Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 107 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P164 Tyson Foods Inc IJM212306 

2410G 

10JUN2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

To: Mr. Steve Langford, Plant Manager Tyson 

Foods, P-164 Forest, MS At approximately 0404 

hours, while performing a portion ofthe Good 

Commercial Practice task as I was observing the 

conditions in the Picking room area in the 

Establishment's Ev_isceration department.. 

- observed a deep red live bird 

entering the scalding tank for Picking Line #1, the 

live bird was small and no cut was evident on the 

bird's neck area. The bird was alert at this time. I 

proceeded to watch the bird until it could be 

safely removed from the picking line. Upon closer 

examination, the bird in question was still intact 

with no cut to the neck area or anywhere else on 

the bird. I informed of this 

bird was observed with a bad cut along the neck 

area for Picking Line #3. However, I did not 

observe the second bird going into the scalding 

tank. 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 recommend that 

- review Federal Register Notice Vol. 70, 

No. 187, published September 2005 [Docket No. 

04-037N] for FSIS recommendations concerning 

treatment oflive poultry before slaughter and 

provided him a copy of this document. I notified 

- that this MOI will be forwarded to the 

District Office and the District Veterinary Medical 

Specialist (DVMS) in case additional follow-up is 

recommended. 

■ 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 108 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P164 Tyson Foods Inc IJM030908 

0009G 

09AUG2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized On August 08, 2019 atapproximately 1128, t 

observed less than Good Commercial Practices 

(GCP), on the Back Dock/Live Receiving Area. 

observed a live chicken rn the DOA Bin. The 

chicken was on top of the dead carcasses, 

appeared to be in good health and was removed 

by Plant Personnel when notified ofthe issue. 

as notified oft 

was present with me when this issue was found 

and Plant Personnel were notified. 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 109 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P165H OK Foods, Inc. DAF53040 

55821G 

21MAY2019 04COS Poultry Good 

Commercial 

Practices 

Finalized At approximately 0109, I went to live hang to 

perform part ofthe GCP task and immediately 

observed 3 live birds caught in the transfer belt 

gears. The belt was no longer covering the gears, 

which allowed live birds to get caught in them. 

The gears were ripping into their abdomens and 

crushing their rib cages. The live birds were unable 

to escape from the moving gears. One employee 

was trying to pull a live bird out from the gears 

while the gears were still moving. As I entered the 

live hang room, a maintenance employee exited 

the room through the back-dock door. There were 

2 employees with white shovels pushing the live 

birds that were on the dumping belt over to the 

opposite side to avoid the moving gears. The live 

hangers were sorting through the injured birds on 

their belt and hanging the uninjured birds. At no 

time did any employee stop the line to prevent 

any further birds from being injured. I 

immediately took regulatory control and had the 

belts stopped. I placed US Reject Tag No. 

B-45141447 to the emergency stop lines. I asked 

a maintenance employee that had just walked out 

the back door to radio 

that were caught in the gears. Two ofthese birds 

were still alive and one had just succumbed to his 

injuries. There were approximately 3-4 dead birds 

mangled within the gears also. Upon further 

inspection ofthe birds that were on the hanging 

belt, approximately 15 birds were found dead. 

Some ofthese had been eviscerated while t hey 

were alive. There were another 4•5 live birds with 

severe injuries such as partially amputated legs 

and crushed rib cages with deep lacerations to the 

abdomens. These birds had shallow breathing, not 

moving and t heir eyes were closed, which 

indicates they were in a state of moribund. The 

birds were removed and immediately euthani.zed 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 110 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

via decapitation. During the time that I was in 

live hang, I discovered that the live hang transfer 

belt that covers the gears had come offits track 

earli.er in the evening. At that time, Maintenance 

repaired the belt and had to remove a link in the 

belt during the repair 

and 

informed me that this had occurred and that they 

thought the problem had been fixed. I asked■ 

llllifanyone monitored this belt to ensure that 

it stayed on track. He told me that he did not 

believe anyone stayed to monitor the belt during 

operation. At approximately 0200 hours. 

- informed me that he had held a training 

session with all the live hang employees and 

leads. The training covered the topic of 

immediately stopping the line when a piece of 

equipment malfunctioned and notifying the lead 

or supervisor. - informed me that■. 

- was going to hold the same training 

for the maintenance employees as we11.• 

- also stated that a maintenance employee 

would be placed in live hang for the rest ofthis 

shift to ensure that the belt stayed on its' tracks. 

Regulatory control was relinquished at 

approximately 0236 hours after I monitored the 

equipment to ensure that it was functioning 

appropriately. I reviewed the establishment's 

Animal Welfare Program, last updated 2-17-19. 

There are no written procedures that describe 

what an employee should do when a piece of 

equipment breaks and begins injuring the birds. 

The establishment's program has procedures for 

instructing employees how to hang birds, carry 

birds, stun birds, and euthanize birds but it does 

not instruct them on how to stop a line to prevent 

birds from becoming injured. USDAs concerns are 

that there were approximately 15 employees in 

the live hang room, and no one was willing to 

stop the line to prevent the birds from enduring 
Table: MOls in Response to FOIA2020-110 10:12 Fnday. Februaty 21 , 2020 111 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

the injuries or agonizing death that they had to 

endure. USDA encourages the establishment to 

respond to this MOI. 

P165H OK Foods, Inc. DAF31090 

65910G 

i0JUN2019 04COS Poultry Good 

Commercial 

Practices 

Finalized On 06-09-19 at apprnximately 2126 whrle 

performing a good commercial practices check, I 

- observed two ltve birds in the DOA 

dumpster outside the live hanging room. It was 

early in the shift, so the birds were towardsthe 

bottom of the dumpster. I observed a rhythmic in 

and outof the bird's abdomen as it breathed. I 

ln the area at the time of my observation. A plant 

employee removed the lfve bird from the 

dumpster at which time I observed a second live 

bird that had been underneath it. During the 

removal process both birds had their eyes open 

and began moving around. Past pract ice at this 

facility is for all birds to receive cervical 

disarticulation prior to being placed in the DOA 

dumpster. rhe establishment's Animal Welfare 

Program states "Do not place any live birds ln the 

DOS containers. - explained that the 

employee responsible would receive additional 

animal welfare t raining. 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 112 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P165H OK Foods, Inc. DAF13101 

13319G 

19NOV2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized At approximately 0902 on Tuesday, November 19, 

2019, while performing a good commercial 

practice check in the live hang room I observed 

the following. An employee hanging live chickens 

on line 1 was repeatedly using excessive force to 

place the birds in the metal shackles. The force 

being applied was such that I was easily able·to 

hear the metal shackles banging loudly against 

the metal guide bar as the employee used a rapid 

downward motion to force the birds Into the 

shackles. After observing this same forceful 

technique used several times, I immediately 

proceeded to the cage dumper and motioned for 

the operator to cease dumping cages oflive birds 

onto the transfer conveyor. US reject tag 

B-45009716was attached to the dumper. Shortly 

thereafter, I metwith Mr. Danny Houston, Plant 

Manager and 

and explained my observations. 

Mr. Houston explained that all the live hangers 

had received training on animal welfare. The live 

hanger who had been using excessive force had 

already been removed from the live hang room 

and sent to the HR department. Mr. Houston 

explained that the employee would be 

terminated. Mr. Houston personally reviewed the 

establishment's animal welfare expectations with 

the remaining live hangers. Additionally, Mr. 

Houston commented that the establishment will 

be considering placing functional cameras in the 

live hang room. At approximately 0930 I released 

regulatory control ofthe cage dumper. Later in 

the shift, I toured the live hang room again and 

observed all employees using the appropriate 

hanging techniques. 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 113 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P165H OK Foods, Inc. DAF51041 

11129G 

29NOV2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized At approximately 0310, while performing Ante 

Mortem inspection on Lot #11-trailer 2030 in 

the Live Shed, I observed a bird with its head 

caught in between the top of the door and the 

cage frame. The bird was showing obvious signs of 

distress with the eyes closed and labored open 

mouth breathing. The head ofthe bird was 

beginning to show areas that were turning purple, 

which would indicate that the air flow intake of 

the bird was impeded. I immediately went to the 

live dock and motioned for 

to follow me to the Live Shed. I 

the distressed bird. He 

gently opened the door and was able to turn the 

bird's head slightly so that it could be placed back 

inside the cage. Once the bird was freed from the 

door, the bird immediately collapsed for 

approximately 20 seconds. The bird then slowly 

raised its head/body and opened its eyes. The 

breathing became more regular and the purple 

color began to slowly dissipate from the head. 

USDAs concern is that ifthis bird had not been 

found at thatt ime, it would have died due to 

suffocation. I asked- if he knew 

when that trailer was checked by the live side 

employee. He informed me that he went to the 

Scale house to review the log but was unable to 

locate any log. The employee present stated that 

he did not know where any log was either. A MOI 

was written on 2-11-2019 for a cage door being 

open while the fork lift driver from back dock was 

transferring the cage to the cage dump area. 

There were 4 chickens sitting on top ofthe door 

and one ofthe four fell offthe door when the 

cage was placed on the dock. The other 3 were 

caught between the door and the cage frame as 

the cage moved forward on the rolllng dock. The 

establishment replied to that MOI by stating the 

following: ''Heavener Plant will continue 

implementing our programs that we have in 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 114 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

place. In addition to our program Live Haul will be 

hiring two general yard employees. These 

employees will monitor the trailers and will help 

ensure that cage doors remain closed. These 

employees will also help keep cages in good 

repair. Live haul has issued flashlights to yard 

hands to help inspect cages in the holding shed. 

Live haul has added additional trailer check for 

the drivers.". USDA is also concerned that the 

program that the Live Haul has in place is not 

being implemented as it is written. The records 

documenting the inspection ofthe cages on the 

trailers in live shed could not be provided to USDA 

when they were requested either. This brings into 

question whether the cages are being inspected 

by the live haul employees. USDAstrongly 

recommends that the establishment respond to 

this MOI and address this issue of concern. 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 115 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Stat us MOI Agenda 

P165H OK Foods, Inc. DAF05021 

15530G 

30NOV2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized At approximately 2236 hours, while pe.rforming 

Ante Mortem on Lot 13-trailer 2004, I observed 

a chicken with its head and upper neck caught 

between the door and the side wall ofthe cage. 

The chicken had its eyes closed and was not 

breathing. I continued to monitor this chicken for 

another minute to ensure that this chicken was nd 

longer alive. This cage was located on the third 

row.of cages from the front ofthetrailer. The 

chicken was in the top right section ofthat cage. 

This chicken died due to strangulation/suffocation 

from having the airway impeded_ This would have 

occurred during the loading ofthe cage by the 

catch crew. As I continued my Ante Mortem 

inspection, I observed a door that was open 

approximately 2 inches. About this time, the scale 

house employee came to the· live shed to perform 

his trailer inspections. I showed him the open 

door and he tried to close it, but it would not 

close. He stated that the springs were broken on 

the door. He also stated that he has flagged 

numerous cages for broken springs, but they do 

not seem to get repaired. After I finished Ante 

Mortem inspection ofthe trailer, I went tothe 

scale house to noti ofmy 

observations. went to the live shed and 

had the employee free the chickens head from 

captivity. He also tried to close the open door on 

the other cage, but it would not close for him 

either. USDA is concerned that damaged doors are 

not being addressed in a t imely mannerand could 

result in the injury to chickens. USDAs concern is 

that the programs that the establishment has in 

place to prevent the injury to the chickens is not 

being followed. A similar incident was 

documented last night, 11-28-19, on MOI 

DAF5104111129G (Poultry Good Commercial 

Practices/DAF47011115291). In that incident, a 

chicken had its head caught between the door 

and the upper cage frame. This chicken was 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 116 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

semi-comatose with labored breathing. Although 

was able to free 

the chicken and the chicken survived, USDA is 

concerned that chicken would have succumbed to 

its injury if we had not found it. The establishment 

has not responded to that MOI at this time. The 

establishment's written program incorporates the 

ca.tch crew checking every cage before itis loaded 

onto the trailer, the truck driver checking the 

cages prior to leaving the farm and again once the 

trailer is dropped offin the live shed, as well as 

the scale house employees performing routine 

inspections ofall trailers that are in the live shed. 

Ifthis protocol was followed as it is written, the 

incident tonight should not have occurred. USDA 

strongly recommends that the estab'lishment 

respond to this MOI and address the concerns 

that are brought forth in this MOL 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 117 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P165H OK Foods, Inc. DAF47080 

13717G 

17 JAN2020 04COS Poultry Good 

Commercial 

Practices 

Finalized On the afternoon/evening of 1- 15-20 birds were 

caught and brought to the plant fro~ 

- located in Waldron, Arkansas. The earliest 

load arrived at 1747. Due to water related issues, 

the establishment did not slaughter on the 

evening of 1-15-20 and did not resume normal 

operations until approximately 0715 on 1-17-20. 

These same birds are still on site and have been 

without food or water for an extended period of 

time (approximately 37 hours). The 

establishment's Animal Welfare Plan contains the 

National Chicken Council Animal Welfare 

Guidelines and Audit Checklist for Bro.ilers. Page 

11 ofthe plan states "Feed withdrawal must not 

exceed 18 hours prior to slaughter''. Page 14 of 

the plan states "Holding times of live birds at the 

plant must be kept tothe minimum consistent 

with good processing practices, with the 

maximum time from catching to slaughter 

recommended to not exceed 12 hours". Both of 

these timeframes were exceeded. On the 

morning of 1-17-20, I met wit 

my concerns over the length of time these birds 

1

were kept on-site without food or water-

- understood my concerns and explained 

that the plant had requested that OK Farms live 

haul division return the birds to a farm on 

1-16-20. However, this did not occur. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 118 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P165S+V16 

ss 

OK Foods, Inc. LWA41120 

65714G 

14JUN2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized This MOI is to document my conversation w ith 

While performing a GCP task In the 

Live Hang area, I heard loud offensive music being 

played on a speaker device and being sang loudly 

by the employees. The lyrics contained vulgar 

content and foul language- stated that 

he did not take the issue lightly and would 

directly take care of it. Also, while performing a 

GCP task, I observed a live bird on the line #1 Kill 

line enter the scalders. The neck of the bird had 

not been cut. The eyes of the bird were opened 

and moving. While- and r were present, 

the cadaver carcass was sorted properly at the 

line #1 rehang table by being removed and placed 

into the marked ''Condemned" barrel. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 119 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P17766 Southern Hens, Inc SSN50140 

92607G 

07SEP2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On 09/06/19 at approximately 0715 hours, the 

following less than Good Commercial Practices in 

Poultry (GCPIP) incident was observed at Pl7766, 

Southern Hens Inc., Moselle, Ms while performing 

the routine PHIS Poultry Good Commercial 

verification task. In the back-dock area, ■ 

witnessed a live bird as it was 

stuck on the conveyer belt between a metal 

connecting piece ofthe sprayers above the crates 

and between the actively moving creates headed 

back to the loading trucks. The crates were 

pressed against the bird such that it was unable to 

free itself and .causing the right side of it's body to 

scratch and rub pulling feathers and creating 

small cut wounds. The cage conveyer belt was 

stopped to prevent further harm to the live hen. 

was brought out to 

visually observe the situation and was informed of 

the GCPIP MOI failure. I explained to ■ 

- that allowing live birds to remain in 

this type of condition while crates are actively 

moving could cause discomfort, stress, and death 

depending on the size ofthe birds with the 

contributing factor of heat. Live birds could 

potentially get loose and could be crushed by 

crates as well. 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. A establishment 

meeting was held at 3:00 p.m. 09/06/19 anti 

discussed briefly the less than 

GCPIP incident at back dock area. Respectfully, 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 120 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P18557 Sanderson Farms, Inc. QNA14080 

