Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P18860

Sing Wah Live Poultry Mkt Inc

XPD2409055,
819G

19MAY2020

04C05

Poultry Good
Commercial
Practices

Finalized

While doing a routine GCP observation task on 05/18/2020
at P18860 at 8:10, | observed the following. A plant
employee put into the scalder approximately 10 young
chickens that were still breathing and flapping their wings. |
stopped the line and noted that the bleed out process was
incomplete and ineffective. A worker removed the birds
from the scalder, placed them into a barrel, and then them
transferred back into the cones. Good commercial
practice requires a complete bleeding out of the carcasses
prior to further processing per CFR 381.65 (b). Any
subsequent occurrences of this issue will result in the
issuance of an NR and possible further regulatory action.
informed SPHV of this deviation from GCP.

P18860

Sing Wah Live Poultry Mkt Inc

XPD1411065,
316G

16JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

This meeting serves as a formal notice that all birds must
be bled out thoroughly in the cones BEFORE being placed
in the barrels and the scalder. As members of
management, itis your responsibility to ensure that all
employees working on the kill floor are properly trained
how to slaughter according to good commercial practices
to avoid the issuance of noncompliance records.

P18860

Sing Wah Live Poultry Mkt Inc

XPD3611061
517G

17JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

(7EZZ land | met today around 10:00AM to further discuss
good commercial practices. Around 9AM while | was
performing my routine GCP tasks, | observed the slaughter
of light fowl. We received 12 crates of light fowl today and
during my antemortem inspection, there were only a few
dead on arrival; however, at the time of slaughter, shortly
after 9AM, there was a large number of dead birds in the
crates. Final count was 25, per the kill floor employee. |
asked what happened and he told me they "got too hot
waiting."[ DG pnd | addressed the ventilation situation in
the live holding area and he is aware that he is required to
provide proper ventilation in all rooms of his plant. | also
explained to him during our meeting that even though we
cannot control the loading of the birds to the
slaughterhouse, we can control what happens once they
arrive and we have a responsibility to keep the live birds
comfortable and alive while waiting to be slaughtered for
food. This means not keeping them overnight, and not
letting them get too hot in summer months and too cold in
winter months. Next week, the high is expected to be in the

80s so itis very important that this is addressed promptly.

20


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

Task
MOINbr Date Code | TaskName Status

MOI Agenda

P7487

Koch Foods, LLC

SPG4515043 30APR2020 | 04C05 | Poultry Good Open
730G Commercial
Practices

While doing a Good Commercial Practices task on
4-30-2020 on 1st shift at Koch Foods of Chattanooga, TN,
lentered the bleeding room. | noticed that birds were not
entering the killing machine correctly and that there were
several hung by one leg. | observed that the back-up killer
was working what | consider to be too hard and having to
bleed a lot of birds. | left the bleeding room and live hang
to observe the birds enter the scalders. To perform my
observations, | stood beside the scalders, between the two
lines, where the birds come through the windows of the
bleeding room into the picking room. As | was observing,
four (4) live birds entered the scalder of the 280 picking
line. | had begun observing the birds enter the scalder

at ~ 0930. At 0933, | observed the first bird enter the
scalder. Its head was up, the eyes were open and it
blinked. | observed two more live birds enter the scalder
almost immediately behind it. Then, less than a half minute
later, at 0934, | observed the 4th live bird enter the

scalder. These last 3 birds also had their heads up and
eyes open. | found Plant Superintendent Kevin McClendon
in live hang, | informed him of the live birds entering the
scalder and that ! would be writing a MOL.

P7487

Koch Foods, LLC

SPG1503063 15JUN2020 | 04C05 | Poultry Good Finalized
615G Commercial
Practices

On 6/15/2020 at approximately 0330 hours, | was called to
the evisceration department by an online inspector on line
3. The online inspector informed me that they had gotten
multiple cadavers at their station. The cadavers shown to
me appeared to have very shallow cuts on the back of the
necks. | immediately went to the stunning/killing area to
observe conditions. At 0340 hours, | performed a Good
Commercial Practice check prior to the scald tanks.
During this check, | observed one young chicken out of a
subset of 500 to be alive while entering the scald tank on
thel (b)(4)_ |The young chicken had a lifted head with
open and responsive eyes with no cut on the neck. Plant
management was already present in the area, so they
were immediately informed of the finding and began
adjusting the killer as well as switching out the employee
located in the back-up killer position. A second verification
check of approximately 500 birds was conducted prior to
the scald tanks and there were no live birds observed
entering the scald tanks during this retest.

(b)(6) as notified. | explained my
‘observations and informed him that a Memorandum of
Interview (MOl) was going to be documented and a copy
forwarded to the appropriate personnel in the Jackson
District Office. Respectfully submitted, (b(6)

[vay] Cef fhyé) ]

(bV6)

41


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P510

House Of Raeford Farms

RHB2306065,
110G

10JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 06/10/2020 at 0542 hours | was conducting a Good
Commercial Practice verification task in the kill/picking
area behind the evisceration department. | was observing
the birds going by on the line after they had exited the
blood tunnel near the first scalder. | noticed one of the
birds had its head turned to one side and appeared to be
blinking. The line was stopped by[__ caval]
(b\6) ind the bird was removed from its
shackle. The bird was breathing, looking around, and
upon further exam | noted that it did not have a cut on its
neck. | discussed with that per regulation
381.65(b) in CFR 9, 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 entering the
scalder. The bird was returned to the live hang area and
placed on the receiving line. This issue was also
with the| OWEN
le confirmed that the current back up cutter is

37

very experienced. [/i:i74\l reported that apparently an
employee was trying to rehang a bird near the backup

(6)

cutter which had removed one of its own legs from its
shackle. He reported this may have blocked the back u
cutter’s view long enough for an uncut bird to pass by
unnoticed. | discussed my concems regarding this
situation with [3243] including potential for employee
safety issues. confirmed the employee who
rehung the bird will be retrained not to approach the
backup cutter’s area. reported that he would
monitor the backup cutter and the birds on the line during
the remainder of the shift to confirm no further issues were
noted. | continued monitoring the birds on the line before
they entered the scalder and saw no further issues. The
last occurrence ofa similar issue was documented on
05/31/2020. _A copy of this MOI will be forwarded to the

THYVAY I ye) ]

and to the| OWA Jifyou have any
questions you ¢:
Respectfully, (b\(6)

P51179+V5S1
179

Sanderson Farms, Inc.

RQE2312051
107G

O7MAY2020

04C05

Poultry Good
Commercial
Practices

Finalized

Mistreatment MOI in the poultry GCP task On May 4,
2020 at approximately 0900 hours while performing a Good
Commercial Practice (GCP), |
‘observed the following Conditions; The Sanderson Farms
Inc. (SF!) employee stationed at the Cage Dumper Control
area_kicked a live bird into the Cage Dumper conveyor
belt. The same SFI employee got the water hose and then
sprayed water at another live bird into the Cage_Dumper
Conveyor belt. | |/iy1/4)notified| (HVA)

(by(6)_| Of my findings.



Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 46

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda

with him my observations in the live hang area the previous
night. He informed me of actions that management had
taken that same night to retrain all team members in the live
bird area on the proper handling and treatment of live
poultry. Today additional measures were taken aimed at
reducing the overall number of dead birds. This included
discussion with the live catching managers to reduce the
number of birds that are being placed in the cages,
particularly as the birds are currently larger than their
targeted preferred weights, and to address the water
misting systems and retum them to proper function. This
MOI has recorded in summary all the pertinent matters
discussed during the two meetings with plant management
and a copy will be forwarded to the District Veterinary
Medical Specialist (DVMS) in the District Office in case

additional follow-up is recommended. Respectully, [pypq
(b\V6) st. P806 Tyson Foods, Inc.

