including the use of raddle
paddles, electric sticks and other
devices use to move livestock.
Verify once.

Verify firearms and handheld
captive bolt (HHCB) are cleaned
and maintained before each
slaughter date. Note: Handheld
captive bolts (monthly) and
firearms daily after use. Verify
records each slaughter day.

Verify the establishment creates a
monitoring record for
consciousness. This document will
include the signature, date,
verification of knock placement,
no rhythmic, no righting reflex, no
tracking eye movement, no
vocalization, and proper stick.
(CFR 313.15). Verify once

Verify that each employee
responsible for knocking or
monitoring HH activity is trained to
determine unconsciousness for all
species slaughtered at this
establishment. Verify weekly.

Verify that each animal is
unconscious by direct observation
and record review. PHIS HATS
Category Vill. Verify daily.

Verify that there is a secondary
stunning firearm or captive bolt in
the immediate area. Verify daily at
each knock. Verify that a 30/30
caliber rifle is specifically available s
as back-up for larger animals.

Verify swine larger than five hundre|
(500) pounds are held separately in
pens. Verify daily.



Establishment Name: Towson Cold Storage May 1, 2023
Establishment Number: 18731M

Week ending:

On April 24, 2023, the Food Safety, and Inspection Service (FSIS) issued a Notice of
Suspension (NOS) withholding the marks of inspection and suspending the assignment of
slaughter inspection program personnel for livestock slaughter at Towson Cold Storage, Est.
18731M located at 301 South Ridge Ave. Tifton, GA 31794. This action was based on your
establishment's failure to handle livestock humanely according to 9 CFR Part 313. This
Food Safety and Inspection Service (FSIS) Verification Plan is designed to verify that the
establishment fully implements the corrective actions and preventive measures proffered
in response to the Notice of Suspension (NOS) issued on May 1, 2023. Inspection personnel
and the Atlanta District Office will utilize the Verification Plan to evaluate the effectiveness

of the corrective actions in assuring future regulatory compliance. This FSIS Verification
Plan identifies the corrective actions, the relevant regulatory requirements, and the PHIS
Task under which FSIS officials will verify the implementation and effectiveness of the

proposed action plan. The verification plan has the following tasks.

Humane Handling and Slaughter Verification

“Results of Verification” should be recorded as acceptable or unacceptable. Under the
heading “Inspection Actions”, please document corrective actions taken in compliance
with 9 CFR 313. Please explain all unacceptable findings in the “Inspection Actions”
column.

Items to Verify Results of Verification Inspection Actions
Acceptable (A) or List actions taken if
Unacceptable (U) Unacceptable.

Livestock Humane Handling Verification
Task

9 CFR 313

A) Verify all employees handling live
animals have been re-trained for

humane handling techniques



H) Verify that for the next 10 kills, a
training session with completed
training records, is done prior to
kill. Each slaughter day.

Verify that this training is

performed once per month after
the 10" session. Once per month

Verify all firearm and captive bolt
maintenance is documented in
the Captive Bolt and Firearm
Maintenance Log. Daily

Verify animals are allowed to calm
down in the knock box before
stunning/shooting. Daily

COMMENTS AND RECOMENDATIONS

Two Week Period Ending:

IC Comments:



Food Safety and
Inspection Service

Office of Field
Operations

Atlanta District Office

100 Alabama St., SW.
Suite 3R90

Atlanta, GA. 30303
Phone: 404-562-5900
Fax: 404-562-5877
Toll Free:
800-282-7005

USDA
cee

United States Department of Agriculture

Certified mail

May 2, 2023

Towson Cold Storage
EST. M18731

301 South Ridge Ave.
Tifton. GA 31794

EEE 6 2012i1 com

(229) 388-3242
NOTICE OF SUSPENSION HELD IN ABEYANCE
Dear Mr. Bill Towson:

On April 24, 2023, the Food Safety, and Inspection Service (FSIS) issued a
Notice of Suspension (NOS) withholding the marks of inspection and suspending
the assignment of slaughter inspection program personnel for livestock slaughter
at Towson Cold Storage, Est. M18731 located at 301 South Ridge Ave., Tifton,
GA 31794. This action was based on your establishment's failure to handle
livestock humanely according to 9 CFR Part 313.

On April 25, 2023, you submitted written corrective actions and preventive
measures to meet the requirements of the Humane Methods of Slaughter Act.
Based on your assessment, you determined that inadequate training for an
animal of this size and temperament led to the animal’s over-excitation, and a
lack of a weapon of the proper caliber size and condition led to the animal
needing multiple stunning attempts before rendering the hog unconscious. Your
corrective actions included: evaluating hogs for size, sex, and aggressiveness
before unloading; training employees on how to handle larger hogs more
effectively; maintaining and recording maintenance of firearms and captive bolt
guns; using a 22 caliber rifle as the primary stunning method for larger hogs and
a 30/30 rifle as the secondary method; searching for a method to restrain big
hogs in the knocking box; and retraining and monitoring employees in proper
stunning methods.