55806G 

06MAY2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized On May 6, 2019 at approximately 05:40 CDT, ■ 

observed less than Good 

Commercial Practices while performing an 

Ante-Mortem Inspection and Good Commercial 

Practices check at 18557 P In Summit, MS. While 

observing the kill machine ofeach picking line for 

proper function, I did not observe any 

abnormality in the equipment's operation. I did 

observe that a new employee was backing the kill 

machine on line #2. I walked to the end ofthe 

blood trough to observe for any live birds entering 

the scalder. I observed a single, live bird at05:40 

CDT enter the scalder on picking line #2. The bird 

was hanging on the shackle with its eyes open, 

blinking, head retracted and showing voluntary 

head movement. I did not observe a cut on its 

neck. This bird entered the scalder alive and still 

breathing. I observed the head grossly swollen 

and hemorrhagic after the bird exited the scalder 

and before itwent through the deheader. I did 

not take any regulatory action with this 

single-bird incident, since no evidence ofa system 

failure existed. I notified 

ofthe observed 

nonconformance, .during a brief meeting held in 

rehang at approximately 05:47 CDT. I presented 

the cadaver to him, explained my observation, 

informed him that a Memorandum_ of Information 

(MOI) was going to be documented, and 

relinquished the carcass into his control. A copy 

ofthis Memorandum of Information will be 

forwarded to the appropriate personnel in the 

Jackson Distrkt Office. Respectfully 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 121 

Task 

EstNbr EstName MOINbr Date Code TaskName Stat us 

P18557 Sanderson Farms, Inc. QNA53091 17OCT2019 04C05 Poultry Good Finalized 

05817G Commercial 

Practices 

P192 Pilgrim's Pride Corporation OOB30090 23APR2019 04COS Poultry Good Finalized 

4.4923G Commercial 

Practices 

MOI Agenda 

At approximately 05:55, while performing a Good 

Commercial Practices task- noticed 5 

birds in 4 minutes displaying conscious movement 

entering the scalder on line 1. Some had obvious 

cuts to the neck and were bleeding. In all 5 cases, 

the necks were not flaccid, and the birds had their 

heads cocked to the side, and were observed to 

be consciously looking around . .I immediately 

notified . He 

determined that the stunners on both lines had 

not been set to proper operating settings after 

maintenance. They were reset. A recheck at 

06:00 by- showed that the situation has 

been resolved. 

At 0452 white was performing 

Antemortem inspection the following failure to 

observe Good Commercial Practices was 

observed. A trailer-with live birds from Lot2 

- contained a cage ih Which the floor 

bottom divider had fallen down on top of several 

birds, which had to bear the weight of the divider 

and layer of birds atop it, and forcibly pinning one 

bird against the cage bars. The bird was alive, but 

its breathing appeared stressed. The inspector 

immediately notified 

- to address the animal welfare 

concern. Cage conditions were recently 

discussed in weekly meeting with management 

held on 4/ 18/19, to confirm cages in poor 

condition were culled during slaughter renovation 

downtime 3/25- 3/29/ 19. Previous issued MOI 

OOB1712129311 on 12/31/18 was for cage 

conditions affecting live birds. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 122 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P192 Pilgrim's Pride Corporation OOB34200 

23111G 

11FEB2020 04COS Poultry Good 

Commercial 

Practices 

Finalized 

P19688+V1 

9688 

Sanderson Farms, Inc. KJA471812 

3609G 

09DEC2019 04COS Poultry Good 

Commercial 

Practices 

Flnallzed 

MOI Agenda 

On February 11, 2020 at approximately 1840 

hours while performing the poultry good 

commercial practices check, I observed a live bird 

enter the scalder. The bird was completely 

conscious, with its head raised, blinking, and 

looking around. The bird did not have a cut on its 

neck. I immediately notified- of the 

situation. 

On 12/9/2019 at 1820 hours,_ 

observed the following while performing a Good 

Commercial Practice task. On kill lfne #2 at 1820 

hours, a live bird was observ.ed without an incision 

on the neck of the bird. The live bird blinked 

numerous times when CSI shined a flashlight in Its 

eyes. CSI took regulatory control action by 

stopping the affected line and notifying 

Establishment Management ofthe situation. 

removed 

the live bird from the line and confirmed no 

ird became extremely 

Id bird in the air. 

as informed at 1824 

hours of a MOI being written. The above 

aforementioned situation is not compliant with 

9CFR381.65(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." -

-12/9/2019 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 123 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P19688+V1 

9688 

Sanderson Farms, Inc. KJAS01702 

0814G 

14FEB2020 04COS Poultry Good 

Commercial 

Practices 

Finalized At approximately 1714 hours on February 14, 

2020 a live bird, that was still breathing, was 

observed entering the scalding tank on line 1. ■ 

observed the cadaver. 9 CFR 381.65(b) requires 

that poultry be slavghtered in accordance with 

GCP and in a manner to ensure breathing has 

stopped before scalding. Furthermore, 9 CFR 

381.90 states that poultry carcasses showing 

evidence ofhaving died from causes other than 

slaughter are considered adulterated and must be 

condemned.- disposed of the carcass 

immediately. As immediate corrective actions 

to prevent ongoing bird suffering and adulteration 

ofproduct,_ said he would ensure the 

automatic knife was working properly, discipline 

the employee stationed at the back up kill 

position, and provide t raining to said employee. 

Preventing mistreatment and slaughtering poultry 

in compliance with 9 CFR 381.65(b) decreases the 

chances of producing adulterated carcasses. 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 124 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P20251 Tecumseh Poultry, LLC PBM00090 

62110G 

10JUN2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On 06/10/19, at approximately 0809 hours, while 

performing a routine Poultry Good Commercial 

Practice Verification task, I­ - observed one instance of bird 

mistreatment on an NAE (No Antibiotic Ever) 

trailer, numbered T323, in the loafing shed. The 

bottom module had a compartment with a stuck 

bird. The bird's two middle toes (second and third 

digits) ofthe left paw were trapped between the 

spring wire and the door. The toes were squeezed 

flat by the spring door contraption causlng the 

toe's segment atthe distal phalange toturn 

slightly blue/purple, which may have indicated 

ischemia. The bird at this time was not moving or 

attempting to move. The bird had its eyes closed 

and was not fully alert/responsive to 

manipulation. The left leg ofthis bird was laid out,. 

if not stretched out, horizontally behind it. I met 

wit to show him 

the situation. He slowly opened the door and 

released the toes. The bird remained recumbent 

with the leg staying in the same position. The 

Poultry Products Inspection Act and Agency 

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

poultry be handled in a manner that is consistent 

with Good Commercial Practices (GCPs). 

Compliance with GCPs increases the likelihood of 

producing unadulterated product. Poultry are to 

be handled in a manner that prevents needless 

injury and suffering in order to produce a 

commercially marketable product. Establishment 

management may review Federal Register notice 

"Treatment of Live Poultry before Slaughter", 70 

Fed. Reg. 56624 (September 28, 2005), for FSlS 

recommendations concerning the treatment of 

live poultry before slaughter. This l\/lOI will be 

forwarded to the District Office and the District 

Veterinary Medical Specialist (DVMS) in case 

additional follow-up is recommended. Sincerely,

-
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 125 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P20251 Tecumseh Poultry, LLC PBMS7120 

61413G 

13JUN2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On 06/13/2019, at approximately 1150 hours, 

while performing a routine Poultry Good 

Commercial Practice Verification task, I­ - observed three instances ofbird 

mistreatment on two NAE (No Antibiotic Ever) 

trailers in the loafing shed. On trailer number 32, 

one bird had its wing tip squeezed between a 

metal board and the floor board ofthe 

compartment above. The bird had enough wing 

length to still be able to lay down. However, its 

wing was raised above its back. At this time, I 

released its wing by propping the top floor board 

from the metal bar. Due to the feathers, I was not 

able to see Ifthere was damage to the wing tip. 

Then, on trailer number T786, on the very top tier 

ofthe stacked modules, one bird had its "shank" 

stuck between the floor board and the metal bar. 

This bird made multiple attempts ofwithdrawing 

this foot and as itdid, blood was actively dripping 

from the area that was being scraped by the floor 

board. There was evidence of bleeding before I 

·arrived to see this mistreatment. Small amount of 

blood could be seen on some ofthe metal bars of 

the lower part ofthe module and on the ground 

below the injured shank. On the same trailer, the 

module below the module with the bleeding bird 

had another bird with its left hock stuck between 

the floor board and the metal bar. The bird was 

not able to retract this leg against the floor board. 

The result was heavy bruising and scrapes on the 

medial aspect ofthe hock and distal thigh. This 

bird was not dripping with blood, butthe floor 

board edge had a bloody color that was 4-5 

inches in length. At approximately 1200 hours, I 

to show and explain to them what I 

saw. A scale house personnel was assisting the 

bleeding bird to retract its leg and was successful 

so that it was no longer stuck. The bird did not 

flex its hock back to a normal position after.its 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 126 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

shank was released. The establishment was not 

able to release the bird with the stuck hock due to 

the location ofthe bird in the module, so the QA 

Supervisor had this trailer pulled up to be 

slaughtered next. The Poultry Products 

Inspection Act and Agency regulations (9 CFR 

381.65(b)) require that live poultry be handled in 

a manner that is consistent with Good 

Commercial Practices (GCPs.). The establishment is, 

encouraged to mafntaln the standards ofGCP 

through a systematic approach that focuses on 

treating poultry in such a manner as to minimize. 

excitement, discomfort, and accidental injury the 

entiretime thatlive poultry is held in connection 

with slaughter. Establishment management may 

review Federal Register notice ''Treatment of Live 

Poultry before Slaughter", 70 Fed. Reg. 56624 

(September 28, 2005), for FSIS recommendations 

concerning the treatment of live poultry before 

slaughter. This MOI will be forwarded to the 

District Office and the District Veterinary Medical 

Specialist (.DVMS) in case additional follow-up is 

recommended. Sincerely, -
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 127 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P206+V206 Pilgrim's Pride Corporation KCC482006 

4618G 

18JUN2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

On June 17, 2019 at approximately 1955 hours 

while performing a routine PHIS Poultry Good 

Commercial Practices task 

observed the following noncompliance. At the 

entrance of the stunning equipment there was a 

dead bird lying on the ground just below the east 

picking line with both ofits legs ripped off. I 

immediately informed 

llllto stop hanging birds so as to prevent 

anymore birds from dying before slaughter and 

call management to the area.-

was notified and 

observed the mutilated bird along with the 

remnants from where the bird was ripped apart. 

As I was examining the birds entering the 

stunners., one bird came down the west picking 

line hung by only one leg and the birds were 

being smushed up against one another 

inappropriately as the equipment was elevated 

too high - instructed maintenance to 

adjust the stunning equipment and new shielding 

was installed to the east line to protect the birds 

from being pulled apart. A similar occurrence 

took place on March 15, 2019 for birds dying in 

this same way, with their legs ripped offby 

equipment. Failure to Implement procedures for 

preventing accidental injury and/or death 

inconsistent with 9CFR 381.65(b) in regard to 

birds presented for slaughter, resulted in a GCP 

failure, and a bird 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 

prevent excitement, discomfort, and accidental 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 128 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

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 mannerthat 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 ofthis 

noncompliance will be distributed to the 

establishment, inspection file and District 

Veterinary Medical Specialist per FSIS Directive 

61D0.3. The establishment is also reminded that 

NRs and MOls documented for GCP issues can be 

FOIA requested and made available for viewing by 

FSIS. Documented by 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 129 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P206+V206 Pilgrim's Pride Corporation KCC421601 

5015G 

15JAN2020 04COS Poultry Good 

Commercial 

Practices 

Finalized At approximately 1146 hours, while pe.rforming 

ante mortem inspectlon at the back-dock area, I 

observed a chicken's leg caught between the door 

and the side wall cage frame. This cage was the 

4th cage from the tail end ofthe trailer and on the 

top level, bottom cell on the right. I then observed 

a chicken with its head caught between the door 

and the top of the cage frame. This cage was 

directly beneath the cage that was mentioned 

above, third cell on the right. The chicken's head 

was pale in color, the eyes were closed, and the 

beak was open wide. I could not see any 

breathing pattern exhibited bythis chicken, which 

indicated to me that this chicken was dead due to 

strangulation. 1 continued with ante mortem and 

observed a chicken with its wing caught between 

the door and the cage frame. The angle of the 

wing indicated that this wing could be broken. 

This cage was on the top level at the very tail end 

ofthe trailer, second cell on the right. I 

immediately located an .employee that could find 

someone from management for me. The 

arrivec!, and I 

deficiencies 

· ed for 

I informed that no more cages were to 

be unloaded from this trailer at this time. He then 

told the back-dock forklift drivers notto remove 

any more cages from the trailer. When the 

managementteam arrived, I showed them the 

inhumane handling deficiencies that occurred 

when the chickens were being placed in the cages 

by the catch crew. I informed Mr. Cabrera that 

this was unacceptable, and a MD.I would be 

written. I allowed the forklift driver to remove the 

cage with the chicken's leg caught in the door and 

place the cage on the ground atthe end of the 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 130 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

trailer.- opened the door to release 

the leg. I immediafely noticed that the leg was 

broken from being caught in the door/frame. I 

then turned back around and noticed that the 

cage in which the chicken's head was caught was 

110 longer on the trailer, nor was it on the ground 

at the end ofthe trailer. I asked- where 

that cage went to. He stated that he did not know 

and that he did not tell the forklift drivers that 

they could remove any other cages. We then 

observed the forklift driver remove another cage 

from the trailer.- immediately stopped 

the employee from going any further with that 

cage. I informed management at that time that I 

had not allowed any other cages to be removed 

from the trailer except for the cage in which the 

chicken's leg was caught in the door. I informed 

management that they needed to locate the cage 

in which the bird's head had been caught in the 

door. The cage was located on the back-dock, 

waiting to be dumped onto the live hang belt. The 

last cage in which the wing was caught was 

removed from the trailer and set on the ground. 

The door was opened, and the wing was released. 

Fortunately, the wing was not broken. The 

chicken with the broken leg was humanely 

euthanized by the establishment. USDA's 

concerns are that the inhumane handling ofthe 

chickens that were observed today should have 

been identified by numerous individuals (live 

catch crew, the employee that tightens the booms 

on the cages, the truck drivers that haul the 

trailers to the plant, the "yard dog" that brings 

the trailer from the live shed to back-dock, and 

the employee that releases the booms) prior to 

USDA observing them. The failure for the 

establishment and the live side to identify these 

issues has resulted in the injury ofone chicken 

and the death of another chicken. The 

establishment should beaware that this Good 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 131 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

Commercial Practice MOI is subject to the 

Freedom of Information Act and can be requested 

by organizations such as Mercy for Animals. USDA 

encourages the establishment to respond to this 

MOI as well as develop a strong live animal 

handling protocol in which their employees from 

live side and the establishment can adhere to. A 

similar GCP MOI was documented on 1-10-2020, 

MOI -KCC481801140G, for damaged cages being 

placed back into circulation and the potential for 

injury to the chickens. 
Table: MOls in Response to FOIA2020-110 10:12 Fnday, Februaty 21 , 2020 132 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P208+V208 George's Processing, Inc. XIC111306 

2604G 

04JUN2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On Tuesday, June 04, 2019, at approximately 

11:45 hours, 

. The following is a synopsis of the events 

and discussion regarding possibly suffocated birds 

due to belt malfunction. At approximately 10:45 

hours while performing Good Commercial 

practice verification, I .observed that the Line 1 

back-up killer was performing an abnormally high 

number ofkill cuts (approximately 18 over one 

minute with the normal observations being six per 

minute), I immediately informedWhile discussing w[th 

him, the belt for the Line 1 live hang conveyor 

system malfunctioned. Since this area was next on 

my area to evaluate and due to previous history, I 

elected to observe the establishment 

implementing their procedures. As I observed the 

belt, I observed that birds were 3-4 layers deep 

with birds on top of each other on the conveyor 

from the wall until first live hang personnel 

position. As I continued watching, there was one 

(and at times a second person) that was pushing 

or lightly tossing birds further down the belt to 

allow the personnel to hang the birds on the line. 