P890 Peco Foods, Inc. CYD2416063 17JUN2020 | 04C05 | PoultryGood | Finalized | Est. P-890, Peco Foods, Inc., June 17, 2020, 1:40 pm. In
517G Commercial atendance:[_——_(hyai__Mr. ef il,
Practices Assistant Plant Manager. At approximately 1:18 pm, | was
performing a check for Good Commercial Practices. |
went to observe conditions in the live hang pen in the
poultry receiving department. | then left the live hang pen
and walked past the plant sorter station located at the end
of the picking line. | observed two cadaver birds inside the
barrel on top of other birds disposed of by the plant sorter.
Neither bird had a bleeding cut on the neck. The birds
were immediately presented to Mr. Jeff Hill, Assistant Plant
Manager. At approximately 1:21 pm, | went to the picking
room to observe the birds entering the scalder. | had
observed approximately 75 birds when | observed one (1)
live chicken on the picking line entering the scalder. The
bird was blinking its eyes, chirping, and lifting its head. |
observed no cuts to the neck and no bleeding. Mr. Hill
walked up immediately after and | informed him of my
observation. We observed the birds on the picking line for
approximately 3 minutes and observed no additional live
birds entering the scalder. At approximately 1:40 pm, |
met with Mr. Hill in the USDA office to inform him of the
forthcoming GCP MOI, documenting the incident and my
meeting and communication of these facts. Mr. Hill
indicated that the usual back-up killer is absent this week.
He stated that he will do additional training on the
temporary replacement bac! ler. Respectfully,

(b)(6) P-890 Peco Foods,

inc. Canton, Mississippi



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

Task
MOINbr Date Code | TaskName

Status

MOI Agenda

still parked close to the center of the new shed in its
overnight location at approximately 0630 hours. When |
checked the right side (looking into the shed) of the trailer,
| did not observe excessive numbers of DOAs. However,
when | checked the left side (which was directly exposed
to the row of fans) and checked the cages at the level of
the fans, | noted multiple dead birds. These birds overall
did not have overt signs of pathology or fatal injuries,
looked well-fleshed, and were reddish and reddish-purple
in skin color. The fans were not running at the time of my
observations. When | checked Poultry Lot Information for
Lot #2 and #3, there were a large number of DOAs
recorded: 1785 and 740 heads, respectively. This was also
confirmed in the DOA totals recorded by The
total number of DOAs for each lot was not broken down by
individual trailers; there were a total of three trailers for
both Lot #2 and #3, with only one truck from each on the
premises ovemight (the other two trucks from each lot had
arrived in the morning). However, both | and
visually noted that the majority of DOAs for both Lot #2 and
#8 were on the trailers that were left overnight on the
premises. | spoke on the phone with Plant Manager Sam
Groseclose about the incident at 1255 hours and informed
him | would be issuing a GCP MOI. | told him would
provide a copy of this MOI to my L__asway |
(6\Jand to our (hV6) for review (in
accordance with Directive 6110.1: Verification of Poultry
Good Commercial Practices). Mr. Groseclose told me he
was going to discuss the issue with 2nd shift management
to determine what happened. On Friday, May 8 at 1300
hours, Mr. Groseclose told me that, according to their
observations, it appeared high winds were able to turn the
fans and channel cold air into the shed, which may have
occurred on the night in question; establishment
supervision was able to see and video the wind turning the
fans in the new shed on the night of May 7 while there was
no power to the fans, and hypothesized this may have also
happened on the night of May 6.

14


Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 56

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI! Agenda
P935 Allen Harim Foods, LLC. | YXA1911062 25JUN2020 | 04C05 | PoultryGood | Finalized | This memorandum of interview serves as written
925G Commercial Notification of one cadaver found on Evisceration Line 2
Practices inspection station 3, today At approximately 2150 hours
while giving inspectors break on Evisceration Line 2 at A)

Station 3, | observed the carcass's head was intact and
the head and neck were dark red to purple and had not
received a cut to the neck. (hVAY

Lie Was notified of th érvation
of bird dying other than by slaughter.) —firiformed me that 6)
the supervisor in charge was informedand| —jwould—__|

observe and investigate the cause. | was later informed by
Ciena tat the issue was resolved by
adjustments to the Kill Machine and Stunner and also that
the responsible associates would be disciplined. Itis
recommended that establishment management review the
Federal Register on “Treatment of Live Poultry before
Slaughter’, published September 2005 for FSIS
recommendations concerning treatment of live poultry prior
to slaughter 75)74) _] was notified that this MOL
will be forwarded to the District Office and the District
Veterinary Medical Specialist (OVMS) in case additional
follow-up is recommended. Respectfully,

thi) _] Allen Harim Foods, LLC. P-935 _Harbeson,

DE. 19951 CC{ fbi)



Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 54

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI! Agenda
P935 Allen Harim Foods, LLC. | YXA0706064 41JUN2020 | 04C05 | PoultryGood | Finalized | Ante-mortem check performed on lot tat about 8.15am. No
211G Commercial concems. Verified GCP which followed regulations.

Practices Dumper and belts in good condition, Birds were housed
properly, humanely handled; Birds appeared to be in good
health. DOA’s removed and denatured properly, Stunning
and Killing was effective, no loose bird in live hang, live
haul and holding sheds.

From:

Date: 06/10/2020
Subject: Poultry Good Commercial
Practice/ MO! Meeting Date. 06/10/2020 Meeting
Time : 1.40pm. Establishment: P 935 — Allen Harim

Foods, LLC Comments:___MOI. (Good Commercial
Practice) To{__(5V(6) cc: me

(bV6) This memorandum of interview serves as

written notification of occurrence of one Cadaver found on

USDA line 3 station 2. At approximately 1.40 hours.
Inspector on line 3 station 2called me for Cadaver
disposition which was hanged by{_—tfor veterinary

disposition. Observed cadaver carcasses with head
- intact and no cut on the neck. The facial area was cherry
(b)(6) red and swollen; skin around the neck was purple in color
while the rest of the body of the carcass was bright red in
The (by\(6) was
notified, a id observe the cadaver carcasses.
|_assured me that{= |will be taking care of the employee
OG) responsible and make sure to correct and coach to avoid
reoccurrence. The agency regulations do require that
poultry must be slaughtered in accordance to good
commercial practices in manner that will result in thorough
bleeding of carcass and ensure that breathing was stopped
prior to scalding, so that birds do not drown or die other
than slaughter. Itis the agency expectation that all Good
Commercial Practices be correctly and effectively
implemented, The copy of this Memorandum will be
forwarded to DVMS Raleigh district and Front-Line
‘Supervisor (FLS) in case additional follow up is
recommended. A copy will be placed in the official USDA

file. Please feel free to contact me with any question or
concem. Sincerely. THVAY

CHW 6) cc; (by(6)



Table: Noncompliance Reports in Response to FOIA2020-434 11:13 Thursday, July 9, 2020 4

EstNbr EstName NR# Date Task TaskName Regs Description Status
M27389+P27 | Pitman Farms Nco021 04/24/2020 | 04C05 | Poultry Good 381.65(b) On Wednesday, April 22, 2020, at approximately 0745 CLOSED
389+V27389 2044524 Commercial hours, while performing a Poultry Good Commercial

N-1 Practices Practice task in Live Hang, | observed Line #2 hanging

chickens but was unable to control the chickens from flying
out of the baskets. The chickens were landing on the
"retum basket washer’, | observed some chickens were
getting trapped under the baskets that was entering the
washing solution and were drowning. | observed other
chickens that were riding on top of the baskets through the
"return basket washer" and they were getting drenched
with the washing solution. | then observed a dead chicken

on the floor next to the "return basket washer conveyor (by)
belt”. | immediately informed
(b\6)_|of my observation and findings. | + that

(e)(6) | = would immediately make a makeshift barrier wall to |

prevent the chickens from falling onto the "return basket (b)6)
conveyor belt". At approximately 0810 hours, | informed
[2X75 Jof my observation and findings and [ —}weritto |
the Live Hang area to inquire of my observation and
findings.At approximately 1205 hours, | conducted another
Poultry Good Commercial Practice to inspect the makeshift
barrier and observed another chicken that had drowned
from the solution inside the return basket washer. |
observed another chicken riding on top of a basket that
was going through the return washer basket. | pointed out
another chicken that was stuck inside the return basket
washer to an establishment employee who pulled the
chicken out. This chicken was mangled up from being
stuck between the machinery mechanisms.On Thursday,
April 23, 2020,[ jae) _linformed[___ away |
THWAN }hat a noncompliance will be
forthcoming. This is a noncompliance with regulatory
requirements of 9CFR 381.65(b)Agency Regulations
require that live poultry be handled in a manner that
prevents needless injury and suffering and that is
consistent with Poultry Good Commercial Practices. |
recommend that the establishment review Federal Register
Notice Vol. 70, No. 187, published September 2005
[Docket No. 04-037N] for FSIS recommendations
concerning treatment of live poultry before slaughter.



Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29, 2020
Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P9197 Perdue Foods, LLC. UAB0208061 02JUN2020 | 04C05 | PoultryGood | Finalized | On 6/2/20 at approximately 0725 hours, the inspector on
502G Commercial Line #3 Stand #4, presented me with a cadaver bird. The

Practices

bird had its head and neck attached which was bright red
to purple in color. The neck of the bird had no cut mark on
itand was fully intact, indicating that the bird was not bleed
out thoroughly in accordance with 9 CFR 381.65(b). |
informed (bye) jeff Stalls,
Complex Manager, and fhyVay about
the bird that had been presented to me. | showed

i. Stalls, and Pieier ine bird. After informing
the plant about the cadaver bird | went to where the birds
are slaughtered on Line #3 and observed the birds going
through the kill machine, past the backup killer, and just
before they entered the scalder. | observed these areas for
approximately 10 minutes total. During that time, | did not
see any birds go past that were not properly slaughtered. |
also reminded_jhiral_|and| that the PPIA and
Agency regulations require that live poultry be handled ina
manner that is consistent with good commercial practices
and that they not die from causes other than slaughter. |
referred them to Federal Register Notice Vol. 70, No. 187,
which they have, and | recommended that they review it for
FSIS recommendations concerning treatment of live
poultry before slaughter. | notified them that this MOI will
be forwarded to the District Office and the District
Veterinary Medical Specialist (DVMS) in case additional
follow-up is recommended.

