attached document from /P-7345 Butterball LLC. I believe

we can move forward with a GCP MOI on this. According to the facts described on the

information described by . Your feedback/correlation will be appreciated.

Wilson Circuit

Raleigh District Office

Food Safety and Inspection Service- OFO

Office : 919-208-2952

@fsis.usda.gov

From:

Sent: Friday, January 25, 2019 5:58 PM

To: - FSIS @fsis.usda.gov>

Subject: GCP concern

For your review.

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 x2310

Fax Number: 919-658-5575

Email: @usda.gov

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For your review.

FSIS, USDA

Mt. Olive, NC P7345

Phone Number: 919-658-6743 

Fax Number: 919-658-5575

Email: @usda.gov

(b) (6)

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From:

To:

Cc:

Subject: RE: GCP MOI for 5 birds almost entering the scalder

Date: Thursday, March 28, 2019 9:38:27 AM

Thank you. The MOI looks good.

Unfortunately there’s not much we can do about their response. We don’t have the authority to

take regulatory action at this point, so they can give us any response that they want. But you are

correct in that it’s the same response given before, so we could discuss with them our concerns

about the ineffective nature of their previous response and question why they think a similar

response would yield different results this time.

District Veterinary Medical Specialist

Raleigh District Office

Office of Field Operations

USDA FSIS

6020 Six Forks Rd.

Raleigh, NC 27609

Office: 919-208-2936

Fax: 844-839-6359

Email: 

From:

Sent: Thursday, March 28, 2019 9:30 AM

To: ; - FSIS

< @fsis.usda.gov>

Cc: Williams, Phillip - FSIS <Phillip.Williams1@fsis.usda.gov>

Subject: GCP MOI for 5 birds almost entering the scalder

Good morning ,

Please see the attached MOI that I have issued to House of Raeford Farms Inc., P510, Rose Hill.

During my GCP task today, I identified 5 live birds almost entering the scalder. Three of the birds

were uncut and 2 birds were improperly cut and still alive. The plant has been in the process of

training a new back up killer and they attribute it to the trainer not paying attention. A similar

incident was documented by on 3/4/2019 for a single bird without a cut on the

neck. The preventive given by the supervisor on 3/4/19 was to have the back up killer pay more

attention, which is very similar to the response I received today.

Thank you,

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Relief Supervisory Public Health Veterinarian

Office of Field Operations

Food Safety Inspection Service/USDA

Tyson Foods, Inc. P-622

2023 Hasty St.

Monroe, NC 28110

704-296-1933

704-282-4400 (Fax)

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@usda.gov

From:

To:

Subject: Re: GCP question

Date: Wednesday, February 13, 2019 8:54:33 PM

Wow. I don’t remember seeing that email at all. Who sent it to us?

From: "Auxier, Travis - FSIS" < >

Date: Wednesday, February 13, 2019 at 5:11:20 PM

To: " - FSIS" >

Subject: FW: GCP question

I called Mark about this. It was about a GCP MOI written at P146, Tyson (Glenn Allen) from 01/17.

The SPHV took a regulatory control action after observing one bird being run over by the forklift/jack

driver. There is no mention of what the RCA was specifically, other than telling the jack driver to

stop operating the jack and go get a supervisor. She did say that she released regulatory control

after approx. 9 minutes, so a pretty substantial amount of time for the process to be stopped (I know

they have two picking lines, but I don’t know how many cage dumps they have).

District Veterinary Medical Specialist

Raleigh District Office

Office of Field Operations

USDA FSIS

6020 Six Forks Rd.

Raleigh, NC 27609

Office: 919-208-2936

Fax: 844-839-6359

Email: @usda.gov

From: Roling, Mark - FSIS 

Sent: Wednesday, February 13, 2019 4:38 PM

To - FSIS @fsis.usda.gov>; - FSIS

@fsis.usda.gov>

Subject: GCP question

Can one of you call me on a question please

Mark Roling

Deputy District Manager

Raleigh District

Office of Field Operations, FSIS, USDA

6020 Six Forks Road

Raleigh, NC. 27609

Phone: 919-208-2935

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mark.roling@usda.gov

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253 Butterball Road

Teachey, NC 28464

(910) 463-7082

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@usda.gov
From:

To: Simon, Theodora - FSIS; - FSIS; Banks, Catherine - FSIS

Cc: - FSIS

Subject: RE: Please find attached GCP MOI for your review.

Date: Friday, February 15, 2019 10:34:31 AM

No comments.