One of the people that was pushing the birds 

further down the belt would stop every few 

minutes to retrieve birds that were no longer 

breathing. Another person positioned on the 

opposite was sporadically relocating birds further 

on down the belt. As I continued watching, I 

observed that numerous birds ofthe tqp layer 

were lifting their wings, beaks open, and their 

respiratory rate appeared faster than normal. It is 

important to note that while observing the 

condition ofthe birds in the trailers as well as the 

modules (outside), I only observed one or two 

birds with their beaks open and what appeared to 

be an increased respiratory rate. I also observed 
Table: MOls in Response to FOIA2020-110 10:12 Fnday, Februaty 21 , 2020 133 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

that birds on the lower layers appeared to be 

repositioning to get out from other birds. In 

addition, I observed one bird that was sitting on 

top of two birds that was trapped on its back by 

two other birds. It was flapping its wings, 

attempting to roll, open beak, respiratory rate 

was fast, and the bird appeared to have increased 

respiratory effort. Before the establishment could 

remove the birds sitting on it, the bird stopped 

breathing. After about 20 minutes, the 

establishment was able to get the belt clear. As I 

watched the live hangers, I observed two birds 

that were not mo'v'.ing, no obvious breathing, and 

that were not responsive to stimuli that were 

hung on the line. During the 20-minute period of 

the beltbeing malfunctioning, I observed 

approximately 30-40 dead birds that had been 

removed from the belt by employees or fallen on 

to the floor at the end ofthe belt. Now that the 

belt was clear, I immediately informedofmy observations and that the malfunction ofa 

belt resulting in the suffocation of at least one 

bird (and possibly as many as 40) was not 

consistent with good commercial practices. I also 

informed him that at least two dead birds had 

been hung on the lines. I Informed- that 

this was not consistent with the establishment's 

sorting procedures which indicates that the live 

hang will not hang dead birds on the line. Then, 

we proceeded to the kill line between the end of 

the pickers and the post pick dip to retrieve any 

carcasses that died by methods other than 

slaughter. As we watched the line looking for 

cadavers, 

approached and I informed him ofmy 

observations, concerns, and that the malfunction 

ofthe belt resulting in at least one bird 

suffocating was not consistent with good 

commercial practices. After the conversation 

ended,- removed a single carcass that 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 134 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

appeared to be· a cadaver with red to purple 

discoloration of the neck and body. The meeting 

was adjourned at approximately 11:50 hours. On 

June 5, 2019, at approximately 10:30 hours 

explained his observations 

and concerns from the belt malfunction from 

yesterday. - explained that these birds 

were not slaughtered in accordance with Good 

Commercial Practices - informed 

establishment management that he wanted to 

provide the establishment with an opportunity to 

respond with a plan in action to prevent future 

occurrence. - continued that memoranda 

ofinterviews (as well as noncompliance records) 

are not punishments and are an opportunity for 

FSIS to present concerns in writing·to the 

establishment to provide them With due process. 

- further summarized 9 CFR 381.65 and 

explained that this is the regulatory requirement 

for Good Commercial Practices. - informed 

establishment management that based on 

conversations yesterday that the establishment 

was going to modify their preventative 

maintenance schedule for the live hang belt 

replacement.- inquired ifthere were any 

additional steps that production could take to 

help alleviate the possibility of birds dying by 

methods other slaughter. - informed . 

- that the establishment's goal (when the belt 

malfunctions) is to attempt to get the birds off the 

belt as soon as possible (to prevent any dying by 

methods other than slaughter). -

informed- that the belt malfunction or 

the steps to correct was not intended to harm any 

chickens. Discussion involved potential steps to 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 135 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

improve efficiency oftransporting the chickens 

from the dumper to the live hang personnel when 

the belt malfunctions. Establishment 

management also informed- thatthe 

establishment will evaluate whether improving 

ventilation from the dumper to the live hang 

personnel would help minimize the number of 

birds in respiratory distress. The meeting was 

adjourned at approximately 10:40 hours. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 136 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P208+V208 George's Processing, Inc. XIC221309 

4310G 

10SEP2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On Monday, September 9, 2019, at approximately 

1050 hours, 

following is c1 synopsis ofthe events and 

conversation regarding live and dead birds that 

were trapped between the green fiberglass floor 

sheets of each layer ofthe module and the 

vertical partitions ofthe framework on the 

module. At approximately 1050 hours While 

performing antemortem due to a.change in lot, I 

observed that there was module on the outgoing 

conveyor ofthe dumper. I immediately observed 

t hatthere were.numerous live and dead birds in 

the module. I observed that there were at least 

two dead birds whose neck was trapped between 

the Vertical partitions ofthe framework ofthe 

module and the green fiberglass floor sheet. The 

forklift operator sat the module to the side and I 

requested that the receiving personnel wait to 

allow me to show it to establishment 

management. I immediately requestedor- to my location. While waitTni torllll 

llllllfobserved that there was a total of 11 

chickens. Three ofwhich were still living with two 

who had wing caught between the framework of 

the floor ofthe layer module and the green 

fiberglass floor sheets. These chickens were 

unableto get their wings free. I also observed one 

carcass whose head was twisted and caught 

between the vertical partitions ofthe framework 

and the green fiberglass floor sheet. This carcass 

also had a compound fracture that was protruding 

between the vertical partitions ofthe module. I 

verbally and visually informed him ofmy 

observations. I also informed- that these 

findings indicate that these poultry had not been 

slaughtered in accordance with good commercial 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 137 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

practices.- informed me thawas on his way down from the live haul building. 

Wherallll arrived, I visually and verbally 

informed him of my observations. I inquired about 

the cause.- informed me that the module 

was likely dropped at the farm. - informed 

me that he would address with the live haul crew. 

- discussed with - about which 

trailer the module had been unloaded from. The 

meeting was adjourned at approximately 1100 

hours. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 138 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P208+V208 George's Processing, Inc. XIC391909 

3230G 

30SEP2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized September 30, 2019 at approximately 1915 

hours, while observing the scalding and picking 

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

bird enter the scalder. The bird did not appear 

stunned and there was no evidence ofa cut on 

the neck or head. Due to the height and speed of 

the line I was unable to safely remove the live bird 

from the kill line before itentered the scalder. I 

immediately observed the stun and kill operations, 

for both kill lines and determined that the 

slaughter process was not out of control. l then 

notified who 

immediately investigated the incident I also 

notified of 

my findings. I monitored stun/kill operations on 

both kill lines for an additional 10 minutes and 

did not observe any more live birds enter the 

scalder, although I did note that approximately 1 

bird per minute was being hung by one leg on Kill 

Line #1. I spoke to- at 1950 hours 

and he stated that the backup killer on Kill Line-#1 

received counseling and would undergo additional 

GCP training - was also addressing the 

one-legged hanging on Kill Line #1 at this time. At 

2000 hours I observed stun/kill qperations on Kill 

Line #1 and observed noticeable reduction in the 

number ofbirds being hung by one leg. Live 

poultry entering the scalder reflects poor 

commercial practices and may result 

in noncompliance with 9 CFR 381.65(b) which 

states that ''poultry must be slaughtered in 

accordance with good commercial practices in a 

manner that will result in morough bleeding of 

the carcasses and ensure that breathing has 

stopped prior to scalding". 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 139 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P208+V208 George's Processing, Inc. XIC131510 

0224G 

24OCT2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized October 23, 2019 atapproximately 2140 hours. 

While walking through the live receiving area I 

observed a transport cage lying on its side on a 

trailer. The cage contained approximately 200 

chickens which were piled oh top ofeach other 

due to cage position. At this time I noted that 

there were several dead birds at the bottom ofthe 

pile. I observed as a forklift was used to remove 

the cage from the trailer, place it on the ground, 

and set it upright. The cage was then taken to the 

Line #1 cage dumper where the chickens were 

deposited onto the live hang belt. The live birds 

were then hung on Kill Line #1 to be slaughtered 

and then condemned by the establishment prior 

to entering the scalders. While monitoring the 

live hang and slaughter activities I noted that 

there were approximately 80 dead chickens from 

the overturned cage which were being removed 

from the live hang belt and condemned by 

establishment personnel. At 1750 hours on 

October 24, 2019 I discussed the incident with 

stated that the transport cage had fallen 

onto its side due to mishandling by a forklift 

driver. He also stated that the forklift driver 

will undergo addltional training In 

humane poultry handling and forklift driving to 

help prevent similar instances in the future. 

Poultry dying from causes other than by slaughter 

reflects poor commercial practices. Poultry 

slaughter establishments are responsible for 

ensuring that humane methods of handling and 

slaughter are consistent with good commercial 

practices. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 140 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P208+V208 George's Processing, Inc. XIC200512 

3717G 

17DEC2019 04COS Poultry Good 

Commercial 

Practices 

Finalized On Monday, December 16, 2019, at 

approximately 1150 hours, 

met with 

, in the evisceration supervisor 

office. The following is a synopsis ofthe 

discussion and events regarding approximately 9 

cadavers due to no back-up killer after production 

resumed due to a loss ofelectricity to the 

establishment. At approximately 0910 hours upon 

the restoration of electricity and power to the 

establishment, I observed that the kill lines were 

about to start. I observed - don a 

cut-resistant glove and knife to attend to the birds 

missed by the kill machine on Kill Line 2. I 

observed the picking room employee who wears a 

maroon smock don the other cut resistant glove_, 

but the receiving/paw lead requested the cut 

resistant glove from the employee wearing the 

maroon smock. It is important to note that no 

employee was in the role ofthe back-up killer for 

Line 1. At this point, the employee wearin15 the 

maroon smock dipped under the line and left the 

picking room (toward the picking room 

breakroom). I observed a- and the 

receiving/paw lead began addressing the birds 

missed by the kill machine on Kill Line 2, but no 

one was addressing the birds missed by the kill 

machine on Kill Line 1. It is important to note that 

the - and the receiving/paw lead 

appeared to be struggling to keep up based on my 

observation. As the last birds (due to break) 

passed by on kill Line 2, the picking room 

employee wearing the maroon smock returned to 

the area. Then, I proceeded to the area to watch 

the carcasses enter the scalder. While observing 

Kill line 1, I observed two birds that there head 

was tucked up against the breast muscle. It is 

important to note that this was an atypical 

observation. I observed as both birds missed the 

head puller stationed prior to the scalder. At that 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 141 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

time, I was unable to visualize any kill cut. Due to 

the uncertainty, I proceeded to watch the 

birds/carcasses exiting the pickers/scalder. I 

observed as approximately 9 carcasses over 15-20 

seco.nds that had cherry red to purple 

discoloration of the neck and breast muscle with 

no visible kill cut. It is important to note that this 

was observed prior to the establishment's back up 

head puller. I requested 

presence as the cadavers passed by the rehang 

table and demonstrated the carcasses that had 

cherry red to purple discoloration ofthe neck 

indicate that they had entered the scalders alive. 

As three of the cadavers were condemned, I also 

visually inspected and verbalized my findings to 

- in which these cadavers had no kill cut. 

At this time, I discussed with- that these 

observations may indicate noncompliance with 9 

CFR 381.6S(b). At approximately 11:50 hours, I 

informed- that birds should be 

slaughtered in a manner that results in thorough 

bleeding of the carcasses and ensure that 

breathing has stopped prior to scalding. These 9 

cadavers were not slaughtered in accordance with 

good commercial practices. I informedthat no back- up killer was present which could 

potentially indicate a loss ofprocess control. I 

explained the physiological and gross pathological 

differences between a cadaver and a DOA talso informed me that the 

been sent to lunch and that 

mployee with the maroon 

informed me his name is 

ave been the back-up killer for 

ofmy 

observations that had left the area 

and was not present at on Kill Line 1. I explained 

that ifIPP identify a trend ofcadavers that this 

may result In noncompliance w ith 9 CFR 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 142 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

381.65(b). The meeting was.adjourned at 

approximately 1200 hours. 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 143 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P211 Palmetto Pigeon Plant, Inc. DJK231309 

1210G 

10SEP2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On September 10, 2019, at approximately 0935 

hours while performing a Poultry Good 

Commercial Practices (GCP) task in the Slaughter 

Area, I made a few observations while the 

establishment was slaughtering Silkies. There 

were several birds with inadequate cuts jumping 

around on the floor area In excess scald water. I 

observed one (1) loose live bird walk under the 

scald tank into the flames. An employee had to 

drag the bird with the squeegee mop used to 

clean the floor to get the bird before being almost 

incinerated. Another observation was made ofthe 

employee applying the cut on the neck of the 

birds and sometimes having to apply more than 

one cut resembling a saw-like motion. Lastly, I 

observed several live birds that werenot cut or 

had poor/inadequate cuts without allowing full 

time to bleed out, moving around in the barrels 

that are used prior to dumping in the scald tank. 

Some ofthe live birds were buried beneath dead 

birds and I observed breathing, body and wing 

movement from the live birds that were trapped. 

After observing the issues noted, I ask that the kill 

process be stopped, and I went to notify . . Once she 

arrived I notified her of my observations and she 

verbally counseled the employees and went to 

retrieve more knives that were sharpened. I then 

allowed the kill process to resume and observed 

for several minutes along with to 

ensure the slaughter process was in acc;ordance 

with Good Commercial Practices, 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 w ith Good Commercial 

Practices. I notified that this MOI' 

will be forwarded tothe District Office and the 

District Veterinary Medical Specialist (DVMS) in 

case additional follow-up ls recommended. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 144 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P211 Palmetto Pigeon Plant, Inc. DJK371101 

2414G 

14JAN2020 04C0S Poultry Good 

Commercial 

Practices 

Open 

MOI Agenda 

Today, at approximately 0930, as well as,.on 

01/13/2020; observations were made by■ 

(double placement of birds into one cup) 

(Red Birds at Postmortem) ■ 

made observations of plant employees 

placing two birds in one "bleed out cup". This was 

hindering the top bird from bleeding out properly. 

Also observed during this GCP was some of the 

top birds were moving so much that they were 

wiggling out ofthe cups onto the floor. I informed 

- of my observations and she indicated 

she would address the issues. This observation 

was made while slaughtering "Black Meat 

Chickens" today. On Monday, I was informed by 

- that she had a higher than normal 

count for birds that appeared to not have bleed 

out properly. My observation on today may have 

been the cause for the higher number of"Red 

B.irds" coming in at the Postmortem station on 

Monday while slaughtering Squabs/Pusan's." 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 145 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P21234 Perdue Foods LLC XG1331208 

1127G 

27 AUG2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

Perdue Farms P-21234 Date: 8/27/2019 Time: 

1:36PM On Tuesday, August 27, 2019, at 

approximately 8:21am, I,_ observed 

the following: while performing Good Commercial 

Practices Verification, there were approximately 

20-30 birds piled up on the DOA taple. Mixed with 

these birds were 7 visibly live birds. The DOA birds 

were falling on top ofthe live birds, smothering 

them. I did not see anyone on the floor 

monitoring the DOA table so J went to find 

someone. I informed that they 

needed to retrieve the live birds immediately and 

appropriately condemn the DOA birds. I reminded 

him that someone should be monitoring the table 

at all times, even when they are short staffed. 