52


Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P274V27 Tyson Foods, Inc. JYK5221052 21MAY2020 | 04C05 | PoultryGood | Finalized | 00027P, Tyson Foods On May 21, 2020 FSIS inspection
521G Commercial and plant management met at 22:00 on night shift to.

Practices discuss a failure to follow Tysons animal well-being training
procedures. The following people were in attendance.

Fis: [—fhire_—_JPant Management: Richard
Castor, GPM Plant management informed the nights of the
findings. Live Receiving
(05/19/20 and 05/20/20)
(05/20/20) Fill-in GPM On 05/19/20 at approximately
02:15 hours while performing the nightly GCP/animal
well-being task I found a chicken (hen) that was breathing,
eyes were open and able to move in the DOA tank outside
of Live Receiving. | immediately informed the Live
Receiving Supervisor of the finding and explained the
importance and need to ensure that no live chickens are
placed in a DOA tank. The supervisor spoke with the team
member responsible for sending dead chickens from the
hanging chain to the tank on how to handle DOAs. As this
was the first time in approximately two years that a live bird
was found in a DOA tank no further actions were taken by
inspection. On 05/20/20 at approximately 21:35 hours
while performing the GCP/animal well-being task | went to
observe the DOA tank outside of Live Receiving. At that
time, the DOA tank was approximately two-thirds full. |
noticed a chicken was struggling to move under

several carcasses that had accumulated on top of it. |
immediately asked a nearby employee to call the Live
Receiving Supervisor to the DOA tank. While waiting for
the supervisor to arrive, | immediately began digging the
bird out from under the carcasses. | had to remove
approximately eight carcasses off the buried chicken
(rooster) before it was free. The rooster was lively, eyes
open and able to move after being taken out of the tank.
The supervisor was informed that this being the second
occurrence this week a MO! may be issued. Management
had a meeting with the Live Receiving team members on
the importance of following the animal well-being training.
The team member responsible for the DOAs at the time of
this finding (not the same team member from the finding on
Tuesday moming) updated his animal well-being training
before the end of the shift. In the 22:00 hour time frame |
met with the Whole Bird Pack-out Supervisor to discuss
the finding in Live Receiving and to inform her that there
would be a MO! issued. In the 02:00 hour time frame | had
another meeting with the WBP Supervisor to discuss
corrective actions taken by the establishment. Management
was informed on the nights of 05/19/20 and 05/20/20 that
it's unacceptable to allow live chickens in the DOA tanks.
Given that no incidents had occurred in the past two years,
having two occur within the same week is concerning and
indicates a potential loss of process control.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29,2020 42

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P764 Perdue Foods, LLC CUA0107053 O9MAY2020 | 04C05 | PoultryGood | Finalized | A meeting was held between me
609G Commercial (bie) in
Practices Tbe) at P-764) and aatva
ele) 075 hours in
Office at P-764, Perdue Foods, LLC (Salisbury, MD). The

meeting was held to discuss poultry welfare concerns that |
observed this morning while performing the poultry good
‘commercial practices inspection in the receiving
department. At approximately 0740 hours | had entered
receiving through the grading department door and

observed conditions at the sorting table near the Dead Oi
Arrival (DOA) and inedible dumpster/bin. Birds were piled

()

(6)

2-3 deep beneath the exits of the conveyors leading to [hi
table from both kill lines. | proceeded to perform ante
mortem inspection, then found|___jhy(@)_ acting
receiving supervisor) in the receiving office to noti

the conditions at the sorting table that needed to be
addressed. | proceeded to walk into the picking/dressing
room areas. | immediately went to inspect kill line 1
because | knew that that line had just started to break (the
live hang crew had been seen near the receiving office)
and | wanted to see the birds at the pre-scald area. As |
passed the kill room for kill ine 1, | could see no further
birds on the line heading to the kill machine. | passed the
Kill room and observed birds exiting the pre-scald scrub
brush unit and then enter the scalder. At 0745 hours, |
observed one of these birds looking at me with open eyes,
a flexed neck, and no app it enter the scalder. |

immediately went to find | went through the
live hang room and pass‘ igh the table by the DOA
dumpster again (no one was there and there continued to

6)

be birds piled up 2-3 deep with live birds on top 0
and non-ambulatory birds), then found
receiving office at 0748. | notified|_—jthat ad seen a

live bird enter the scalder on kill ine 1. | (j9)(6) | said they
would contact the company that reviews the poultry welfare
videos and see if they could find the bird that entered the
scalder at 0745 so they could investigate through video
footage. | reminded hat the PPIA and Agency
regulations require that lve poultry be handled in a manner
that is consistent with good commercial practices and that
they not die from causes other than slaughter. | notified
Ithat this memorandum of interview (MOI) would be
forwarded to the District Veterinary Medical Specialist
(DVMS) in case additional follow-up was recommended. |
attest that this memorandum contains all of the information
discussed at this meeting, to the best of my knowledge.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020 5

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
M579+P579+ | Jennie-O Turkey Store Ul03412055 30MAY2020 | 04C05 | PoultryGood | Finalized | GCP MO! dated 05/30/20 At approximately 10:00 am on
579 130G Commercial Saturday 05/30/20, |, noticed the
Practices red alarm lights were on in the live hang area. The monitor

stated that there was a south conveyor fault. | also
observed the overhead lights were on in the SW corner
over the front half of the tractor trailer, which, was up on
the lift. | observed (2) dead birds laying in the
waste-water trough and (1) live bird standing in the
waste-water trough at the bend prior to the feather elevator.
There was no cover on the bend of the waste-water trough.
removed the live bird from the trough, so, that it wouldn't
get swept away and killed. Additionally, | saw birds falling
from the overhead walkway onto the truck and ground
(approximately 4-5 birds) with one of the birds ending up
under the trailer lif, | observed (2) establishment
employees removing birds from the conveyor by hand due
to.a clog on the south conveyor, while, the conveyor was
still operational. They were observed pushing birds forward
through the clog while pulling others from the conveyor all
while the conveyor was still in motion. They were pulling
birds from (2) side doors on the conveyor initially, and

then through a 3rd door later. Additionally, | observed
employees still unloading birds into the south conveyor
while trying to address the clog. Some of the birds
observed on the walkway were motionless-dead, some
alive, and others recovering from asphyxiation. After
employees had worked through the clog, | observed (2)
establishment employees adding dead birds back into the
system. | immediately told them to stop by putting my
hands up and went to find and notify a supervisor of my
observations. No Supervisor was immediately present
during the incident. When | returned to the area, | noted
that the employees had loaded additional dead birds back

into the system after | had motioned to stop. | notified the
lead to call for the 1st sit) away
and for’ (hw A) ‘to discuss the

ie ‘observations, and my concerns. | spoke
with individually initially at approximately 10:10 am

and .d him that | had observed employees working
through the clog, pushing birds forward while pulling others
all while the conveyor was still operational. | stated that |

saw birds fall nto the waste-water trough, which was npt rj)
covered, birds falling from the walkway onto the truck and
ground, dead birds, live birds, and birds regaining

consciousness on the upper walkway. Additionally, aw
employees adding dead birds back into the conveyor once
the clog had been cleared, | informed at dead

birds from the clog are not eligible for slaughter and should.

not be added back into the conveyor to run through the | (0)(6)
system as they died from causes other than slaughter. |

observed approximately 10-15 dead birds (dead
asphyxiation). | later spoke with both|



Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 35

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P48304 Lincoln Premium Poultry YOT1315054 12MAY2020 | 04C05 | PoultryGood | Finalized | On 05/11/20, at approximately 1822 hours, while
312G Commercial conducting a routine poultry good commercial practices

Practices (GCP\task at Lin ium Poultry (Est. P48304),
relief! (D6) __ did note the following deviation
from poultry good commercial practices. In airage, in the
area between conveyor belts where kill/pick (KP) line three
makes its final tum towards stack off, a live bird was noted
sitting on the floor outside of the lairage cages. No

establishment employees were seen in the area attempting wal
i

to retrieve the loose bird, and there was no indication that
the establishment was aware that there was a loose bird in

lairage. At approximately 1832 hours | located Lait
and notified| (of the loose bird

picked up the loose bird and
placed it back into a airage cage. [ayaa then
accompanied me for the rest of my GCP task, where we
identified three additional birds loose at various points
along the conveyor belts in lairage; one further along the
conveyor belt under KP line three, one undemeath KP line
two, and one undemeath the electronic control panel in the
alcove off to the side of stack off for KP line two. These
birds were also picked up and placed back into lairage

cages. | ()(6) _|was notified that a GCP MOI would be
i

issued forme Toose birds in lairage. | met wil

(b\(6). egarding the loose birds
i lairage and see if they could get an extra person back
(b\(6) | | there. Inotified{~jpy@)__ hata GCP MO! would be
issued. Loose is not consistent with
poultry good commercial practices and results in an
increase risk of birds dying by means other than slaughter.
The Poultry Product inspection Act and Agency
regulations (9 CFR 381.65(b)) require that live poultry be
handled in a manner that is consistent with GCPs. The
establishment is encouraged to maintain the standards of
GCP 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 FSIS
recommendations concerning the treatment of live poultry
before slaughter. Eo as notified that this
Ol willbe fowardeaTo te Dever Distict Office and the
District Veterinary Medical Specialist (VMS) in case
additional follow-up is recommended. Regards,