Raleigh District Office

Office of Field Operations

USDA FSIS

6020 Six Forks Rd.

Raleigh, NC 27609

Office: 919-208-2936

Fax: 844-839-6359

Email: 

From: Simon, Theodora - FSIS 

Sent: Thursday, February 14, 2019 3:48 PM

To: - FSIS @fsis.usda.gov>; - FSIS

@fsis.usda.gov>; Banks, Catherine - FSIS <Catherine.Banks@fsis.usda.gov>

Cc: Simon, Theodora - FSIS <Theodora.Simon@fsis.usda.gov>

Subject: Please find attached GCP MOI for your review.

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From:

To:

Subject: RE: Question

Date: Wednesday, February 27, 2019 9:03:50 AM

Thanks!

Office of Field Operations

Food Safety and Inspection Service, USDA

c/o House of Raeford, P-737

253 Butterball Road

Teachey, NC 28464

(910) 463-7082

@usda.gov

From:

Sent: Wednesday, February 27, 2019 7:48 AM

To: Hodge, Stanley - FSIS < @fsis.usda.gov>

Cc:

Subject: RE: Question

It’s a tricky situation, I think.

They have no back-up person normally stationed just prior to the entrance of the scalder, so if

anyone is there, then that is a circumstance that it out of the ordinary.  That being the case, I think

an MOI would be warranted because they wouldn’t have been there under normal circumstances

and the bird would have entered the scalder while still breathing.  Even if they are performing their

own daily/weekly/monthly audit of the system, they don’t have anyone stationed there normally so

any bird you identify as “live” would have entered the scalder while still breathing.  It’s no different

than what we saw when I was there last week...we saw it, but their person retrieved the birds from

the line.

I think the MOI is still warranted, but if you want to use discretion, then that would be okay as well.  I

think there will be plenty of times for us to document this issue when a plant person isn’t there

pulling birds off the line.

Raleigh District Office

Office of Field Operations

USDA FSIS

6020 Six Forks Rd.

Raleigh, NC 27609

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Office: 919-208-2936

Fax: 844-839-6359

Email: @usda.gov

From:

Sent: Tuesday, February 26, 2019 9:35 AM

To: Auxier, Travis - FSIS @fsis.usda.gov>

Subject: Question

If we go do a GCP and the plant is in front of us and takes off birds only when we are doing our

check, should we write MOI stating like you did on the one from your visit?  We had been told

previously that if they remove the birds that we don’t write one. 

Thanks!

Office of Field Operations

Food Safety and Inspection Service, USDA

c/o House of Raeford, P-737

253 Butterball Road

Teachey, NC 28464

(910) 463-7082

@usda.gov

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From: - FSIS

To: Hodge, Stanley - FSIS

Cc: - FSIS

Subject: RE: Question

Date: Wednesday, February 27, 2019 7:48:07 AM

It’s a tricky situation, I think.

They have no back-up person normally stationed just prior to the entrance of the scalder, so if

anyone is there, then that is a circumstance that it out of the ordinary. That being the case, I think

an MOI would be warranted because they wouldn’t have been there under normal circumstances

and the bird would have entered the scalder while still breathing. Even if they are performing their

own daily/weekly/monthly audit of the system, they don’t have anyone stationed there normally so

any bird you identify as “live” would have entered the scalder while still breathing. It’s no different

than what we saw when I was there last week...we saw it, but their person retrieved the birds from

the line.

I think the MOI is still warranted, but if you want to use discretion, then that would be okay as well. I

think there will be plenty of times for us to document this issue when a plant person isn’t there

pulling birds off the line.

District Veterinary Medical Specialist

Raleigh District Office

Office of Field Operations

USDA FSIS

6020 Six Forks Rd.

Raleigh, NC 27609

Office: 919-208-2936

Fax: 844-839-6359

Email: @usda.gov

From: - FSIS 

Sent: Tuesday, February 26, 2019 9:35 AM

To: Auxier, Travis - FSIS <Travis.Auxier@fsis.usda.gov>

Subject: Question

If we go do a GCP and the plant is in front of us and takes off birds only when we are doing our

check, should we write MOI stating like you did on the one from your visit? We had been told

previously that if they remove the birds that we don’t write one.

Thanks!

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Supervisory Public Health Veterinarian

Office of Field Operations

Food Safety and Inspection Service, USDA

c/o House of Raeford, P-737

253 Butterball Road

Teachey, NC 28464

(910) 463-7082

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@usda.gov

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