There were also several live birds (approximately 

20) on top of and under the cage dumps and no 

one was retrieving them either. I spoke with. 

informed 

him of my observations, and let him know that I 

would be documenting my findings in an MOI, 

because it is mistreatment and it is not consistent 

with good commercial practices. This MOt will be 

forwarded to my

Illthe District Office, and the· District 

Veterinary Medical Specialist in case additional 

follow~up is recommended. Respectfully, ■ 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 146 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P21234 Perdue Foods LLC XGIS41008 

5030G 

30AUG2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized Perdue Farms P-21234 Date: 8/30/2019 Time: 

11:56AM On Friday, August 30, 2019, at 

approximately 11:23am1 I, 

while performing Good Commercial Practices 

Verification, observed under the holding shed a 

live bird dangling from a cage that was not in 

good repair. The side of the cage was not secure; 

the metal was sticking outward and twisted in an 

unorganized fashion, and the bird was caught on 

the side ofthe cage and hanging by one leg. The 

bird was obviously distressed flapping its wings 

hysterically and trying to throw its body back into 

an upright position. I quickly alerted­

- to assist me with getting the bird 

down, which he did. This incident caused the 

bird to be significantly stressed. This is 

mistreatment and it is not consistent with good 

commercial practices. I informed­

- ofthe mistreatment I had observed, and told 

him that I would be documenting my findings in 

an MOI. This MOI will be forwarded to my-

, the District Office, 

and the District Veterinary Medical Specialist in 

case additional follow-up ls recommended. 

Respectfully, 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 147 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P21234 Perdue Foods LLC XGI010811 

5107G 

07NOV2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

Perdue Farms P-21234 Date: 11/7/2019 Time: 

9:02AM On Thursday November 7, 2019, at 

approximately 8:31am, I,_ , while 

performingGood Commercial Practices 

Verification in the picking room, observed 2 

shackles that had 2.birds hanging on them coming 

out of the scalders on evis line 1. There should .not 

be more than one bird per shackle. The extra birds 

were hanging by one leg, both were without a 

neck cut, and were not properly bled out. They 

were identified as cadavers. I informetlllll 

this issue and told them to 

gers that there should be only 

. The backup neck cutter also 

d as well to know what to do 

. ■ 

of the 

dings in an MOI. 

myhe District Office, 

·and the District Veterinary Medical Specialist in 

case additional follow-up is recommended. 

Respectfully, 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 148 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P21234 Perdue Foods LLC XG1312011 

37256 

25NOV2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On Nov. 20th at approximately 03;30 while doing 

a three-minute GCP check on line one, I observed 

one bird enter into the scald tank alive. The bird 

had raised its head above t he level of the neck 

cutter. After observing this., I went and observed 

the back- up neck cutter, and discovered that 

instead of paying attention to the birds, he was 

washing down the floor with a waterhose. As I 

watched he also turn the hose unto the blood 

troth in front of his station, spraying the birds 

with water as they went by. I notified­

- of this event; and went with him to 

the end of the line one in the picking room and 

recovered the bird that had entered the scald 

tank. later informed me 

t hat a training was performed with all back-up 

neck cutters, instructing them not to be using a 

water hose when performing their job as back-up 

neck cutters. On Nov. 25th at 03:15 while doing 

a three-minute GCP check of line one, I observed a 

live bird again entered into the scald tank. The 

bird's small size allowed him to avoid the neck 

entering the scald tank. Again, it was observed 

that the back-up neck cutter was usinga water 

hose when the bird had entered into the scald 

tank 

accompany 

oom line to recover the 

was also informed of 

this incident. The back-up neck cutter was given 

disciplinary action. These two incidents were 

disc:ussed with- and he agreed that 

though these incidents were of concern, they did 

not constitute a loss of process control. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 149 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P2178 PERDUE FOODS LLC MXM4804 

125517G 

17DEC2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized At approximately 13:06 hours on Wednesday, 

December 11, 2019, while preforming a routine 

Good Commercial Practice/Ante Mortem task as 

part ofthe routine USDA Poultry Welfare audit, in 

the receiving area of P-2178, Perdue Foods LLC in 

Georgetown, DE, two (2) live birds were found in 

the DOA bin. Both birds were on top ofthe tank: 

one was on its' back and the other.had its head 

buried in the pile with its tail up. Both birds 

appeared to moribund, struggling to breathe and 

moving their feet slightly. 

- at P-2178 who was preforming the Audit 

also observed the findings. 

- also was notified. The findings with 

were discussed in detail with all present at the 

time of the finding and stated that a MOI will be 

issued for this animal welfare concern. This is an 

isolated incident with the most recent finding 

related to this was from March 2018, On 

Thursday, December 12, 2019 at approximately 

06:30 hours, I discussed the findings with ■ 

told me that corrective 

actions including immediate and thorough 

training all associates in receiving, along with 

re-certlfication and evaluations of associates 

assigned to floor duty in receiving were already 

being implemented by Establishment 

Management. 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 

MDI wi!l be forwarded to the District Office and 

the District Veterinary Medical Specialist (DVMS) 

in case additional follow-up is recommended. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 150 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 
Table: MOls in Response to FOIA2020-110 10:12 Fnday, Februaty 21 , 2020 151 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P218 Pilgrim's Pride Corporation WOD3113 

085219G 

19AUG2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On August 17, 2019 at approximately 2145 hours 

the following failure to adhere to Good 

Commercial Practices was obser1;1ed: While 

observing birds coming out of the pickers, three 

carcass heads were observed pushed against the 

wall next to the metal drain cover where an 

employee was emptying a bucket of paws into a 

drain. The bird heads were red and engorged with 

blood. I did not observe bird carcasses, just the 

heads. I observed the Picker Line for several more 

seconds and then went over to observe conditions 

at the backup cutter. On approach, a live bird was 

observed on the floor near the backup cutter. On 

closer Inspection the bird was observed to under 

the Picker/Kill Line and covered with blood. The 

bird was located directly behind the Line 2 Backup 

Cutter and in front of the· Live Hang entrance 

door. The door to the Live Hang area from the 

Picker Room was dosed. There was no one 

moving to retrieve the bird from the ground. I 

asked a Live Hang employee to notifythat I would like to 

came to the area . He was shown the 

bird. I asked - how a bird would have 

gotten to this point in the Picker Room and he 

stated possibly when the doors were opening or 

closing to Live Hang the bird may have escaped. 

picked up the bird and demonstrated 

it to At that point I observed 

what I thought were two additional bird carcassesin a shallow drain under the Line 2 scalder also 

behind the backup cutter position. This drain is 

below the scalders and possibly connects to the 

Live Hang Department. On closer observation one 

ofthe birds moved and another lifted its had and 

began to look around. I moved closer and looked 

''up'' the drain (towards the portion covered by 

the grate cover and towards the Live Hang 

department) and observed two additional birds at 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 152 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

the exit end ofthe grate· right before the drain 

opened up. I notified- ofthe four live 

birds in the drain and asked him to stop hanging 

and regain control of his Live Hang and Picker 

Room Departments. - had a 

maintenance employee remove the birds from the 

shallow drain. The third of four birds was 

observed to not be breathing. It appeared to have 

drowned in the·shallow drain. I then went to 

observe the birds exiting the feather picking 

equipment again as the backup cutter was no 

longer in his position and was observed to run 

after and grab a bird hanging on the line at the 

scalder to try and get it offthe line before 

entering the scald tank. He was unable to retrieve 

the bird. The bird exited the scalder and was 

observed to have a red engorged head, a shallow 

neck cut and blood staining ofthe neck area. The 

bird was demonstrated to a QA technician who 

was standing behind me who went to the Paw 

Room to get the bird offthe line. She did not 

come back. I then went into the paw room, 

because a few additional birds were observed to 

exit the pickers in the same condition after 

pointing that bird outto QA The individual 

standing in the Paw Room sorting bird carcasses 

was observed to be taking the miscut birds offthe 

line and throwing them into a drain below him. I 

motioned for him to hand me one of the birds and 

he threw it in the drain. I motioned for another 

and he threw that one in the drain as well. At 

that time an employee with a gray hat came 

over. I asked him to tell the employee to hand me 

one ofthe birds. He shook his head in affirmation 

and looked up atthe employee making a motion 

to him to hand him the bird. The employee took 

a miscut bird carcass off the line and threw itin 

the dtain. Neither employee made attempts to 

notify plant management when they observed the 

birds exiting the pickers with poor cuts to the 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 153 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

neck area. I asked the rehang employees to stop 

the evisceration line while I looked for plant 

management. I notified 

o·f my findings and she went to 

speak to the employee located at the exit ofthe 

feather pickers. I notified 

- of my concerns and asked him to take 

measures to regain control of his Live Hang and 

Picker Room departments. The evisceration lines 

were restarted. I requested a meeting with 

establishment management and immediate 

short-term corrective actions to maintain process 

control In the Department for the remainder of 

the shift. I notified the establishment I would 

discuss long term actions with them on Monday 

August 19, 2019, as they needed to identify how 

the birds got out ofthe Live Hang Department 

into the Picker Room drain. Hanging operations 

were released back to- at approximately 

2205 hours when short term corrective actions 

had been provided and the issue had been 

discussed wi.th plant management. The 

establishment later stated the bird found dead in 

the drain may have been a DOA as the backup 

cutter had been instructed to take them off the 

line if he saw them. The dead bird did not appear 

to be a DOA and that would not explain the 

presence of the other four birds in that same 

location. It ls important to treat poultry in a way 

that minimizes a.ccidental injury. Employing 

humane methods of handling consistent with 

Good Commercial Practices can help produce an 

unadulterated product. Observing live and dead 

birds In a drain in the Picker Room Is of concern 

with the establishment's commitment to operate 

under good commercial practices its' ability to 

properly maintain operations in the departments 

where live birds are intended to be handled and 

slaughtered in accordance with Good Commercial 

Practices. The establishment is asked to ensure 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 1S4 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

establishment employees handling live animals 

are aware of the requirements to check all 

animals, in the Live Hang and Picking Room areas, 

for life before they are condemned as dead. The 

establishment is also reminded it is important to 

treat poultry in a way that minimizes accidental 

injury to include proper sorting of live and dead 

birds in the Live Hang/Receiving areas, proper 

euthanasia and proper disposal of condemned 

carcasses. In addition, employing humane 

methods of handling consistent with Good 

Commercial Practices can help produce an 

unadulterated product. Copies ofthis 

Memorandum of Interview (MOI) will be 

distributed tothe establishment, inspection file 

and District Veterinary Medical Specialist per FSIS 

Directive 6100.3. 
.

Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 155 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P218 Pilgrim's Pride Corporation WOD3417 

105426G 

26OCT2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized On October 26, 2019 at approximately 1455 

while conducting a GCP task 

observed the following conditions in the live Hang 

Area. When - walked through the 

hanging pen there were six live birds scattered 

throughout the floor and one DOA. No 

supervisor nor team member were attending to 

the birds on the floor. Upoh walking outside of 

the hanging pen, she notified- ofthe 

birds on the floor and he stated he would take 

care of them. - began performing 

ante-mortem examination and at approximately 

1502, she located two live birds in a cage that was 

tied down and the driver was honking signaling he 

was leaving. - went around to the driver 

and signaled to not move. - came to 

see what the c;oncern was, and she·showed him 

the birds in the cage. He had the fork lift drive 

remove the cages, so the birds could be removed 

from the cage and then it was replaced on the 

trailer. - took the birds and placed 

them in an unloaded cage. Allowing birds to be 

left in cages loaded onto trailers and having live 

and DOA birds on the floor ofthe hanging pen is 

inconsistent with the Agency's expectations of 

Good Commercial Practices. The establishment Is 

asked to ensure establishment employees moving 

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 ofthis 

Memorandum of interview will be distributed to 

the establishment, inspection file and the District 

Veterinary Medical Specialist per FSIS Directive 

6100.3. The issue will also be discussed at the 

next weekly meeting. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 156 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P2186 GEORGE'S FOODS, LLC YJ0472001 

0727G 

27 JAN2020 04COS Poultry Good 

Commercial 

Practices 

Finalized P2186 - George's Foods, LLC At 21:33 on 

1/27/2020 while performing a GCP check in the 

live hang room, 

observed the following instance of poultry 

mistreatment. The· live hang floor and under the 

conveyor belt was covered in an abundance of live 

and dead poultry. When I stepped in the room, 

an employee began picking up all ofthe birds and 

either placing them back on the belt or in the 

DOA bin behind the belt, respectively. I walked to 

the end of the belt where itempties into a yellow 

condemn barrel. When I looked into the 

condemn barrel, I saw the head of a single live 

chicken buried up to the neck In feathers, feces, 

and other debris. I shined my light in its eye to 

ensure it was alive, and it blinked. I immediately 

notified the employee picking up birds from the· 

ground and hedug the bird out ofthe condemn 

barrel. He asked what to do with it and I 

instructed him to put it back on the belt. I then 

notified 

immediately went out to check on the situation. 

The est. determined that the metal guard at the 

end ofthe belt is too short and live birds could 

occasionally get over the guard and fall into the 

condemn barrel. They will discuss making 

adjustments to the guard.

-
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 157 

EstNbr EstName M OINbr Date 

Task 

Code TaskName Status M OI Agenda 

P244 Plainville Brands, LLC GCN23050 

80203G 

03AUG2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized At approximately 0430 hours on 7/31/2019, 

while performing Ante mortem Inspection and 

Good Commercial Practices Verifkation, 

Inspection- observed a concerning 

amount of dead turkeys in the trucks due to 

failure to protect the birds from extreme heat. 

The establishment had held over birds from the 

previous day production. Temperatures reached 

approximately 92 degrees Fahrenheit onTuesday 

7/30. The establishment had moved t railers so 

that there were 2 trailers in each barn to try to 

maximum air flow in the trailers. They also had 

driven the trucks during the nightto provide 

airflow to the turkeys. However, this was 

inadequate to prevent a concerning number of 

dead turkeys (361 DOAs for lot 429 and 864 DOAs 

for lot 428). It was explained to 

that the Poultry Products Inspection Act (PPIA) 

and Agency regulations require that live poultry 

be handled in a manner that is consistent with 

good commercial practices and that this MO! will 

be forwarded to the District Office and the District 

Veterinary Medical Specialist (DVMS). 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 158 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P247 Sanderson Farms, Inc. (Procesing Div) ETG321008 

1428G 

28AUG2019 04C0S Poultry Good 

Commercial 

Practices 

Open At approximately 10:04am on 8/28/19,_ 

while performing an 

unannounced GCP site verification visit/check, 

discovered a Good Commercial Practices (GCP) 

deficiency. After reviewing outside premises, near 

the live bird holding and dumping areas■ 

- entered the Live Hang Room. All 

employees were absent, due to it being a 

scheduled break time. Upon entering Live Hang, 

- found a pile of dead birds with one 

moribund bird comingled among the pile of dead 

birds and two additional birds sitting upon and 

immediately adjacent to the same pile ofdead 

birds. As there was noestablishment personnel to 

immediately notify in the areaimmediately proceeded to the USDA Office, where 

the IIC and he paged and notified 

ofthe GCP deficiency and 

the forthcoming issuance ofthis GCP MOI, 

documenting both the deficiency and notification 

ofplant management. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 159 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P300 Maple· Leaf Farms, Inc. EDK41020 

71502G 

02JUL2019 04C0S Poultry Good 

Commercial 

Practices 

Open At approximately 0520 on 6/28/19, I observed a 

crate that was placed near the hanging belt. In the 

crate, there were five dead ducks that had been 

placed around and on top of one live duck, which 

was at the· bottom ofthe crate. The five dead 

ducks were in rigor mortis, and the live duck was 

alert and obviously alive. I notified 

, who was covering for 

of my findings. euthanized 

the live duck. He also stated that it was 

sometimes difficult to be sure a duck was dead, 

and that could be the cause of a situation like this. 