(b)(6)



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P19688+V19 | Sanderson Farms, Inc. KJA0816041 10APR2020 | 04C05 | PoultryGood | Finalized | On Friday April 10, 2020 at approximately 1504 hours |
688 710G Commercial observed the employee stationed at the back up cutter on
Practices picking line #1 fail to slaughter a bird that was directly after

a bird hung by one leg. The live bird was again observed
prior to the scalder entrance where Processing Manager
Stopped the lie and removed the
bird. At that time, we were able to confirm that the bird was

in fact alive,
was removed

restarted the line. First

(by) |, put the bird

back on the line prior to the stunner and it was properly
slaughtered. If | had not observed the live bird at the back
up cutter and acted, the bird would have entered the
scalding tank alive. 9 CFR 381.65(b) requires that
poultry be slaughtered in accordance with GCP and ina
manner to ensure breathing has stopped before scalding.
Furthermore, 9 CFR 381.90 states that poultry carcasses
showing evidence of having died from causes other than
slaughter are considered adulterated and must be
condemned. As immediate corrective actions to prevent
‘ongoing bird suffering and adulteration of product,

said he would provide training for the live
hang employees as well as for the employee stationed as
the back up cutter. Preventing mistreatment and
slaughtering poultry in compliance with 9 CFR 381.65(b)
decreases the chances of producing adulterated
carcasses) (b\(6)

21


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P445

Wayne Farms, LLC

FKA2313063
610G

10JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 06/09/20, at approximately 09:00, while performing a
Good Commercial Practices (GCP) task | observed one
live bird in the DOA condemn vat in the live receiving
department. Upon further visual examination, the bird was
liberally doused with denaturant and was still breathing and
stil had its head attached. (The normal procedure is to
remove the head before placing the bird in the DOA vat) |
also saw one dead bird with its head stil attached in the
DOA condemn vat. | met with| (b)(6)

to discuss my finding a live bird in the DOA
c

condemn vat. He removed the live bird and decapitated it

before placing it back in the DOA vat. | notified (51/6)
(bV6) bf my findings. | also met with

|to discuss

(bx),
my findings. Ifthe live birds would have remained in the
DOA condemn vat, itis likely they would have died by
asphyxiation due to being smothered by dead birds being
placed on top of them. PPIA and Agency regulations
require that live poultry be handled in a manner that is
consistent with good commercial practices (GCP), and that
they do not die from causes other than slaughter. |
recommend that management review Federal Register
Notice Vol. 70, No. 187, published September 2005
[Docket No. 04-037N] for FSIS recommendations
concerning treatment of live poultry before slaughter. A
copy of this document can be provided on request.
Please provide an explanation for this incident. A copy of
this MOI and your response will be forwarded to the
Raleigh District Office and the District Veterinary Medical
Specialist (DVMS) in the event that an additional follow-up
is recommended.

P445

Wayne Farms, LLC

FKA3812060
515G

15JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

Today, June 15, 2020, at approximately 1208, while
performing a poultry good commercial practices (GCP)
check, | observed 3 birds go into the scalders, alive and
breathing. The last 2 birds were observed within a 30.
second timeframe from the first, approximately 1 minute
into my check. The birds all had their eyes open, were
attempting to hold their heads upright and appeared alert
and responsive. | did not observe any evidence of cuts on
or around the neck of the birds. | travelled to the scalder
exit to confirm whether or not there were any cuts that
were not readily visible at the time of my initial sighting and
all three birds appeared to have hyperemic skin, which
was more pronounced around the head and neck areas,
with no evidence of any cuts having been made to the
carcasses. _limmediately informed [caval _]
thy) of the nonconfomance and he

initiated corrective actions. At approximately 1318, |
performed a follow-up GCP check to verify the
establishment's corrective actions and found no additional
nonconformances.

27


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020 23

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P2186 GEORGE'S FOODS, LLC ¥JO4518060 19JUN2020 | 04C05 | PoultryGood | Finalized | The following GCP poultry mistreatment incident occurred
119G Commercial on 6/18/2020. At approximately 17:15, |,

Practices

was verifying the denaturant sprayers. | noticed they were
not working, and that condemned product was being
disposed with no denaturant ink. An employee stood next
to.a drain, leading to the auger, with a gray condemn
barrel. | went to look if the product had been denatured but
noticed that they were DOA’s from live hang. He was
picking out birds one by one, and after disposing of 4-5
birds in the drain, there was movement and noise coming
from the barrel. The employee dug live, healthy bird from
the barrel, grabbed it by one leg, and looked at me for
instructon, [immediately called over Ey

(C7) |who was standing nearby. He instructed the

‘employee to take the bird back into Live Hang. At the
moment of my finding, | was concerned that the bird could
have been injured or killed by being crushed, suffocated
or drowned in the drain. When | spoke mC]
he told me in Spanish that ‘this is an issue they Rave offen,
as birds jump from the live hang belt and fall into the
condemn barrel all the time.” | explained that my concern
was that the bird had possibly been buried for a prolonged
period, since it had several DOAs on top of it, and that |
would be notifying my supervisor of these observations. At
approximately 17:35, daya)_land |, spoke with h\6))
poutine incident. During our
conversation, | expressed my concerns about the
mistreatment of the bird, as well as how the incident was
handled by the employee and the Live Hang Supervisor. |
also notified[ 7174) |that | had spoken with [fara _|

(sé) _|and he had contacted our| bY6)
(b\(6)_|said he would “take action and make sure they

monitored more often” and to “t know aboutany

feedback from USDA supervisors”. USDA will be
performing additional checks in the area to ensure

1b)(6)

continued proper treatment of poultry. A copy of this MO!
will be sent to our FLS and DVMS, as well as kept on file in

the USDA office.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29,2020 36

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P510 House Of Raeford Farms RHBO212051 21MAY2020 | 04C05 | PoultryGood | Finalized | At 0534 hours on 05/21/2020 | was conducting a Good
321G Commercial Commercial Practice verification task in the kill/picking

Practices

area behind the evisceration department. | was observing
the birds on the line after they had exited the blood tunnel
and prior to entering the first scalder. | observed one bird
that had its head elevated, was looking around, and was
blinking. The line was stopped by (b)(6)

(b)(6) and the bird was removed from the
shackle. It was breathing, alert, looking around, and
blinking. Upon further exam of the bird | noted there was
nota cut on its neck. | reminded [7/41
regulation 381.65(b) in CFR 9, poultry must be slaughtered
in accordance with good commercial practices in a
manner that will result in thorough bleeding of the
carcasses and ensu reathing has stopped prior to

entering the scaider. changed out the current back

up cutter and discussed the issue with hel caso |
contacted the maintenance department who chang}

ib)(6)

the kill blade and adjusted the height of the shackles on the
line, The bird was taken back to the live hang area and
ving Li d the issue with

{b)(6) | continued
monitoring the birds on the line before they entered the
scalder and saw no further issues. The latest occurrence
of a similar situation at this establishment was documented
on 03/24/2020 See MO! RHB1309033124G. A copy of
this MOI will be forwarded to the (BY6)

(bye) jand to the circuit
If you have any questions you can
Respect,

(by(6) P510



Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 18

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda

P165H OK Foods, Inc. DAF3807053 23MAY2020 | 04C05 | PoultryGood | Finalized | At approximately 0623 on 5/23/20, while performing a good
923G Commercial commercial practice check, | observed a
Practices sensible bird (eyes closed, head up held close to the body)
proceeding down the line and into the line 1 scalder. |
traveled down the line and observed a cadaver exit the
pickers. | removed the cadaver from the line and
examined it. There was no cut on the neck. [__(b/6)
[ ThYAY was notified of my
observation and shown the cadaver. (b)(6)
was also shown the cadaver. The incident was discussed
later (approximately 0720) in the supervisor's office with
Caine Tana THVAY
Ce elaine that after she was
Shown the cadaver, she proceeded to the kill room and
‘observed the plant employee responsible for monitoring for
sensible carcasses on line 1 looking at his cell phone as
carcasses went by. The employee was immediately
removed from that position, suspended until further notice,
and escorted off the premises. A different plant employee
was placed on line 1 monitoring for sensible carcasses.
Later in the shift | performed a recheck and observed zero
sensible birds prior to the scalder.