On May 1, 2023, FSIS determined that the proffered corrective actions and
preventive measures submitted were not adequate to properly address the
inhumane handling incident and further clarification was requested. Specifically,
FSIS requested clarification regarding the description of events not matching

An Equal Opportunity Provider and Employer


Continue Verification Process:

Suspension or Reinstatement of Suspension:

No Further Action / Close with a Letter of Warning:

HIC Signature



NOTICE OF SUSPENSION HELD IN ABEYANCE
Mr. Bill Towson, Plant Manager

Towson Cold Storage, Est. M18731

May 2, 2023

Page 2

IPP’s observations of the number of stunning attempts; explaining why a 22 caliber rifle
instead of a larger caliber firearm was used in this event; planning to use the same 22
caliber rifle that caused this incident as the primary stunning method for larger hogs;
verifying if a second stunning device will be in the immediate area during knocking;
determining how often firearms will be maintained, determining what qualifies as a
‘bigger’ hog for your system; creating a more specific plan for a method to restrain large
hogs; and verifying if the employee training will include how to determine
unconsciousness and the source of this training.

On May 1, 2023, you submitted your second response to provide clarification to your
proffered corrective actions. Your response included: a description of the events that
included six stunning attempts, five with the 22 caliber rifle and one with a captive bolt
gun; an explanation that there were not any firearms of bigger caliber on hand at the time
and the 22 caliber rifle was inadequately cleaned and had a faulty spring; having both a
22 caliber rifle and 30/30 rifle on the kill floor for larger hogs and involving management
to determine the appropriate firearm to use; creating a Captive Bolt and Firearm
Maintenance Log for documenting maintenance and cleaning of firearms after each use
and captive bolts monthly; specifying that ‘bigger’ hogs are those over 500 Ibs; a diagram
of the planned restraining gate to be implemented by May 30, 2023; and stating that a
training session with a signed training log will be held for the next 10 kills and then will
be held monthly. You provided a copy of the updated Robust Systematic Approach to
Humane Handling Protocol, a copy of the updated Humane Slaughter Monitoring Report,
a record documenting employees that were retrained, a copy of the Captive Bolt/Firearm
Maintenance Log, and a diagram of the planned restraining gate.

On May 2, 2023, you were verbally notified by FSIS that the corrective actions and
preventive measures met the requirements to place Towson Cold Storage, Est. M18731,
in Abeyance and that a Notice of Suspension Held in Abeyance (NOSHA) and
Verification Plan (VP) would be issued. You are hereby being provided written
notification of the Notice of Suspension Held in Abeyance.

Please be further advised that the suspension of inspection at your establishment will
remain in abeyance pending verification by FSIS that your proposed corrective actions
and preventive measures have been implemented and are effective in ensuring future

regulatory compliance and preventing the inhumane treatment of animals. Agency
personnel will begin immediate verification of your corrective actions and preventive
measures.

A copy of the FSIS Verification Plan is attached to assist you in understanding the nature
and importance of the agency’s verification activities. The FSIS Verification Plan is
designed to verify that your establishment fully implements the revisions to its humane
handling of animals and other corrective actions stated in your responses, and that these
revisions and corrective actions are effective in ensuring future regulatory compliance.

An Equal Opportunity Provider and Employer


NOTICE OF SUSPENSION HELD IN ABEYANCE
Mr. Bill Towson, Plant Manager

Towson Cold Storage, Est. M18731

May 2, 2023

Page 3

The FSIS Verification Plan identifies your proposed corrective actions, the regulatory
requirement(s), and the PHIS Task under which FSIS officials will verify the
implementation and effectiveness of your proposed action plan.

Please be reminded that as a federally inspected establishment, you are expected to
comply with FSIS regulations and to take appropriate actions to prevent the inhumane
handling of animals. It is important for you to understand that FSIS has the
responsibility to initiate action if your establishment fails to operate in accordance with
the regulations, or conditions occur that do not comply with the Humane Methods of
Slaughter Act. Please be advised that failure to comply with these regulatory
requirements or failure to effectively implement your proposed corrective actions and
preventive measures could result in the immediate suspension of inspection at your
establishment or other appropriate action.

If you have any questions, please contact the Atlanta District Office at 404-562-5900.

Sincerely,

Dr. Phyllis Adams
District Manager

ce: Melissa Moore, EARO
Alexander Domesle, Acting EARO

Phyllis Adams, DM
(by) Humane Handling Enforcement Coordinator

Scott Ehle, Acting OIEA Regional Director
Edward Hepburn, DDM
Barney Welch, DDM

‘Tracy Bryant, DDM
CS

IDVMS
‘A Coordinator
LIC at M18731
FO/Quarterly Reports

An Equal Opportunity Provider and Employer