I told him this duck was obviously alive and could 

not be mistaken for a dead duck, I also described 

how to use the palpebral reflex to help determine 

consciousness, and that if there was any doubt to 

utilize their euthanasia method (at this time 

cervical dislocation) to ensure a duck was dead. I 

then informed- that I would be 

documenting this event in an MOL Directlyafter 

meeting with- , I notified­

- ofwhat had happened. At 

approximately 0330 on 7/2/19, I met wit­

- to ensure he. was aware ofthe above 

situation. He was aware of it, and he stated that 

the employee responsible had a lready been 

counseled. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 160 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P300 Maple· Leaf Farms, Inc. EDK28020 

75116G 

16JUL2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized At approximately 0145 on 7/8/19, while 

performing line inspection duties, I observed six 

ducks at inspection stand #1 that had severe 

antemortem compound fractures and/or leg 

bruises. I notified , who took 

the identified ducks and showed them to■. 

in Live Hold. At approximately 

0230 on 7/10/19, again while performing line 

inspection duties, I observed one duck with a 

severe antemortem compound fracture. I also 

observed an additional duck that had an old 

partially healed fracture that had fused the leg 

joint, forming a twisted immovable Joint; this 

duck was septic, probably due to the fracture and 

resulting synovitis. I met wit 

10/19 at 

■· hotographed the 

t I was unable to 

discern whether the fractures and bruising 

occurred atthe plant, in transit, or atthe farm. If 

the fractures occurred at the plant or in transit, 

they indicated GMP issues that needed to be 

identified and corrected. Ifthey occurred at the 

farm, the ducks would not have been able to walk 

on to the trucks, and the shipment ofthese ducks 

would then be a violation ofthe plant's own SOPs, 

which state that ducks must be able to walk on to 

the truck. I also told- that the duck 

with the old fracture/fused joint would not have 

been able to walk on the truck without extreme 

suffering, so its presence atthe plant indicated 

either an SOP violation or inhumane treatment 

(making It "hobble" on that fracture). I met with 

at approximately 0630 on 

7/10/19 inmy office. He indicated that he would 

investigate these Issues, and stated that some 

recent repairs/modifications had been made to 

the belt that, although it is unknown atthis titne 

where these injuries occurred, would further 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 161 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

prevent fractures like these from occurring at the 

plant. - stated that he has observed 

ducks with old fractures walking, but that the 

duck with the fused joint should have ,been culled 

at the farm. 

P300 Maple Leaf Farms, Inc. EDK59151 

02616G 

16OCT2019 04C05 Poultry Good 

Commercial 

Practices 

Rnallzed At approximately 1154 hrs. on 10/16/2019 while 

watching birds exit the bleeding room to the 

scalder I saw 1 bfrd that was still alive, I took itoff 

the line and gave it to who took 

it to be rehung and stunned. While he was doing 

this a second live bird appeared I immediately 

took1t offthe line and took it to the live hang 

area and gave it tolllto be stunned a second 

time. I returne.d to the line and at approximately 

1158 hrs. a third live 'bird appeared. I took It off 

the line and gave it to who was 

standing nearby. It was then taken to the live 

hang area to be stunned. I observed the line for 

approximately 10 more minutes and did not see 

any more live birds. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 162 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

informed me that at 

approximately 1315 on 2/17/20, while observing 

the animal handling at the entrance tunnel and 

the live hang area, she observed the first 

employee (the one closest to the entrance tunnel) 

repeatedly grab multiple ducks with his hands and 

push the ducks backwards on the moving 

conveyor toward the entrance tunnel - he neither 

slowed nor stopped the conveyor to facilitate 

having ducks in front of him to hang. This 

conduct not only constitutes inhumane handling 

and increases .fractures and bruising, but also 

violates the plant1

s own SOPs. I discussed this 

iss(le with 

in the Feather Room at approximately 2300 on 

2/17/20. I asked - to inform 1st shift 

plant management of the issue, and also asked 

- to reinforce the proper procedures with 

his 3rd shift personnel (I have not observed this 

conduct on 3rd shift). This issue will also be on the 

weekly meeting agenda for 2/19/20. 

P300 Maple· Leaf Farms, Inc. EDK28020 

21519G 

19FEB2020 04C05 Poultry Good 

Commercial 

Practices 

Open 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21, 2020 163 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P300 Maple Leaf Farms, Inc. EDK24020 

23420G 

20FEB2020 04C0S Poultry Good 

Commercial 

Practices 

Open 

P325 Tyson Foods, Inc. YDM07230 

60705G 

05JUN2019 04COS Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

On June 5, 2019 at approximately 1650 while 

conducting a GCP tas 

observed the following conditions in the Live Hang 

department. There were two condemn barrels at 

the end ofthe DOA bin. - noticed the 

birds in one barrel were moving up and down 

signifying the possibility ofa live bird underneath. 

Upon further inves,tigation_, she removed 

approximately 3 layers of birds and found a live 

bird breathing. - took regulatory control 

action and stopped live hang from hanging any 

birds until the barrel was cleared ofany further 

live birds mixed with the DOA birds. I notified 

humane handling. 

stated that the team member had just been up to 

HR due to some concern over pay that was owed 

to him. The concern was when­

- arrived, there was no one attending to the 

carcasses in the condemn barrels. The mixing of 

live birds with dead birds in the condemn barrels 

can suffocate the live, weak birds and is not 

consistent with the Agency expectations for 

handling oflive poultry. The establishment is 

asked to ensure establishment employees 

handling live animals are aware of company 

policies regarding live bird handling. 

Employing humane methods ofhandling 

consistent with Good Commercial Practices can 

help produce an unadulterated product. Copies 

ofthis Memorandum ofinterview will be 

distributed to the establishment, inspection file 

and the District Veterinary Medical Specialist per 

FSIS Directive 6100.3. The issue will also be 

discussed at the next weekly meeting. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 164 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P325 Tyson Foods, Inc. YDM23230 

63306G 

06JUN2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On June 6, 2019 at approximately 1545 while 

conducting a GCP task 

observed the following conditions in the Live 

Receiving Area. She was performing ante-mortem 

examination on the trailer that had just been 

placed in live receiving. There was one cage 

approximately midway on the trailer that had 

three doors open. - noticed the birds 

sitting on the· doors and not in cages. Upon 

further investigation, she noticed a total of5·6 

birds outside of a bottom cage on three different 

levels (or sections). They were sitting on the cage 

doors and trailer bed. One bird had one ofits legs 

stuck between the door and an adjacent cage. 

immediately notified Nightshift 

of the concern with live 

bird humane handling and transport. -

and came out to 

the trailer and began removing the birds that 

were sitting on the cage doors they could reach. 

They instructed the fork lift driver to remove the 

cag_e on top ofthe one with the open doors to get 

to the birds and close the cage doors. While 

removing the top cage adjacent damaged cage, 

the fork lift driver manipulated both the top and 

bottom cage onto the bird's leg that had been 

pinned. - immediately instructed them 

to stop. A team member came over to release the 

bird's leg and remove it from the cage door. The 

establishment removed the adjacent cage and 

the remaining birds before. closing the cage doors. 

At the time of the observation described above, 

there were no establishment employees attending 

to the open cage or attempting to remove the 

birds who had come out of the cage onto the 

doors. Allowing birds to be outside cages and be 

pinned between cages is inconsistent with the 

Agency's expectations ofGood Commercia_l 

Practices. The establishment is asked to ensure 

establishment employees moving live animals are 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 165 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

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 FSIS Directive 6100.3. The issue 

will also be discussed at the next weekly meeting. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 166 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P325 Tyson Foods, Inc. YDM28210 

60713G 

13JUN2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized On June 13, 2019 at approximately 1530 while 

conducting a GCP task- observed 

the following conditions in the Live Hang 

department. Approximately five DOA birds were 

on the floor to the side of the metal DOA bin and 

approximately 10 live birds on the floor in the 

hanging pen throughout the floor. 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 two live birds 

mixed in with the DOAs in the bin. Those birds 

were underneath the layer of dead birds. I notified 

of the concern with live 

bird humane handling. 

informed- that the normal team 

member that picks up live birds and removes 

DOAs from the bin was not present this evening 

and the establishment was using someone new in 

that position. While- continued her 

GCP task at 1545, a live bird was found under the 

stunner that was soaked and huddled up. No one 

was attending to or removing the bird _ 

took regulatory control action and stopped the 

live hang lines. was notified of 

the bird under the stunner. He removed the bird 

from under the stunner and- released 

regulatory control back to the plant. 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 oflive 

poultry. Allowing the DOA bin to fill two three 

layers of birds deep with overflow onto the floor is 

indicative ofa loss ofprocess 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 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 167 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

1------ P325 +-------------------+-- Tyson Foods, Inc. ----+- YDM29230 

64921G 

------+- 21JUN2019 ---- 04COS +------ Poultry Goo·d 

Commercial 

Practices 

+----- Finalized 

Practices can help produce an unadulterated 

product. Copies ofthis Memorandum of 

interview will be distributed to the establishment, 

i'nspect ion file and the District Veterinary Medical 

Specialist per FSIS Directive 6100.3. The issue 

will also be discussed at the next weekly meeting. 

1--- W hi I e performing presentation checks at about 

1640 there were 2 cadavers hung back for 

veterinary disposition. Upon further investigation, 

there were no cuts on the necks of either bird. 

Exiting the picking room an additional cadaver 

was observed without a neck cut. -

was notified ofthe 

cadavers. The presence of birds that are not 

thoroughly bled out and cadavers that would have 

entered the scald tank while still breathing 

constitute a concern with 381.65(b) and good 

commercial practices. ) 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 168 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P325 Tyson Foods, Inc. YDM44230 

91619G 

19SEP2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On September 19, 2019 at approximately 1706 

while conducting a GCP task 

observed the following conditions in the Live 

Receiving Area. When- walked outside 

the hanging pen there was a bird on the side of 

the track that cages run to the dumper. She 

notified a team member because no supervisor 

was available at the time and there was a concern 

for the safety of the bird. She began performing 

ante-mortem examination and at approximately 

1710, another bird was observed on the same side 

of the track that moves cages 

was notified ofthe concern and 

removed the live bird from the area. At 

approximately 1714, one live bird was visualized 

inside a cage that was loaded onto a trailer after 

being dumped. was notified of 

the concern, had the forklift driver remove the 

cage from the trailer, removed the bird from the 

cage, and took it into the hanging pen. At 

approximately 1716, there was one cage 

approximately midway on a trailer in live 

receiving that was approximately half unloaded 

that had a cage door open and birds were sitting 

on the door outside ofthe cage. -

noticed the birds sitting on the door and not in 

cages. She immediately notifie 

of the concern with live bird humane handling 

and transport. came out to the 

trailer and placed the birds back into the cage and 

shut the door. As- entered the hanging 

pen there were 19 live birds and three dead birds 

on thefloor. pointed them out to 

and he· 

picked up the birds. At the time ofthe 

observations described above, there were no 

establishment employees attending to the open 

cage or attempting to remove the birds who had 

come Gut ofthe cage onto the doors, removing 

the birds from the side of the track cages were 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 169 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

moving, removing the bird from the cage loaded 

onto the trailer, nor picking up the live birds on 

the floor ofthe hanging pen. Allowing birds to be 

outside cages, left in cages loaded onto trailers, 

and having live and DOA birds on the floor ofthe 

hanging pen is inconsistent with the Agency's 

expectations ofGood Commercial Practices. The 

establishment is asked to ensure establishment 

employees moving 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. 

ofthis Memorandum of interview will be 

distributed to the establishment, inspection file 

and the District Veterinary Medical Specialist per 

FSIS Directive 6100.3. The issue will also be 

discussed at the next weekly meeting. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 170 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P325 Tyson Foods, Inc. YDM45171 

20203G 

03DEC2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized At approximately 2130 hours, 27th of November 

2019, railed out one 

suspected DOA (Dead on Arrival) young chicken. 

I, Relief inspected the 

carcass and observed a strong odor of 

putrefaction, dark red and congested viscera, limp 

neck, and reddish discoloration ofthe carcass. I 

showed the suspected DOA toand the latter 

concurred it is a DOA. At approximately 2220 

hours, 27th of November 2019, I, Relief SPHV 

railed out one DOA (Dead on Arrival) young 

chicken. The carcass emits a strong odor of 

putrefaction, has dark red and congested viscera, 

friable liver which easily disintegrated to light 

pressure, limp neck and reddish discoloration of 

the carcass. - inspected the carcass 

and insisted it is not a DOA but a cadaver. -

vehemently 

challenged the basis of my DOA disposition. At 

approximately 2015 hours, 30th of November 

2019, railed out one 

suspected DOA (Dead on Arrival) young chicken. 

I, inspected the 

carcass and observed a mild odor of putrefaction. 

There is only one lobe of friable liver which is 

congested and dark red in color. The gizzard is 

congested with grayish and reddish discoloration. 

The interior walls ofthe cavity is dark red in 

color. The neck is limp. At approximately 2100 

hours, came to 

the USDA office and argued about my disposition. 

Plant Manager Brian Shankle quietly listened and 

before leaving, told me that DOA is a serious 

matter to the plant. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 171 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P33900+V3 

3900 

Foster Farms NHH44091 

23405G 

OSDEC2019 04COS Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

On the morning of December 5, 2019 at 

approximately 0655 hours while performing Good 

Commercial Practices verification activities in the 

Live Receiving area at establishment P-33900, a 

plant employee was observed removing two live 

chickens that had failed to dump from the cage 

and throw them onto the hang belt. Minutes 

later, the same employee was observed 

attempting to remove a live chicken that had 

failed to dump because its wing was stuck 

between the cage bars, by placing a metal rod 

with a hooked end around the hock and forcibly 

trying to pull the bird out ofthe cage by jerking 

on the rod. When that failed the employee 

reached into the cage, freed the wing and 

removed the bird, A second employee was 

observed removing two live chickens and placing 

them on the top ofthe cage and then dumping 

them onto the hang belt. 