P165H OK Foods, Inc. DAF5810051 28MAY2020 | 04CO5 | Poultry Good Finalized On 5-28-20 at approximately 0948 while performing a good
9286 Commercial commercial practice check. || jy/)_ ] observed one live

Practices bird in the DOA dumpster outside the live hanging room.
The bird was partially covered by DOA’s and had red dye
onit. | observed a rhythmic in and out motion of the bird's

|(b)(6)

abdomen as it breathed. | immediately requested that the
back-dock supervisor come to the area. Upon [ arrival,
Ishowed| hay The ive
bird in the dumpster and notified [ —|that a GCP MOI
would be issued. A plant employee reffioved the live bird
from the dumpster. During the removal process the-bird
opened its eyes and began trying to fly. After being he
removed from the dumpster, the bird immediately
underwent cervical disarticulation. Past practice at this
facility is for all birds to receive cervical disarticulation
prior to being placed in the DOA dumpster. The
establishment's Animal Welfare Program states “Do not
place any live birds in the DOS containers.
explained that the employee responsible would receive
additional animal welfare training.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P1209

Whitewater Processing Co.

FFG1408051
008G

O8MAY2020

04C05

Poultry Good
Commercial
Practices

Finalized

‘At 0910 hours while observing birds entering the scald tank
as part of a routine GCP task, observed the
following. Multiple old Breeder turkeys (Hens) were
observed to be breathing and raising their h
production line just before the scald tank.
stopped the line multiple times. Plant persi
removed the birds from the line and rehung them prior to
the stunner. | ())(4) | then restarted the line multiple
times. went immediately to the office and
discussed the finding with This is a violation
of 9 CFR 381.65(b) which states: Pouliry must be
slaughtered in accordance with good commercial practices
ina manner that will result in thorough bleeding of the
carcasses and ensure that breathing has stopped prior to
scalding.. explained that this issue continues to
occur. The Tast oné occurred ten days ago

(04/28/2020) . There had been a extended period where
there were no occurrences but today was terrible . Further
corrective actions need to be implemented. He stated he
would discuss this with management and they would take
immediate corrective measures which included reviewing
findings with plant personnel. | again stressed that it is not
a condition that the birds are not cut but are not adequately
cut, meaning that only one carotid is cut and the birds are
regaining consciousness prior to bleeding out.

the

P1243

Perdue Foods, LLC.

XLB3812064
317G

17JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

(b)(6)

On 06/17/2020 at approximately 1308 hours, while
performing the Good Commercial Practice Verification
Task | observed a live bird in the DOA bin, It was on top of
the pile and had no denaturant applied during the time of
my observations. | observed the bird was continuing to
breath, blinking its eyes and moving head. | came closer to
the DOA bin to ensure that the bird inside of the DOA bin
was still alive and it was. (bY6)

THVAN came, and | informed and showed
| = Iny observations.| _()i/G) _pgreed that the bird was
fully alive. The rehang lead person picked the bird up and

saw that it was breathing, moving its head, blinking and
kicking. He agreed that it was alive. At this time, he had
placed the bird back on the rehang table to rehang it back
tothe line. Perdue Foods LLC. establishment #1243 P-
has established a protocol that any birds should be
confirmed dead prior to entry the dead container. If a bird
is questionable, it should be hung as a suspect prior to
making a determination. | prepared this report on
06/17/2020 and | certify that this report has recorded in it
a summary of all pertinent matters discussed. This MOI
is associated with MOI # XLB5400042120G dated
04/20/2020.

10


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

33

EstNbr

EstName

Task

MOINbr Date Code | TaskName

MOI Agenda

P48304

Lincoln Premium Poultry

YOT0408041 21APR2020 | 04C05 | Poultry Good
321G Commercial
Practices

Finalized

On Tuesday April 21, 2020, at approximately 0620 hours, |
observed the following deviation from Good Commercial
Practices (GCP) while performing a poultry Good
Commercial Practices task in the live-hang room of Lincoln
Premium Poultry, Est. P48304. On Line 2, at the
dead-on-arrival (DOA) sorting station, | observed two live
young chickens in a red condemn barrel. The first chicken

I saw was near the top of the barrel, and although the
chicken was weak, | noticed it was still breathing and
moved its foot when | picked it up. | looked further into the
barrel and underneath deceased chickens | found a
second chicken that was moribund but still breathing.
There were approximately 10 deceased chickens in the
barrel with the two live chickens. The DOA sorting
employee removed the two the barrel.
rote ve hongh TOMB ot ne good

commercial practices concem. He elected to humanely

euthanize the two live chickens. It is not consistent with
Poultry Good Commercial Practices for live birds to be
placed in condemn barrels, where they may die of causes

TOS)

other than slaughter. Following this incident, | discuss
the poultry Good Commercial Practices concem with]

fine Jand[_ =]

(VAY ] The Poultry

Products Inspection Act and Agency regulations (9 CFR

(b)(6)
|

381.65(b)) require that live poultry be handled in a manne!
that is consistent with Good Commercial Practices (GCPs).
The establishment is encouraged to maintain the standards
of GCP 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 treatment of live poultry
before slaughter. This MO! will be forwarded to the
District Office and the District Veterinary Medical

Specialist (DVMS) in case additional follow-up is
recommended. Sincerely, Th)



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P48304 Lincoln Premium Poultry YOT2415043 03APR2020 | 04C05 | PoultryGood | Finalized | While performing antemortem inspection at Lincoln
003G Commercial Premium Poultry, Est. P48304, at approximately 4:30 a.m.

Practices

on April 3, 2020, | observed a higher than usual number of
deceased and moribund young chickens at the
establishment. | performed antemortem inspection ona
trailer of young chickens that had just entered the
establishment. The majority of the chickens were huddled
to one side of the trailer, causing them to pile up on one
another. The chickens were damp from the weather, and
the live chickens were quieter and more depressed than
typically observed. Many chickens that were underneath
other chickens were deceased or moribund. There were
additional deceased and moribund chickens that were not
underneath other chickens. The chickens that had arrived
previously at the establishment, and were being held in the
lairage room, were of similar condition. The DOA
incidence for 1st shift on April 3rd was 1.2%, which is 4.5
times higher than the average of 0.27% for the week prior.
The establishment recently changed from using winter
protective curtains to summer protective curtains on the
trailers, as the weather has warmed up. On the morning of
April 3rd, there was a dramatic drop in temperature and
freezing rain preciptation, I met with

REA Tat approximately 5:00 am. to inform him
of the situation. He increased the temperature in the
lairage room to help warm the chickens, had employees
help disperse the birds in some of the trays so they weren't
as piled, and assigned additional employees to help
remove deceased chickens at the DOA sorting stations. As
the day progressed and the weather improved, there were
fewer deceased and moribund chickens arriving in the
trailers. 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 381.65(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 of GCP 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 FSIS recommendations concerning the treatment of live
poultry before slaughter. This MO! will be forwarded to the
District Office and the District Veterinary Medical
Specialist (DVMS) in case additional folloy is
recommended. Sincerely, YG)

30


Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 7

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
M751+P1049 | Pitman Farms Inc. (Moroni Turkey Processing) | MMK491706 10JUN2020 | 04CO5 | PoultryGood | Finalized | Memorandum of Interview to Discuss Birds Dying by
3810G Commercial Means Other than Slaughter Pitman Farms / Est# P01049
Practices Meeting Time: Thursday, June 11, 2020 at 1020
Attendees:
USDA

Establishment

eye) | 7 Mr Mike Vance, VP of
Operations] THA
fivray Mr Jaime

Rodriguez, Plant Manager This meeting was necessitated
by observations made while performing a Good
Commercial Practices task on Wednesday, June 10,
2020. At approximately 1205, | observed a trailer of hens
being unloaded in the hanging bay that contained birds
which had been transported from Minnesota and had a
high number of DOA carcasses. The number of DOA birds
on the tailer resulted in carcasses piling up under the
catwalks that employees use to empty the trailers and the
need for two dumpsters to be brought into the bay to
collect the dead birds. After the first trailer of hens had
been emptied, employees reported 377 DOA on the trailer
which had been identified to be a load of 2304 hens
(37712304 represents 16% of the load). A second trailer
of hens and three trailers of toms from Minnesota were
also unloaded with similar findings observed. While
observing a trailer of toms being unloaded, | observed
three birds get dropped to the floor of the hanging bay
from the high end of the catwalk which were moribund but
not dead. The catwalk is a stepped platform that varies in
height from approximately two feet at the low end to
approximately eight feet from the floor at the high end.
Upon contact with the floor, | observed one bird flap its
wing and attempt to right itself and two others raise their
heads. The birds exhibited eye blink and panting but soon
expired. also observed one live bird get
dropped that then raised its head and shook prior to.
expiring. One of the birds was also contacted by another
dead carcass that landed next to it while on the floor of the
hanging bay.[____ fia) was
presentto be notified and shown the birds. At 1630, |
notified Mr Vance verbally of the forthcoming issuance of
this MOI for the moribund birds that were being treated as
if they were already dead. The Poultry Product Inspection
Act (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. The following morning, | met with
Mike Vance and Jaime Rodriguez to formally review the
incident. A copy of FSIS Directive 6110.1 Verification of
Poultry Good Commercial Practices was reviewed and
provided to management as the directive also addresses
the mistreatment of live poultry before slaughter. We



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020 6

EstNbr

EstName

Task

MOINbr Date Code | TaskName

Status

MOI Agenda

(approximately 10:20 am) reiterating that dead birds are

|

§b)(6)

not eligible for slaughter. The establishment shot é
birds were condemi Femoved from
istated to at he wanted to have a
meeting with all Live Hang employees at the end of the day

ident [iy ra Jcondemned 35 birds from
the clog incident. | am not confident that the establishment
was able to account for alll the dead birds that had been
added back to the conveyor and run through the system by
employees. | informed|}))(6 that | would be documenting
a GCP MOl of the incident.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P17766

Southern Hens, Inc

SSN2517041
130G

30APR2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 04/30/2020 at approximately 0914 hours, the following
less than Good Commercial Practice (GCP) incident was
observed at P17766, Southern Hens Inc., Moselle, MS
while performing the routine PHIS GCP verification task. In
the back-dock area,|____—(b\(6) __| witnessed
four crates of live birds actively tossed from a trailer onto
the conveyer belt by a Southern Hens employee. The
crates that were tossed bounced onto the conveyer belt,
tilted on its side, and then fell onto the side walk way below.
There were no ‘slides’ observed to be utilized by th
employee on the inside trailer area. | informed
[Tazz J First Processing Superintendent, of
TPatccturred and the details that observed. | stated that
this was a less than ideal management of the live birds

P17778

ENA Meat Packing Corp.

TTMMZ3313065
802G

02JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

Establishment P17778, ENA, May 28,2020, 0920 hours.
an attendance |_—-ornWaN |

ame ]Mr. Ali
eon approximately 0915 hours while inspecting
Birds on the Evisceration line a total of seven Cadaver
Birds were pulled of the line and hung on the hang back
rack at various intervals. | stopped the line and closely
examined the red Cadaver birds and observed two of the
Birds were not cut or lacerated with a knife, the were
apparently allowed to go into the scalder alive. Five of the
Birds were not properly slaughtered, the cut to the neck
were not deep enough to allow for proper bleeding to
‘occur. | proceeded to the kill floor and observed that two of
the employees on the kill floor were new and | also
‘observed two birds on the floor bleeding and still walking. |
wentto the producion Managers offce [Thal]
and immediately after to the Establishment owner, Mr. Ali
and informed them both of the violation of Good
Commercial Practice - inhumane handling of Birds by their
employees. Mr. Kucukkarca, Owner ee
[xz immediately went to the kill floor to address the
egregious handling of live Poultry. The affected birds were
condemned as Cadavers and production continued.
Establishments hereby advised to review the Federal
Register notice on Treatment of Live Poultry.

19


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020 9

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

M810+P810,

Pilgrim's Pride Corporation

HAJ5503064,
026G

26JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

At 00:47 Kill ine 2 when down leaving 24 birds inside the
stunner[ asia] waited 30 seconds for the line
to start up before looking into the stunner. Upon closer
look the bird's heads were submerged, in the water at the
bottom of the stunner with 4 birds reacting enough to try
and remove their heads from the water. On finding the
birds in this condition CSI notified thé)

(HVA who sentline leader| (ha) _|to
correct the problem. By the time CSI got back to the kill
room the stunner was being lowered removing the bird's
heads from the water, but the 4 birds were no longer
responsive leading to the belief they had drowned. This
eventwas discussed by[_ thie with live hang
supervisor. [Tava |discussed: That the birds were
not Killed in a manner that results in thorough bleeding of
the poultry carcass and ensures that breathing has
stopped before scalding, so that birds do not drown.

Cay vesponse: When the kill line down more than
@ minute he will have someone making sure that no birds
will drown that way again.

P1209

Whitewater Processing Co.

FFG1008041
628G

28APR2020

04C05

Poultry Good
Commercial
Practices

Finalized

‘At 0900 hours while observing birds entering the scald tank

as part of a routine GCP task, | (h\/4) | observed the
following. One (1) old Breeder turkey (Hen) was observed

to be breathing and raisin clon the production line
just before the scald tank. | (0)(G)_| stopped the line.
Plant personnel then removed the bird from the line and
rehung it prior to the stunner. then restarted the
line. [ ()\/6) | went immediately to the office and
discussed the finding with This is a violation
of 9 CFR 381.65(b) which states: Poultry must be
slaughtered in accordance with good commercial practices
in amanner that will result in thorough bleeding of the
carcasses and ensure that breathing has stopped prior to
scalding.. | explained that this issue continues to occur.
The last one occurred six months ago (10/24/2019). This
shows a vast improvement but we still need to strive for
zero occurrences. Further corrective actions need to be
implemented, He stated he would discuss this with
management and they would take immediate corrective
measures which included reviewing findings with plant
personnel. | again stressed that it is not a condition that the
birds are not cut but are not adequately cut, meaning that

only one carotid is cut and the birds are regaining
consciousness prior to bleeding out.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P308 Koch Foods, Inc SPL1010053 13MAY2020 | 04C05 | Poultry Good | Finalized | At approximately 0748 hours, while performing a portion of
813G Commercial the Good Commercial Practice task and as | was
Practices observing the conditions in the Live Hauling area, |, 1/4)
[ea observed a live bird breathing but covered
by a pile of DOA inside the DOA bin. | immediately
notified nearby Koch team member, Corey, of my findings.
He proceeded to remove the bird from the DOA bin. The
bird, once freed, began to flap its wings with eyes open
and alert. | informed establishment{__(1))(6)
(bY6) of this finding and the forthcoming
issuance of this MOI.
P33900+V33 | Foster Farms NHH1400062 23JUN2020 | 04C05 | PoultryGood | Finalized | Est. P-33900, Foster Farms at Farmerville, LA in June 22,
900 423G Commercial 2020 at 2210 hours. In lieu of face to face meeting,
Practices e-mails are exchanged with the followina:!_T5y/6)

(bY(6) |L_ye\__ [Foster
Farms| Thay Foster
Farms[_____rmy2i___JAtapproximately 3:44
hours, 22nd of June 2020, | spot checked the vats by the
hot rehang table and found S young chicken cadavers
(with intact head with small or no cut in the neck, reddish
discoloration of carcass and neck, head and neck with
hematoma). There is one young chicken cadaver by the
drain. Another 2 young chicken cadavers came by on
shackles by the hot rehang table. [____chwal__lis.
summoned to the area. He concurred that the 5 young
chicken on the vat are cadavers.
said, he lowered the voltage of the stunner to control
vigorous wing flapping of the young chicken. That results
to failure by the back-up cutter to spot uncut necks
smeared by blood. According tol___(ray he
turned back the stunner on to normal setting to resume
stunning the young chicken as usual. For preventive
measure, 7irai___|Sald he will re-train all
concerned employees. |reminded| (isi land
feat 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. | also
recommended to both of them to review Federal Register
Notice Vol. 70, No. 187, published September 2005
[Docket No. 04-037N] for FSIS recommendations
concerning treatment of live poultry before slaughter. In
the e-mail, | attached a copy of the said document for their
perusal. | also notified both of them that an MOI will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended. Respectfully, (hV6)

(b¥6) pt P-33900 Foster Farms, Farmerville,

25


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29,2020 1

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
M20322+P20 | Equity Group Eufaula Div LLC ATFO313052 27MAY2020 | 04C05 | PoultryGood | Finalized | On 05/27/2020, at approximately 1138 while performing my
322 127G Commercial Good Commercial Practices at the entrance of the scalder
Practices on Line 3, and myself

observed four uncut, live birds pass by at approximately
1138 (pair #1) and 1139 (pair #2). | noted that the
birds were breathing and alert to their surroundings. At the
point of observation, the establishment has
no further humane measures in place to ensure that all
breathing has stopped prior to entering the scalder. |
visually followed the birds as they entered and exited the
head puller (prior to the entrance of the scalder) and into
the scalder where both set of pairs entered still breathing. |
immediately notified 1st (hVAy and

6 of my observations.
Afier notification, the establishment elected to immediately

suspended hanging operations. In speaking with [=~ TG
feel itwas determined that the backup killer was a (0)(6)
newly trained employee performing this specific job for the

first time. Management replaced this employee with an
experienced employee and resumed operations. At
approximately 1208, once corrective actions were in place,

=\(41_|and myself performed an additional, extended
GCP check to ensure that corrective actions were

effective. No further deficiencies were observed.
[.xZe)stated that in the future when there is a newly
trained/hired employee, they will have a second trained