, was immediately notified of 

the observations described above and was 

informed that all poultry should be processed 

usfng Good Commercial Practices. -

stated to prevent recurrence the employees 

would be retrained. The meeting adjourned and 

- went to the live receiving area to 

initiate corrective actions. Nofurther issues were 

observed in a subsequent observation of the area 

at approximately 1245 hours. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 172 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P34668 Simply Essentials Poultry, LLC SFJ381507 

5525G 

25JUL2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized July 19, 2019 DOAs and plant rejects. Poultry lot 

information: Lot 1- 3246 DOA and 1675 disposed 

carcasses. Lot 2- 2751 DOA and 2645 disposed 

carcasses. The temperature was in the mid 90s 

with high humidity. Viscera pacs at the leucosis 

inspection station showed the lungs and viscera to 

appear healthy. We experienced assorted 

breakdowns lasting approximately 41/2 hours 

causing birds to be held in the CAS CO2 slaughter 

system and on the line. Some ofthe birds thrown 

away at live hang appeared to be in a state of 

advanced decomposition indicating that they 

were not newly deceased. Examirie the reasons 

for the high DOAs that occurred on 7/19/19, and 

develop a plan to prevent recurrance. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 173 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P445 Wayne Farms, LLC FKA501405 

1328G 

28MAY2019 04COS Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

At approximately 1600, as I went to the live 

receiving department to perform my good 

commercial practices task, I observed an 

unusually large number of Dead on Arrival birds 

(DOA's). The DOA vat was full to overflowing, if 

you tried to place another bird to the vat, that 

bird would fall to the floor. Additionally, there 

was a pile ofDOA's next to the DOA vat that was 

approximately 8 feet long, 3 feet wide and 2 feet 

deep. Also, there was a plant employee 

continuously throwing DOA's from the hanging 

area through the plastic strips onto the pile. I 

found , in the 

evisceration department, and notified her of my 

findings. She went out to live receiving to gain 

control ofthe operation - had a plant 

employee empty the DOA vat and dispose ofthe 

rest ofthe DOA's. She was also monitoring the 

belts bringing the live birds to the people hanging 

the birds on the shackles, sinee this is wt,ere she 

found the cause of the increased DOA's to be 

coming from. This seemed reasonable because 

the cages oflive birds did not have many visible 

DOA's in them, maybe one DOA per 10 cages. 

, was present and he 

started dousing the birds in cages on the trucks 

with water (in addition to the fans and water 

mist) in an effort to keep them cool. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 174 

Task 

EstNbr EstName MOINbr Date Code TaskName Status 

P45910 SANDERSON FARMS, INC GRl082001 07JAN2020 04C0S Poultry Good Finalized 

4907G Commercial 

Practices 

MOI Agenda 

At approximately 2057 hours 

and myself, were performing 

a Good Commercial Practice task and observed a 

forklift operator place a cage full of chickens on 

the deck. He proceeded to tear the top right door 

off using the forklift to rip it off. At that moment I 

told _ , "I hope he doesn't plan to raise 

that cage up and take ittothe cage dumper 

which could cause the chickens to fall out of the 

cage and onto the deck." At that moment the 

forklift operator raised the cage up with the 

forklift to it's full height, which appeared to be 

approximately 12-15 feet in the air, as far as 

myself and- could surmise. At that 

point he started to move forward and a live 

chicken fell out of the cage and dropped to the 

deck, landing on it's head and side body with a 

loud thud. We observed it fluttering a few times 

on the ground before the forklift operator lowered 

the cage and picked the bird off the deck and put 

it back into the cage. I stopped the forklift 

operator and informed him that I witnessed the· 

bird fall from the cage and the trauma that the 

bird suffered from the fall would most likely lead 

to it's mortality. The forklift operator told me that 

the bird wasn't dead. He proceeded to take the 

cage over to the right side of the dumper at which 

point I don't know What he did with the birds in 

the cage. I had informed him that I was going to 

let 

know and document this in an 

MOL I proceeded into Live Hang and found ■ 

- and took him outto Live Receiving and 

explained what myself and- witnessed. 

- told me that sometimes the cage doors 

get stuck and they have to rip them off to get the 

birds out of the cage. I informed him that I had no 

problems with them doing whatever they nee.d to 

do sothey can dump the chickens out properly, 

however, the forkli~ operator should have taken 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 175 

EstNbr 

P45939+V4 

5939 

EstName 

Petersburg Poultry Processing 

MOINbr 

CZJ320905 

4623G 

Date 

23MAY2019 

Task 

Code 

04C0S 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

the cage over to the side ofthe dumper and 

placed the live chickens, from the broken coop, 

into anotherone that was secure so that the birds 

wouldn't fall out during the cage dumping 

process. The forklift operator came over to us at 

that point and told me that there were no dead 

birds in the cage. At this point there were already 

two cages with birds staged on the left side ofthe 

dumper with a bird, outside the cage, sitting on 

top ofthe cages and another live bird sitting on 

the deck, out oftheir cages, sitting nextto the 

cage. I informed- that this is a recipe for 

disaster and these birds need to be properly 

secured in their cages or there would be risk of 

them getting run over leading to further issues. He 

informed me that he would take care ofthis. This 

Memorandum of Interview is to documentthe 

observations and discussion that myself, ■ 

had between USDA 

FSIS and Establishment Management,_

.. 

Upon arrival at Petersburg Poultry Processing for 

slaughter processing on May 22, 2019 while 

which, after confirming with establishment 

employees, were left uncovered In the rain 

overnight from the previous day , they were the 

remainfng chickens that were not slaughtered 

from the day before. After the slaughter was 

finished the establishment counted 83 DOA 

chickens that had passed as a result of being left· 

unprotected from the inclement weather. 

performing the antemortem check on the 

chickens to be slaughtered the 

observed multiple deceased chickens in the crates 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 176 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P4602A NEW MARKET POULTRY, LLC YCG19140 

60121G 

21JUN2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On 6/21/2019 at approximately 1005 hours, ■ 

while performing the Good Commercial 

Practices verification task noticed a live hung hen 

pass the area on the kill line where the backup 

killer was stationed lift its head, look left and 

right, and blink. I took regulatory control action 

by stopping the hanging area line. I informed the 

lead supervisor of the issue and we both observed 

the backup kill find and slaughter the chicken 

with a knife cut across the throat area. The lead 

continued to monitor the backup killer until he 

was satisfied that no more birds were passing the 

final checkpoint uncut. I then informetlllll 

ofmy 

observations. Later, during the weekly meeting, 

establishment management mentioned adding an 

emergency stop button to the backup killer's side 

ofthe line so that he could more quickly stop·the 

line if signaled. Had I not stopped the line, it is 

likely the live chicken would have entered the· 

scalder water while alive and breathing producing 

a true cadaver [381.6S(b)]. Such a cadaver was 

previously on May 6, 2019. Evidence of a 

developing trend of loss of process control such 

that true cadave-rs are produced may result in a 

NR for 381.65(b). 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 177 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P4602A NEW MARKET POULTRY, LLC YCG18100 

74315G 

15JUL2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On July 15, 2019 at approximately 0958 hour I, 

while performing a Good Commercial 

Practices v:erification task inspection of Lot 2 

noticed traffic passing the establishment swerving 

towards the miclline and opposite lane. I looked 

further down the road and saw a loose rooster 

walking on and offthe lane nearerthe officlal 

premises. I Informed an area lead supervisor of 

the issue and observed him capture the rooster 

and take itto the live hang area. Later at 

approximately 1025 hours while gjving an online 

inspector a break and performing postmortem 

inspection ofeviscerated carcasses on Line 1 

Station 1, I identified a heavy fowl hen carcass 

with a diffusely bright "cherry" red appearance 

and attached neck and head. Therewas no cut in 

the throat area of the carcass. When inverted, a 

small amount of fluid freely drained from the oral 

cavity. I judged this presentation to be consistent 

with a "true cadaver," a bird that entered the 

scalding tank without being slaughtered, and 

informed 

of my noncompliant 

finding. I observed the QAM take the cadaver to 

the live hang and slaughter supervisor for 

corrective instructions. These observations are 

suggestive of suboptimal process control in the 

establishment's obligation to uphold 9 CFR 

381.65 (b), which stipulates thatpoultry animals 

are not to die by any means other than slaughter 

(such as being struck by a moving vehicle) and 

that they are not to enter the scalding water while 

still breathing or without having been first 

sufficiently exsanguinated. Greater numbers of 

loose birds leaving the official premises or 

multiple· identifications of true cadavers would 

represent a loss of process control meriting a 

noncompliance record (NR) documentation. 

Deficiencies in the establishment's GCP were 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 178 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

previously documented on 5/06/2019 

(YCG1013054606G), 6/21/ 2019 

(YCG1914060121G), and 7/09/2019 

(YCG5210075609N). 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 179 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P46091 Ozark Mountain Poultry, Inc. FAA02210 

94315G 

15SEP2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

On 7 /22/19 at approximately 8:00 pm I observed 

a cadaver, decapitated, on tine 1 exiting the 

stunner prior to the neck cut station in the picking 

room. I requested an establishment employee to 

remove the •cadaver from the line and dispose of it 

in an inedible container. On 3rd shift on 

7/24/2019 at approximately 3:00 am I again 

observed a cadaver, decapitated, exiting the 

stunner on line 1 prior to the neck cut station in 

the picking room. I requested an establishment 

employee to remove the cadaver from the line 

and dispose of itin an inedible container. I 

ofmy 

d 

I 

observations. later informed me that 

they had checked all their equipment and 

determined that their equipment was not the 

cause ofthe mutilated chickens. He also explained 

to me that he thought the chickens were being 

brought in from the farm with the injuries. On 

3rd shift on 7/25/2019 at approximately 4:00 am 

I observed several more, approximately 15, 

mutilated chickens, legs torn open and torn off, 

on the line 1 conveyor in live hang. Upon further 

inspection ofthe line 1 equipment I observed that 

the plastic guards next to the conveyor needed 

repair and were coming loose from the metal wall 

they were attached to. I also observed parts of 

mutilated chickens (legs and feet) still stuck 

underneath the guard. I determined these 

partially detached plastic guards were the likely 

cause ofthe mutilated chickens and plant 

management agreed with my observations. The 

establishment made repairs to the equipment. I 

did not observe further mutilation, during that 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 180 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

shift,. after the repairs were made. On 9/08/2019 

at 7:41 pm I observed a cadaver, the posterior 

head was mutilated, exiting the stunner on line 1 

prior to the neck cut station. I requested an 

establishment employee to remove the bird from 

the line and dispose ofItin an inedible container. 

I notified 

of my observation. That 

same shiftat 12:06 am I observed a cadaver, with 

a mutilated neck, exiting the stunner on line 1 

priorto the neck cut station. I requested an 

establishment employee to remove the bird from 

the line and dispose ofit in an inedible container. 

I notified of my 

observation. Less than1⁄2 an hour later, at 12:30 

am. I observed a dying mutilated chicken on the 

floor in live hang area next to line 1. The chest 

area was mutilated exposing the breast muscle. I 

notifie of my 

observation and directed them to humanely 

euthanize and appropriately dispose ofthe 

chicken. I also asked 

to have the equipment on line 1 checked for any 

defects that could cause the mutilation. He 

informed me that they had checked all the 

equipment and found no cause for the mutilation. 

Later that same shift at 2:40 am I observed a 

chicken with the neck area mutilated but still alive 

exiting the stunner on line 1 prior to the neck cut 

station. I notified ofmy 

observation. On 09/09/2019 at approximately 

11:00 pm I observed a chicken exiting the stunner 

on line 1 prior to the neck cut station thathad the 

leg area mutilated. I notifie~ 

of my observation. I again askecfll" .-

ifthey had checked the 

equipment on line 1 for defects during the 

previous shift, he again assured me that the 

equipment had been checked and that they found 

no concerns with their equipment. On 3rd shift 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 181 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

on 09/09/2019 at approximately 4:00 am I 

observed a dead chicken In the DOA bin that had 

the leg and back areas mutilated and exposing the 

viscera on the outside ofthe body. I notified 

f my observations. I asked Area 

Supervisor ifthey had checked their equipment 

for any repairs needed that could be causing the 

mutilation. He informed me that they had 

checked their equipment the prior shift and found 

their equipment was in good repair and not 

causing the injuries. Upon further inspection I 

observed a beak, wattle and skin from the head of 

a mutilated chicken and stuck under the plastic 

guard next tothe conveyor belt on line 1. I further 

inspected the line and found 2 more areas that 

were causing the mutilation. Despite the 

establishment's assurance on at least 3 prior 

occasJons that their equipment on line 1 had been 

thoroughly checked for problems that could be 

related to the'mutilation of poultry on line 1, the 

mutilation of birds continued, the cause ofwhich 

was ultimately determined to be the equipment 

that was in poor repair and had not been properly 

maintained. On 3rd shift of09/09/2019 at 

approximately 4:00 am I met with 

I reminded all present that the PPIA and 

the 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. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 182 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P46374 Sanderson Farms, Inc. Tyler Processing Division AQ1400804 

5124G 

24APR2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

Est. P46374, Sanderson Farms Tyler Processing, 

April 23, 2019, 1337 hours. In attendance: 

s also present. At approximately 0545 

hours, 23rd ofApril 2019,while performing 

Poultry Good Commercial Practices verification 

task, I observed at pre-scald two young.chickens 

still breathing. who is right 

behind me immediately stopped the line when I 

said ''still breathing". instructed 

the plant neck cutter to make a cut on the neck of 

the two young chickens still breathing which 

apparently have cut on their necks already. Then, 

adjusted the blades ofthe kill 

machine accordingly. told the 

plant neck cutter to be more alert to ensure that 

all the necks ofthe young chickens are properly 

cut. The plant neck cutter is a back up to the kill 

machine. asked ifwhat I saw is 

nota reflex reaction ofthe bird who may already 

be dead. - said the two 

aforementioned birds open their beaks gasping 

for breath with eyes wide open and the other one 

flapping its wing!i. requested if 

MOI may not be issued as due process with the 

consideration that t he plant has notfound 

cadaver on the line except for 3 birds on the 3rcj 

week of operation. - replied that IPP 

would give the opportunity for the 

establishment's system to work before making a 

compliance determination however, the 

establishment does not have GCP monitoring or 

procedures at pre-scalder which consequently 

cannot prevent these birds from entering the 

scalder while still breathing. - also said 

that under NPIS, FSIS is not monitoring the cause 

of condemnations. - added that based 

on FSJS Directive 6110.1, the aforementioned 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 183 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

incident has to be documented in an MOI. 

reminded - thatthe 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 ot her 

than slaughter. I recommended thatreview Federal Register Notice Vol. 70, No. 187, 

published September 2005 [Docket No. 04-037N) 

for FSIS recommendations coRcerning treatment 

of live poultry before slaughter and provided him 

a copy of this document. I also recommended that 

- review FSIS Directive 6110.1 which is 

Verification of Poultry Good Commercial 

Practices. I notified- that this MOI will 

be forwarded to the District Office and the District 

Veterinary Medical Specialist (DVMS) in case 

additional follow-up is recommended. 

Respectfully, 

P46374 Sanderson Farms Tyler Processing. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 184 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P46374 Sanderson Farms, Inc. Tyler Processing Division AQl330604 

0426G 

26APR2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

Poultry Mistreatment Meeting at Est P-46374, 

Sanderson Farms - Tyler in April 16, 2019 at 

approximately 1000 hours. 

At approximately 

0900 hours, on 15th ofApril 2019, while 

performing Poultry Good Commercial Practices 

task on Lot 2, I, _ sensed the live 

chicken dumper dump a new batch of young 

chickens sooner than usual. I was beside the wall 

looking through the opening and observing few 

young chickens left behind in the cage. So, I did 

not have a vis.ual on what actually happened. 

Then, I positioned myself strategically and 

watched carefully the next dump and I confirmed 

that the dumper is dumping young chickens over 

other young chickens on the first belt. I notified 

accordingly. When I went 

outside to check on few young chickens left over 

in the cage, the dumper motioned on me to climb 

up the control stand and he showed me that the 

first belt is a lot slower than the second belt. He 

explained that it is the reason why approximately 

25% of the dumped young chickens are able to 

walk back to the first belt. I said, it is not a reason 

to dump new batch of young chickens on other 

young chickens. later told me 

that the maintenance crew is adjusting the speed 

of the belt. I recommended to- to 

review the Federal Register Notice Vol. 70, No. 