(b)(6)

individual at the backup kill position to ensure training
effectiveness. Equipment effectiveness was also evaluated
and no obvious issues were noted. No other vulnerabilities
were noted during today's production.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29,2020 48

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P9197 Perdue Foods, LLC. UAB2712040 20APR2020 | 04C05 | PoultryGood | Finalized | On 4/17/20 at approximately 1130 hours the inspector on
720G Commercial line #3 stand #3 presented me a cadaver bird. The bird
Practices had its head and neck attached which was bright red to

purple in color. The neck of the bird had no cut mark on it
and was fully intact, indicating that the bird was not bleed

out thoroughly in accordance with 9 CFR 381.65(b). |

informed [ (hy Ay ] (b)6)

been presented to me. | showed
the bird. After informing the plant about the cadaver
bird | went to where the birds are slaughtered on Line #3
and observed the birds going through the kill machine, past
the backup killer, and just before they entered the scalder.
| observed these areas for approximately 10 minutes total.
During that time, | did not see any birds go past that were
not properly slaughtered. | also reminded and
eal tot 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. | referred them to Federal
Register Notice Vol. 70, No. 187, which they have, and |
recommended that they review it for FSIS
recommendations conceming treatment of live poultry
before slaughter. | notified them that this MOI will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended.

and linea labout the bird that had
Lies Janda



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

Task
MOINbr Date Code | TaskName

Status

MOI Agenda

seen a pileup of dead birds at the DOA table at the end of
the DOA chute last Thursday (April 23, 2020), and | had
documented my observations in my GCP task findings
notes and in the Establishment Weekly Meeting on April 24
(MOI#UVG2110042324E). | told Mr. Groseclose | would
rovide a copy of this MOI to my L__asvay

())(6)] and to our fhV4) for review (in

accordance with Directive 6110.1: Verification of Poultry

Good Commercial Practices). Mr. Groseclose told me he
would get in touch with|__(b\(6)__|regarding the

incident.

12


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29,2020 11

EstNbr

EstName

Task
MOINbr Date Code | TaskName

MOI Agenda

P1249

George's Chicken, LLC

UVG4812055
904G Commercial
Practices

(b)(6)

O4MAY2020 | 04CO5 | Poultry Good Finalized

The following Good Commercial Practices (GCP)
Memorandum of Interview (MO!) summarizes the events
witnessed byme,[ (ha) __land[|_(hyva)

fi

On Thursday, April 30 at 1009 hours, during a GCP
Review and Observation, | observed the main DOA
(dead-on arrival) table at the end of the DOA chute in the
slaughter area with | _(h
the DOA table or on the DOA racks. At approx. 1010-1012
hours, | went to observe slaughtered birds as they entered
the scalders, and | then went into the live hang break room
to find a supervisor to address my finding of a dead
slaughtered bird under the blood tank.
meanwhile went to the kill station, then into live hang.

ji

h(i |on Thursday, April 30 during GCPs at P-1249.

There were no birds on

2nd shift CSI in on-the-job training) —t __
accompanied aa live hang. At approx. b)(6)
1018 hours, | re-entered the slaughter area and noticed a
rapidly growing pile of DOAs on the DOA table at the end
of the DOA chute. The pile was at least 3 birds high with at
least 20 birds on the table. As | approached, more birds
came down the chute, with the pile getting 4 and 5 birds’
high; however, | did not observe any live birds in the pile
DOAS. Atthis point [—frivei- asked me tojin
live hang to view the pile of DOA birds on the DOA tabléin
live hang. | went into live hang and saw a large pile of birds
at least 3 birds high on the DOA table at the end of the
conveyor belt leading from dumper #2. | saw live hangers
actively throwing birds onto the pile, and | also observed
three live birds on top of the pile. | expressed my concems | [5)(6)
that the birds were still alive, and as the DOAs were

continuing to pile up, these live birds could be smothered
inthe pile. | still saw live hangers throwing birds on the pile
as the line leads tried to clear out the birds. Abthis

moment,
hours) an
throwing birds o1 - nd} yees ((b)(6)
Began to clear out the large pile of birds on this DOA table,

as well as clear the DOA table at the end of the DOA

chute. After approximately 5 minutes, | _(\/6)_| and
ici

the other employees had the table sufficiently cleared of
DOA birds, and | returned to my office.
had to leave to attend to other inspection duties, but she
informed me that she had observed live birds on top of,
and buried within the pile of DOAs on the DOA table in live
hang. During a later discussion with i
learned that she had observed at least 3 live birds buried in
the pile and a total of 6 live birds altogether within and on
top of the pile. During a phone conversation with Mr. Sam
Grossclose (Plant Manager) at approximately 1130 hours, |
informed him that | would be issuing a GCP MOI! due to live
birds being buried in a pile of DOA birds on the DOA table
in the live hang area. | also explained that | had previously

b)(6)

(b)(6) came‘in (around 1020



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

Task
MOINbr Date Code | TaskName Status

MOI Agenda

P7927

AMICK FARMS, LLC

YGC0018043 29APR2020 | 04C05 | Poultry Good Open
429G Commercial
Practices

In the Pickin

Est. P-7927, Amick Farms LLC, April 29,2020 18:30.
i and

area at the prescalder line #2 at approximately 1627 hours,
lobserved a bird still breathing when entering the scalder.
At 1629 hours, | observed another bird entering the

scalder still breathing. Both birds were conscious and had
Uneutnecks [PENA
immediately notified of my observation. The corrective
action of the Establishment was to replace the back-up
cutter on line #2 with a more experienced back-up cutter.
Prescalder line # 2 was rechecked at 1823 hours and was
found acceptable. | notified [__cmirai___Ithat this MOI will
be forwarded to the District Office and the District
Veterinary Medical Specialist (DVMS) in case additional

follow-up is recommended. Respectfully,
P-7927 Amick Farms LLC

P7927

AMICK FARMS, LLC

YGC2021060 18JUN2020 | 04C05 | Poultry Good Open
418G Commercial
Practices

Est. P-7927, Amick Farms LLC, June 18, 2020 17:03
Hours. In attendance:[___iray_— and

[ (6) ] In the Picking
Room area at the prescalder line # T at approximately
1656-1658 hours, | observed 5 birds still breathing when
entering the scalder. All birds were conscious and had
uncutnecks.[ fai] was
immediately notified of my observation. The corrective
action of the Establishment was to replace the back-up
cutter on kill line # 1 with a more experienced back-up
cutter. Prescalder line # 1 was rechecked at 1725 hours
and was found acceptable. I've notified|__(hi/a) that
this MOI will be forwarded to the District Office and the
District Veterinary Medical Specialist (DVMS) in case
additional follow-up is recommended. Respectiully,
(aie P-7927 Amick Farms LLC



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020 32

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P48304 Lincoln Premium Poultry YOTS611040 16APR2020 | 04C05 | PoultryGood | Finalized | On April 15, 2020, at approximately 1351 hours, while
916G Commercial ‘conducting a routine Poultry Good Commercial Practices
Practices task at Lincoln Premium Poultry (Est. P48304), | observed

two loose live young chickens under the de-stack machine
on Line 3 in the live hang room. After observing for several
minutes, | did not observe any establishment employees

coming to retvieve the live chickens. | notified First Shit(5)(6]
[

TRAN land [ (hia |

CAVAY of the loose live chickens and the

Good Commercial Practices concen. 7hwAi directed
an employee to retrieve the two loose live chickens, which
was done immediately in a humane manner. Loose live
birds in the establishment is not consistent with poultry
good commercial practices and results in an increased
risk of live birds dying by means other than slaughter. The
Poultry Product Inspection Act and Agency regulations (9
CFR 381.65(b)) require that live poultry be handled in a
manner that is consistent with GCPs. The establishment is
encouraged to maintain the standards of GCP 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 FSIS recommendations concerning the
treatment of live poultry before slaughter. This MOI will
be forwarded to the Denver District Office and the District
Veterinary Medical Specialist (DVMS) in case additional

follow-up is recommended. Regards, (b)(6)



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29,2020 49

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P9197 Perdue Foods, LLC. UAB1708045 25APR2020 | 04C05 | PoultryGood | Finalized | On 4/25/20 at approximately 0655 and 0715 hours the
425G Commercial inspector on line #3 stand #3 presented me two seperate
Practices cadaver birds. Both birds had their heads and necks

attached which were bright red to purple in color. The
necks of both of the birds had no cut marks on them and
were fully intact, indicating that the birds were not bleed
‘out thoroughly in accordance with 9 CFR 381.65(b). |
informed |[ TES ]
ThWAY land
(b)(6). about the birds that had been
Pei Sented to me. Tshowed|_(b/4)_|[_(b\6) land|ib
[(5)(6)]the birds. After informing the plant about the
cadaver birds | went to where the birds are slaughtered on
Line #3 and observed the birds going through the kill
machine, past the backup killer, and just before they
entered the scalder. | observed these areas for
approximately 10 minutes total. During that time, | did not
see any birds go past that were not properly slaughtered. |
also reminded |__fhy6)_ | pie)_ | anal andiyral
(b)(6)]that the PPIA and Agency regulations require that
xe poultry be handled in a manner that is consistent with
good commercial practices and that they not die from
causes other than slaughter. | referred them to Federal
Register Notice Vol. 70, No. 187, which they have, and |
recommended that they review it for FSIS.
recommendations concerning treatment of live poultry
before slaughter. | notified them that this MOI will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P48304