187, published September 2005 (Docket No. 

04-037N). I also notified 

- 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 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 185 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P46374 Sanderson Farms, Inc. Tyler Processing Division AQI041305 

0931G 

31MAY2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

At approximately 1325 hours 011 30th of May 

2019, while performing Poultry Good Commercial 

Practices task, I, observed the 

following: One young chicken still breathing at 

pre-scalder for Lines 1 and 2 which I pointed to 

He had the line stopped and 

pulled out the breathing young chicken off the 

shackle. Closer examination revealed uncut 

trachea, esophagus and right jugular vein and 

right carotid artery. The vent and thoracic cage is 

rhythmically moving. After few minutes, one 

young chicken still breathing is also observed at 

pre-scalder for Lines 3 & 4. had 

the llne stopped but the breathing young chicken 

is unreachable on the second shackle next to the 

scalder. It went to the scalder flailing. One day 

before, 29th of May 2019, atapproximately 0900 

hours, while performing Poultry Good Commercial 

Practices task, I, observed the 

following: One young chicken still breathing at 

pre-scalder. This time, there is no supervisor that 

magically appears behind to pull out the 

breathing young chicken before it goes to the 

scalder. The back up neck cutter stopped the lir:ie 

and promptly cut the head off of the breathing 

young chicken. Few days before, 25th of May 

2019, atapproximately 0840 hours, while 

performing Poultry Good Commercial Practices 

task, I, observed the 

following: One young chicken still breathing at 

pre-scalder. - appeared from 

behind and pulled out a different bird from the 

shackle. Turned out, the one he pulled out is also 

breathing - flailing, vent and rib cage moving 

rhythmically for at about 2 minutes and 

eventually stopped moving. The breathing young 

chicken I saw entered the scalder flailing. The 

aforementioned incidents are evidences of 

isolated instances in which a bird was still 

breathing when it entered the scalder or about to 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 186 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

enter the scalder, but the system is otherwise in 

control. At approximately 1245 hours, 31st of 

May 2019, I summoned 

to notify hin, of these findings. 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 to die from causes 

oth~r than slaughter. I recommended that Illreview 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 co"py ofthis document. I notified 

- that this MOI will be forwarded to the 

District Office and the District Veterinary Medical 

Specialist (DVMS) in case additional follow-up is 

recommended. Respectfully, 

IIC P46374 Sanderson Farms Tyler 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 187 

EstNbr EstName MOtNbr Date 

Task 

Code TaskName Status 

P468 Peco Foods, Inc. JVD420606 

1804G 

04JUN2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

On June ·3, 2019 at approximately 0950 hours, I 

observed a trailer containing 

live chickens underneath one ofthe 

establishment's live haul sheds that had ten open 

cage doors. The opening ofeach ofthese cages 

was located between each stack of cages. 

Numerous birds were sitting on the open cage 

doors; outside ofthe cages. Additionally, three 

live birds had their heads caught in the cage 

doors, presumably after the cage door opened 

and then closed back. I notified 

ofthe situation. 

immediately attended to the hung birds by 

placing them back in the cages. Hethen had the 

trailer moved to where the birds are unloaded via 

forklift and transported to the dumping area. The 

damaged cages were then carefully lowered by 

forklift from the trailer and the birds were placed 

back in the cages and the cage do0rs closed. Upon 

lowering one cage that had three separate open 

doors, one chicken did fall to the ground upon the 

cage being lowered by the forklift. The bird did 

not appear harmed and was placed back in the 

cage by an establishment.employee. All cages on 

this trailer were transported to the cage dump 

area. informed me that 

this was likely caused by the driver ofthe trailer 

slamming on the brakes en route to the 

establishment.- then ensured that the 

driver retraced his route to make sure there were 

no live chickens left along the driving path. He 

also discussed the situation with the live haul 

crew. I informed- that I would discuss 

this situation with my supervisor and that this 

does not follow Good Commercial Practices for 

poultry and may result in a memorandum of 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 188 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P46826 SHENANDOAH VALLEY ORGANIC BOK37110 

93303G 

03SEP2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

At approximately 0855 hours, while performing 

good commercial practices (GCP) verification, I 

entered the picking room 

and noticed that the kill line had been stopped by 

the establishment. I entered the blood room and 

saw approx. 5 live chickens on the floor near the 

back-up head puller's stand. Many (at least 15) of 

the chickens hanging on the line had not been 

stunned or cut. Also, many of the stunned 

chickens on the line had no neck cut. -

was manually cutting the 

necks of the stunned chickens and pulling the 

non-stunned, non-cut chickens off the line. I 

returned to the picking room to inspect the birds 

hanging on the line prior to the scalder. The 

establishment started the kill line and I saw one 

chicken that was alive and breathing, not stunned 

or cut, moving towards the scalder. I pulled the 

chicken off the line just before it entered the 

scalder. was 

present at the time. I returned to the blood room 

and saw that the establishment had again 

stopped the kill line. I told 

- that I had pulled a live chicken offthe line 

just prior to it entering the scalder. I was 

informed that the kill blade had stopped working· 

and maintenance personnel were repairing it. I 

ii 

son 

d. I 

were either manually slaughtered or (ifnot 

stunned or cut) returned to theto the beginning 

of the line to go back into the normal slaughter 

process. The kill line was restarted at 0902 hours, 

and I verified that the stunner and blade were 

functioning appropriately. I observed-
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 189 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

verbally counsel , and 

the back-up cutter. 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 ofthe carcasses and ensure 

that breathing has stopped prior to scalding.'' 

Since this is an isolated incident, it will not be 

registered as a noncompliance record because the 

establishment recognized and corrected the issue, 

and the process appears to be in control; no 

further live birds were observed entering the 

scalder. All precautions should be taken by the 

establishment to adhere to slaughter that is 

consistent with good commercial practices. Any 

deviation from such is unacceptable. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 190 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P46897 IHSAN FARMS, IIC SVH43091 

11205G 

05NOV2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

Memorandum of Interview 

November 

05,2019 

lhsan 

Farms, LLC 

P-46897 

Princess 

Anne, MD Attendees: Mr. Ted Zadeh, 

Plant Manager, P--46897, lhsan Farms ■ 

ours in th 

ess Anne, 

nagement 

management acknowledged they understood my 

offlcial 'Capacity through the conversation. The 

purpose of the meeting was to communicate my 

findings of a poultry good commercial 

practices/ poultry welfare concern that I observed 

within the establishment. I said that at 0917 

hours I was inspecting the area around the live 

hang conveyor belt inside the establishment 

facilities. I looked inside a yellow condemn barrel 

and saw approximately 8 birds that had pink 

denaturant appropriately applied to their outside 

surfaces. I observed one bird to move its head 

and make agonal-type gasps. This bird was at the 

bottom of the pile of birds. I immediately showed 

the bird and told him it appeared to be still alive. 

After he removed it from the barrel, t he bird 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 191 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

continued to exhibit movements of its head. I 

suggested that it be euthanized since itcould not 

be slaughtered on the production line after 

denatured; he passed it over to the person who 

slaughters birds and the bird was killed/ bled out 

manually. I looked inside the condemn barrel 

again and saw another bird towards the bottom 

moving its head/ gasping. I showed this to . 

- who took the bird and it was also 

killed and bled out manually. I reminded Mr. 

Zadeh that the Poultry Products Inspection Act 

and Agency regulations require that live poultry 

be handled in a manner that is consistent with 

good commercial practices and that they not die 

from causes other than slaughter. I tole him that 

there are no regulatory requirements for a 

euthanasia protocol to be written; however, the 

establishment should have a plan (written or not) 

to address birds that cannot be placed onto the 

slaughter line (non-ambulatory, weak birds). I 

notified Mr. Zadeh that this MOI will be 

forwarded to the District Office and the District 

Veterinary Medical Specialist (DVMS) in case 

additional follow-up is recommended. I attest 

that this memorandum includes all the 

information discussed during the meeting to the 

best of my knowledge. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 192 

EstNbr EstName MOtNbr Date 

Task 

Code TaskName Status MOI Agenda 

P47016 The Best Dressed Chicken, Inc. OFG13140 

10823G 

23JAN2020 04C0S Poultry Good 

Commercial 

Practices 

Finalized On this date of record at approximately 1300 

hours, I went into the picking room to perform 

Good Commercial Practices Verification task. 

While standing between the two picking 

machines, I observed five red carcasses with heads 

still attached and engorged and no incision mark 

on the necks exit picker one. Two ofthem were 

separated by one carcass that had been properly 

bled out. The other three occurred at random 

sequence within 15-20 carcass time period that 

occurred 5-7 carcasses after the first two were 

pulled. I then went to the blood trough and 

observed a live bird with an uncut neck.entering 

the scalder. At that moment, 

stepped in and I showed 

him the cadavers.He went to the kill machine 

technician with the cadavers to determine the 

cause ofthe issue. I then observed another lfve 

bird that was conscious and without an incision 

on it's neck enter the scalder. I observed the line 

for live birds for another minute and the blood 

trough and saw no more live birds heading to the 

scalder. - determined that the cause of 

the cadaver issue was human error and space 

design. The kill machine att~ndant was not able 

to see the birds due to excess condensation on his 

face shield. Additionally, the attendant was 

working on the side of the machine that impeded 

his ability to see ifthe birds were fed Into the 

machine correctly. As corrective action,■ 

- cleaned the attendant's face shield and did 

hourly monitoring ofthe attendant and process. 

The monitoring continued throughout the next 

day. - and I met after the end of 

slaughter to discuss the issue. - ~ _ 

preventative measure, is workingwffh­ , to provide the 

necessary changes to the area so that the 

attendant can work on the opposite side ofthe 

machine. While the cadaver issue was discussed 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 193 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

at the weekly meeting with the establishment, 

this MOI serves as separate documentation ofthe 

event ofthe day. This MOI will be forwarded to 

the District Office and the District Veterinary 

Medical Specialist (DVMS) in case additional 

follow up in necessary. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 194 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P47016 The Best Dressed Chicken, Inc. OFG42080 

10827G 

27JAN2020 04C05 Poultry Good 

Commercial 

Practices 

Finalized It was observed on this day, January 21, 2020, at 

approximately 1010 hours, that there were 

several cadavers making itto the inspection stand 

(seven (7) within 5 minutes). These cadavers 

were bright red in c;olor and had there heads and 

necks still attached with no identifiable incision 

mark on the necks. There were also numerous 

carcasses that were pink in color with red wing 

tips and red upper breast as well as red necks with 

some attached heads. Just prior to that at 

approximately 0955 hours, while completing a 

Good Commercial Practices verification task, I 

had observed one live bird with an uncut neck 

enter the scalder. The carcasses on the bleed line 

also appeared to have the bleed out cuts further 

back on the neck. I notified 

, of my observations both 

on the line and in the picking room. At 

approximately 1020 hours, I took regulatory 

control ofthe line due to the number of cadavers 

being presented at the inspection stand 

(approximately twenty (20)). -

implemented corrective action by adjusting the 

stunner depth, adding salt to the stunner, and 

having 

adjust the neck cutter so that the bled out cuts 

were over the vein. Preventative measures were 

discussed later in the afternoon andstated that the bird size was the issue but would 

increase monitoring of the kill area to decrease 

the amount of live birds entering the scafder. I 

notified 1 

that this MOI was being forwarded to the District 

Office and the District Medical Specialist (DVMS) 

in case additional follow- up is recommended. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 195 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P476 Pilgrim's Pride Corporation ODA27230 

52022G 

22MAY2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

Daniel Shaw, Plant Manager Pilgrim's Pride 

Corporation P-0476 616 Kingsbridge Rd. 

Carrollton, GA 30117 On Wednesday, May 22, 

2019 at approximately1850 hours while 

performing a Good Commercial Practices Task at 

P-0476 I, , observed an issue 

with the implementation of Good Commercial 

Practices in the evisceration department. I 

observed approximately thirty-five cadaver birds 

both on evisceration line number one and 

removed from the line Inside a condemn barrel 

within the evisceration department. I immediately 

cadavers on the line in my presence. I was notified 

by that there 

was no water in the stunner and the backup killer 

was trying to kill each bird by hand, which lead to 

the large number of cadavers seen on the 

eviscerat ion line. - stated water was 

replaced in t he stunner on picking line number 

one and the problem was corrected. Once all 

cadavers were removed by UDSA inspection and 

notated on the lot tally sheets, no other cadaver 

birds were observed. The topic will also be 

discussed again at the ne)(t UDSA weekly meeting 

on May 27, 2019 at 2330 hours and the minutes 

will be documented in the corresponding MOL 

Respectfully, 
.

Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 196 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P476 Pilgrim's Pride Corporation ODA57220 

82322G 

22AUG2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

Daniel Shaw, Plant Manager Pilgrim's Pride 

Corporation P-00476 616 Kingsbridge Rd. 

Carrollton, GA 30117 On Wednesday, August 21, 

2019 at approximately 2100 hours while 

performing a Good Commercial Practices Task at 

P-00467 I , observed an 

issue with the implementation of Good 

Commercial Practices in the yard/holding area for 

trailers. I observed two live birds left inside oftwo 

separate cages on trailer #220790. This trailer was 

positioned in the middle ofthe yard with no 

overhead covering or ventilation for cooling .I 

immediately notified the yard driver employee, 

who was in the immediate area, and he removed 

the observed live birds placing them on another 

trailer filled with live birds parked under the shed 

covering equipped with fans and misters. This 

issue was discussed with 

shortly after the occurrence. He 

stated t hat he would look further into the 

occurrence and notify those whom it concerned. 

The topic will also be discussed again at the next 

UDSA weekly meeting on August 26, 2019 at 

approximately 2330 hours and the minutes will 

be documented in the corresponding MO!. 

Respectfully, 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 197 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P481 Tyson Foods, Inc. VHF49040 

55308G 

08MAY2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

On May 6, 2019 at approximately 2200 hours the 

night shift , observed the 

following good commercial practice failure. While 

conducting a routine antemortem inspection, ■ 

- was walking on the pathway parallel to 

the loading dock when she noted the seventh 

cage from the rear oftrailer 228 had been pushed 

offthe truck, lodging it between the vehicle and a 

metal wall. The cage was positioned such that it 

was partially rotated with the bottom corner 

positioned on the ground and the top corner still 

supported by the truck. Due to this all the birds 

were condensed into the lowest point ofthe cage, 

causing them to pile on top ofeach other. Wings 

and feet ofmultiple chickens could be seen 

pushed out of the bars of the cage, and loud 

vocalizatioA could be discerned from the affected 

birds. It was noted that none of the cage doors 

opened during the fail so all the birds were 

of the situation. In response 

maintenance was called to the loading dock to 

assist in the retrieval of the cage. Once tt,e 

situation was properly assessed chains were 

connected from the fallen cage to the forklift. The 

cage was then lifted via said chains and slid back 

into position on the trailerwith minimal 

disturbance to the chickens contained within, 

After the chains were detached the cage was 

removed from the trail.er and presented to the 

SPHV for further inspection at2216. The birds in 

the affected cage were found to be restless, but 

vocalizations had subsided, and they had spread 

outacross the module's floor. The majority of 

visualized chickens appeared unharmed by the 

drop and pressure ofthe animals on top ofthem, 

likely due to their small size. One bird appeared 

reluctant to stand, but it was unclear if it had 

been injured during or prior to tt,e drop. Visual 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 198 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

inspection revealed no frank blood, nor any 

obviously broken limbs. The plant was given 

permission to run the birds once the cage was 

sound enough to be put through the dumper. A 

broken and bent support bar of the cage was then 

affixed back into place, with care taken to prevent 

any sparks from hitting the birds. The chickens 

proceeded through the slaughter system as 

normal with no increase in broken limbs or 

bruises noted by inspection personnel. When 

the forklift driver was interviewed about the 

incident by plant supervision it was determined 

that the issue occurred secondary to live haul 

cage mishandling. When the prongs ofthe forklift 

entered the bottom track ofthe cage the driver 

found that he could not progress further. When 

hetried to remove the prongs, they were found to 

be stuck on detritus lodged inside the tracks 

during the catching process. The driver attempted 

to push forward to free his forklift, but 

unintentionally pushed the cage offthe trailer in 

the process. Upon inspection ofthe cage it was 

found that the track along the bottom ofthe cage 

used for unloading birds were bent. It was also 

noted that multiple cages on the same truck had 

litter and debris filling the entirety of the forklift 

tracks due to the catch crews pushing cages 

through the litter in the houses. Plant 

management observed the issue and stated they 

would be discussing proper cage handling with 

the live haul supervision. Please note it is not 

within the standards ofgood commercial practice 

to cause birds undue stress or injury during the 

slaughter process. Repeated incidences, such as 

this, can result in further action being taken by 

FSIS personnel. 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 199 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P48304 Lincoln Premium Poultry YOT02141 

25017G 

17DEC2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized On Monday December 16, 2019, at approximately 

0425 hours, I observed an incident ofpoultry 

mistreatmentwhile passing through the live-hang 

area of Lincoln Premium Poultry, on myway to 

perform antemortem inspection. I first noticed a 

red condemn barrel that did not appear to have 

been cleaned by the sanitation company, as there 

were dried feathers, feces, and a smal I a mountof 

blood and denaturant present on the upper inside 

rim ofthe barrel. All the other condemn barrels 

had been cleaned and stacked up near the wall. 

As I approached, I saw that there were two live 

chickens sitting in this condemn barrel. The barrel 

was otherwise empty, aside from some feces and 

feathers atthe bottom. I met with 

discuss the situation. As slaughter operations had 

not yet started for the day, and because the 

condemn barrel had not been cleaned during 

routine sanitation on Friday December 13th, 

these chickens were most likely left loose in the 

establishment after the end of production on 

December 13th. Management concluded that the 

sanitation crew may t,ave found the birds loose in 

lairageor live hang area and placed them in the 

barrel to keep them contained. The establishment 

management elected to humanely euthanize and 

condemn the two chickens. It is not consistent 

with Poultry Good Commercial Practices for birds 

to be loose in the establishment, not provided 

with food or water for up to 72 hours, or for live 

birds to be placed in condemn barrels. The 

Poultry Products Inspection Act and Agency 

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

poultry be handled in a manner that is consistent 

with Good Commercial Practices (GCPs). The 

establishment is encouraged to maintain the 

standards ofGCP through a systematic approach 

that focuses on treating poultry in such a manner 

as to minimize excitement, discomfort, and 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 200 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

accidental injury the entire tim_e that live poultry 

is held in connection with slaughter. 

Establishment management may review Federal 

Register no'tice "Treatment of Live Poultry before 

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

2005), for FSIS recommendations concerning the 

treatment of live poultry before slaughter. This 

MOI will be.forwarded to the Dist rict Office and 

the District Veterinary Medical Specialist (DVMS) 

in case additional follow-up ,s recommended. 

Sincerely, 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 201 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P48304 Lincoln Premium Poultry YOT29110 

12504G 

04JAN2020 04C0S Poultry Good 

Comtnercial 

Practices 

Open On January 3, 2020, Est. P48304 Lincoln Premium 

Poultry held approximately 30,500 young 

chickens overnight in the lairage area, after 

slaughter operations could not becompleted 

within operating hours that day. These chickens 

were first placed in transportation modules 

around 4:00 a.m. on January 3rd. They were then 

held in the modules overnight at the 

establishment and were slaughtered beginning at 

4:52 am on January 4th. While performing 

antemortem inspection on January 4th, I noticed 

a higher than usual number ofdeceased birds in 

the group that was held overnight. The chickens 

were crowded in some trays, and I observed them 

clustered towards the sides ofthe trays, with live 

birds resting on top of dead birds. I met with 

at 6:50 a.m. on 

January 4, 2020 to discuss the situation. The 

establishment suspects that there were more 

chickens than usual loaded into some modules. 

Two trailers of birds received on the afternoon of 

January 4th weighed 10,000-20,000 pounds 

higherthan average weight. Itis believed that the 

prolonged time being held in modules without 

access to food and water, in crowded conditions, 

led to the higher mortality rates. In total, 1,622 

chickens were deceased out ofthe approximately 

30,500 bi•rds held overnight. This equates to a 

DOA rate of5.3%. The average DOA rate for this 

establishment is approximately 0.4%. 

- said that the establishment will be 

investigating why some ofthe modules were 

over-crowded with birds, so that it may be 

addressed directly at the farms where the birds 

are loaded. Chickens dying by means other than 

slaughter is not consistent with Poultry Good 

Commercial Practices. The Poultry Products 

Inspection Act and Agency regulations (9 CFR 

381.6S(b)) require that live poultry be handled in 

a mannerthat is consistent with Good 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 202 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

Commercial Practices (GCPs). The establishment is 

encouraged to maintain the standards ofGCP 

through a systematic approach that focuses on 

treating poultry in such a manner as to minimize 

excitement, discomfort, and accidental injury the 

entire time that live poultry is held in connection 

with slaughter. Establishment management may 

review Federal Register notice Treatment of Live 

Poultry before Slaughter Fed. Reg. 56624 

(September 28, 2005), for F51S recommendations 

concerning the treatmentoflive poultry before 

slaughter. This MOI will be forwarded to the 

District Office and the District Veterinary Medical 

Specialist (DVMS) in case additional follow-up is 

recommended. Sincerely, 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 203 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

P48304 Lincoln Premium Poultry YOT03080 

13518G 

18JAN2020 04C0S Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

On January 17th, 2020 at 11:22 a.m., while 

performing a Poultry Good Commercial Practices 

Task, I observed two young chicken cadavers on 

the line at the pre-sort area in the picking room of 

- at Lincoln Premium Poultry, Est. P48304. 

Both cadavers were generally dark red in color, 

with their heads and necks very dark red and 

swollen, and no cut was present on their necks 

indicating bleeding ofthe carcass. These cadavers 

were pulled offthe line by the pre-sorters and 

condemned. I proceeded up the line to monitor 

the chickens entering the scalding tank and asked 

a maintenance employee to call a supervisor to 

the picking room. I observed one bird with no cut 

on the neck enter the scalding tank. 

arrived shortly, and I 

notified him ofthe three birds that were not cut 

at the kill step. He immediately spoke with the 

back-up cutter to notify him of the birds that were 

not cut. - also raised the automatic neck 

cutting blade so that it would beless likely to miss 

the smaller sized birds. I continued to observe the 

chickens on- for 15 moreminutes and did 

not see any more birds entering thescalder 

without being bled. Chickens dying by means 

other than slaughter is notconsistent with Poultry 

Good Commercial Practices. Continuing with my 

Poultry Good Commercial Practices Task, I 

entered the stunning and live hang area at 

approximately 11:55 am. Under the De-Stack 

machine o~ , I observed three birds on the 

floor that appeared to have fallen out of the 

modules during the de-stacking process. One 

chicken was deceased, one was alert and 

appeared unharmed, and one chicken was alive 

but injured. The injured chicken was lying sternal, 

unable to stand but attempting to move. Its legs 

were stretched behind its body, and both wings 

had blood on the feathers at the base of the 

wings. The right wing was turned atan unnatural 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 204 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

angle. There wenrnot any establishment 

employees nearby, so I walked to the live hang 

area to notify the lead about the injured bird. At 

1:50 p.m. I spoke with 

about the GCP concerns. 

He had already discussed the situation with•. 

watched the slaughter process 

closely for-the remainder ofthe day and there 

were no further incidents of birds no~ being bled 

out properly. The establishment plans to pursue 

disciplinary action ifthe back-up cutter continues 

to miss birds. They will also adjust the automatic 

blade when they observe that the birds are of 

varying sizes, so that it works more efficiently. The 

establishment will be monitoring for injured and 

loose birds more closely. The Poultry Products 

Inspection Act and Agency regulations (9 CFR 

381.6S(b)) require that live poultry be handled in 

a manner that is consistent with Good 

Commercial Practices (GCPs). The establishment is 

encouraged to maintain the· standards ofGCP 

through a systematic approach that focuses on 

treating poultry in such a manner as to minimize 

excitement, discomfort, and accidental injury the 

entire time that live poultry is held in connection 

with slaughter. Establishment management may 

review Federal Register notice Treatment of Live 

Poultry before Slaughter Fed. Reg. 56624 

(September 28, 2005), fo.r FSIS recommendations 

concerning the treatment of live poLJltry before 

slaughter. This MOI will be forwarded to the 

District Office and the District Veterinary Medical 

Specialist (DVMS) in case additional follow-up is 

recommended. Sincerely, 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 205 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P48304 Lincoln Premium Poultry YOT55130 

13221G 

21JAN2020 04C0S Poultry Good 

Commercial 

Practices 

Finalized On January 21, 2020 at approximately 4:30 a.m., 

while performing ante-mortem inspection of 

young chickens at Lincoln Premium Poultry, Est. 

P48304, I observed several incidents ofpoultry 

mistreatment. In the lairage area of Line 1, there 

were two chickens, each with one wing trapped in 

the right side of the locking mechanism of the 

tray above them. These two pirds were in the 

same module, but In different trays. The bird in 

the lower tray had blood on its wing over a 1-2 

cm area and was unable to sitor lay down 

because ofthe trapped wing. The bird in the 

upper tray was pulling at the wing repeatedly and 

vocalizing, had a 1 cm area ofblood on the wing 

feathers, and could not sit or lay down. Inotified 

the lead,_ , ofthe trapped birds. He was able 

to free the chicken in the lower tray. The chicken's 

wing did not return to a normal position after 

being freed. The upper chicken had freed Itself, 

leaving behind a clump ofwing feathers in the 

latch. Then, approximately 5 minutes later, a 

module ofbirds was being loaded into lairage on 

Line 2, and I saw another chicken with its wing 

trapped in the locking mechanism of the tray 

above. The establishment employee was notified 

and released the bird's wing from the tray. I spoke 

with and heasked the 

forklift drivers to monitor for trapped birds more 

carefully, so that they can be released. While 

performing a Poultry Good Commercial Practices 

Task at 12:20 p.m., I observed an additional three 

live chickens with wings trapped in the tray 

locking mechanism. The first bird was in a lower 

tray on Line 1. Much ofthe wing was trapped in 

the latch, and the bird was unable to lay down. I 

notified , and 

he found an establishment employee to help 

release the bird. There was blood on the chicken's 

wing, and It did not return to normal position 

after it was released. On our way out of lairage, I 
Table: MOls in Response to FOIA2020-110 10:12 Friday. Februaty 21 , 2020 206 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

showed the employee two more chickens with 

wings crushed in the tray latch. These birds were 

notable to be released because their location 

high in the modules crea.ted safety concerns for 

the employee. When chickens are trapped in the 

trays above them, and not released by 

establishment personnel, they are subject to 

further injury or deat h when the module proceeds 

through the destack machine. The Poultry 

Products Inspection Act and Agency regulations (9 

CFR 381.65(b)) require that live poultry be 

handled in a manner that is consistent with Good 

Commercial Practices (GCPs). The establishment is 

encouraged to maintain the standards ofGCP 

through a systematic approach that focuses on 

treating poultry in such a manner as to minimize 

excitement, discomfort, and accidental injury the 

entire time that live poultry is held in connection 

with slaughter. Establishment management may 

review Federal Register notice "Treatment of Live 

Poultry before Slaughter;" 70 Fed. Reg. 56624 

(September 28, 2005), for FSIS•recommendations 

concerning the treatmentoflive poultry before 

slaughter. This MOI will be forwarded to the 

District Office and the District Veterinary Medical 

Specialist (DVMS) in case additional follow-up is 

recommended. Sincerely, 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 207 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

PSlO House Of Raeford Farms RHB41120 

75516G 

16JUL2019 04C0S Poultry Good 

Commercial 

Practices 

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

House of Raeford Rose Hill, NC 28458 Ms. 

Reynolds At approximately 0809 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 towho 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 itto 

- 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 . 

also placed an employee at the entrance of 

the 1st scalder to monitor for live birds that might 

enter the scalder. I discussed my finding with 

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 toscalding. -

- 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 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 208 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 209 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

PSlO House Of Raeford Farms RHB04081 

03304G 

04OCT2019 04C0S Poultry Good 

Commercial 

Practices 

Finalized Ms. Reynolds Plant Manager, P-510 At 

approximately 0807 while performing the Good 

Commercial Practices Verification task, I observed 

a live bird about to enter the scalder. The bird a.t 

the time of my observation had normal rhythmic 

breathing, eyes open and blinking with the head 

elevated and no cut on its throat. The line was 

stopped before the live bird could enter the 

scalder and was removed by a plant employee. 

was notified of my findings, ofthe 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 ofthe carcasses and ensure that 

breathing has stopped prior toscalding." While 

talking to_ , plant employees took two 

more live birds offthe I ine prior to the scalder 

that had no evidence that their throats had been 

cut. Ail three birds were taken back to live hang 

and put back on the kill line to be properly 

slaughtered. - told me that there was a 

new back up cutter who was supposed to have a 

person working with them until they were fully 

trained but no one was there. Hesaid that they 

did put an experienced person with the new 

person on the line and that they would watch the 

line to make sure no other birds were on the line 

that had been missed. I remained there for 

approximately 5 additional minutes and did not 

see any more live birds. A copy of this MOI. will 

be forwarded to the District Veterinary Medical 

Specialist (DVMS) in case additional follow-up is 

recommended. Ifyou have any questions or 

concerns regarding the above or wish to appeal 

this decision, please contact 

Respectfully, 

P510 
Table: MOls in Response to FOIA2020-110 10:12 Friday, Februaty 21 , 2020 210 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status 

PSlO House Of Raeford Farms RHB04111 

03107G 

070CT2019 04COS Poultry Good 

Commercial 

Practices 

Finalized 

MOI Agenda 

Ms. Nicole Reynolds, Plant Manager, P-510 

House of Raeford Rose Hill, NC 28458 Ms. 

Reynolds At approximately 0710 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 towho stopped 

the line before the bird could enter the scalder 

and had the bird removed from the line by ■ 

. After removing 

the bird from the line, it was observed that there 

was a small shallow 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 the backup cutter.- 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. - stated that the backup 

cutter was j ust relieved for breaks and he 

instructed the backup cutter to pay more 

attention when switching places. I discussed my 

finding with and 

notified them ofthe 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. There 

was a similar occurrence documented on 10/4/19 

on MOI RHB0408103304G. Ms. Reynolds this 

MOI will be forwarded to the District Veterinary 

Medlcal Spedalist (DVMS) in case additional 

follow-up ls recommended. Ifyou have any 

questions or concerns regarding the above, please 

contact 
Table: MOls in Response to FOIA2020-110 10:12 Friday, February 21 , 2020 211 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

Respectfully,