Lincoln Premium Poultry

YOT2015040
108G

O8APR2020

04C05

Poultry Good
Commercial
Practices

Finalized

(b)(6)

On 4/7/20, at approximately 1820 hours, while conducting
a routine poultry good commercial practices task (GCP) at
Lincoln Premium Poultry (Est. P48304),
id note the following deviation from poultry
ommercial practices. In lairage, on KP line 3,

approximately 4-6 feet prior to the entrance to the CO2
stunner, underneath an area of the conveyor belt blocked
off with gates and under several pieces of machinery, a
live bird was noted sitting on the floor outside of the lairage
cages. On further inspection, a dead bird was noted
under the same machinery, with what appeared to be
blood on a wound on its head. No establishment
employees were seen in the area attempting to retrieve the
loose bird, and there was no indication that the
establishment was aware that there was a loose bird in
laage [ ihre) vas notified of
the loose bird in lairage, retrieved the live bird, and placed
it back into the lairage cages. Pianta lettea that the
bird must have jumped out of the cage. [-jmaural_was
notified that a GCP MOI would be issued for the loose bird
inlairage. | met with Thad

(51/6) _Jat approximately 1917 hours on 04/07/20 and
notified 7,3] of the situation. He stated that he would follow

regarding the loose bird in lairage. |
(b)(6)_|that a GCP MO! would be issued.
is in lairage is not consistent with poultry good

commercial practices and results in an increase risk of
birds dying by means other than slaughter. The Poultry
Product Inspection Act and Agency regulations (9 CFR
381.65(b)) require that live poultry be handled in a manner
that is consistent with GCPs. The establishment is
encouraged to maintain the standards of GCP 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 FSIS recommendations concerning the
treatment of live poultry before slaughter.
was notified that this MO! will be forwarded to the Denver
District Office and the District Veterinary Medical
Specialist (DVMS) in case additional follow-up is

recommended. Regards, (hV¥6)

31


Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 8

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda

discussed the appropriate regulation pertaining to good
commercial practices, 9 CFR 381.65(b), as well as the
establishment's animal welfare policy which serves to
ensure the proper care and welfare of the turkeys.
When asked how they intend to properly sort the
carcasses on trailers with a high number of DOA to
preventa recurrence, Jaime will discuss the matter with
the hanging crew and come up with a plan to prevent a
recurrence. This memorandum serves to doct hat
was discussed and also provide [_(hvai_| the{b)(6)
MAL and the Denver district
management team with information concerning the good
commercial practices being employed at this
establishment. A copy of this Memorandum of Interview
was provided to establishment management, and the
signed original will be placed in the USDA files.
eel

M810+P810 | Pilgrim's Pride Corporation HAJ3502041 22APR2020 | 04C05 | PoultryGood | Finalized | On 04/21-22/2020 at 0300 hours [zim

422G Commercial noticed the chickens on kill ine house (1) at the dump

Practices station the chickens are getting double stack. When the
chickens are on the conveyor towards the hanging room.
The chickens are getting hit and rolled over by the
chickens on the shackles going to the kill floor. | notified

(aay ithe issue that is being addressed. In
house (2) kill ine when the birds are exited the house
some of the bigger birds there wings are getting caught on
the fence, And this is making the birds get twisted up and
hitting the birds behind each other.

M810+P810 | Pilgrim's Pride Corporation HAJ4904040 28APR2020 | 04C05 | PoultryGood | Finalized _| While doing Leukosis check on Line 3 and 4 at
228G Commercial approximately 0400 hours on 28 Apr 20 | noticed that there
Practices were 6 birds that appeared to have a dark blue color to the
head and entire body. | also noticed that there were
several cadavers in the green shackle condemn bucket. |
reported my findings to fara and asked her to
continue the investigation because | had to return to my Cl
duties. | also informed that at 0300 hours | did
not observe any of these problems while doing my GCP
cbservations, LESS! investigated further on kill line 2
and found a significant increase in cadavers and several
chickens still had their heads attached. She meet with
Thi) _ Ito let him know of her concerns. At
approximate 0430 hours | (by(6) ]
(i461 _Jreported the following corrective actions. (1)
Kill Line 2's kill blade was readjusted for the larger birds..
(2) He had the head puller in the Picking room unclogged

by[_ ae] 3) He allso had the back up killer on
Kill Line 2 replaced. These actions reduced the problem



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P21234

Perdue Foods LLC

XGI1408063
318G

18JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

(b)(6)

(b)6)

(b)(6)

Perdue Farms P-21234 6/18/2020 Time: 9:14am On
June 18, 2020, at approximately 8:18am, I[_ hai]
while performing a Good Commercial Practices
Verification task in the picking room, observed the
following. While timing and observing the line for 1 minute,
| observed 6 conscious birds moving towards the scalder
on evisceration line 2. The birds were lifting their heads
and flapping their wings. Two of the birds entered the
scalder fully conscious, and the other 4 had their heads
pulled by the puller. | stayed for 1 more minute to be sure
that no other conscious birds were coming. After, |
immediately went to see what the backup neck cutter
ersonnel was doing. The|_/hniva\ __|was standing there.
Rec sal was coming to see what was going on, because
|'m observing live birds going into the scalder. He
mentioned that he had just come to cover the line since the
original person that was there had to go on a break. |
Vaated = ro often are the blades being changed that cut
the bird's necks, because | noticed they were missing
quite a few birds. He said the blades are usually changed
| atbreake soe Ed would be mentioning this issue to
intnance and First Processing Shift Leader Mike Dale.
| informed Mike Dale that | would be documenting my
findings in an MOI, because the establishment is not
preventing conscious birds from entering the scalder, and
this is not consistent with Good Commercial Practices.
This MO! will be forwarded tomy[_____/mwA\_—«d:
the District Office, and the District Veterinary

Medical Specialist in case additional follow-up is

recommended. Respectiully, Nal

22


Table: Noncompliance Reports in Response to FOIA2020-434 11:13 Thursday, July 9, 2020 3

EstNbr EstName NR# Date Task TaskName Regs Description Status
P17766 Southern Hens, | SSN4512 04/28/2020 | 04C05 | Poultry Good 381.65(b) On April 28, 2020 at approximately 0826 hours while CLOSED
Inc 042128N Commercial performing the Good Commercial Practice task, | observed
A Practices the following noncompliance. | observed two birds going

into the scalder. The birds were fully aware of their
surroundings and attempting to actively upright themselves

before going into the scalder. At this time, | informed
(bY/6) for further observation of their
process control. Approximately 0832, 0851, & 0857 |

observed one bird at the respective times going into the
scalder. The live birds were fully aware and actively
positioning themselves into the upright position, The auto
neck cutter and the back-up cutters were not executing
proper technique in preventing the entrance of live birds
into the scalder. This is a noncompliance based on the
observation of multiple live birds entering the scalder while
conscious, with the described loss of process control. At
that time (hv 6)

Thuis) Was notified of the noncompliance,



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

Task
MOINbr Date Code | TaskName Status

MOI Agenda

P6638

Pilgrim's Pride Corporation

UDG0422064 03JUN2020 | 04C05 | Poultry Good Finalized
903G Commercial
Practices

At approximately 1804 hours on Wednesday, June 3, 2020
at Pilgrim’s P-6638 Enterprise, AL, while performing Good
Commercial Practice verification task, the following less
than Good Commercial Practice was observed: in live
hang, both live birds and DOA birds were piled up at the
end of the conveyor belt in the metal bin along with heavy
debris and fecal matter. The pile was filled up to the rim of
the bin with approximately 25+ live and dead birds
‘commingled in the pile. | looked for the lead person or
supervisor, but neither one was near. | told the animal
welfare personnel to call for them, and that | would need
live hang workers to stop hanging. (b\(6)

(hY¥6) ventually arrived and
‘sought to address the problem by joining in with other
workers to remove the birds from the metal bin all while yet
allowing live hangers to hang after been notified that they
needed to stop hanging, | observed ~ 5-10 live birds being
pulled out from the pile. A total of 4 people had to help
empty the bin of both live birds and DOA birds in a timely
manner. The live birds were quickly euthanized by cervical
dislocation. It took ~ 6-7 minutes for them to clear all the
birds from the bin to resume as usual. | informed
about the issuance of this
Memorandum of Information (MO)). Allowing live birds to
be commingled with DOAs can lead to death due to
suffocation. Poultry establishments must take every
available precaution to prevent unnecessary excitement,
discomfort, and accidental injury of birds while on the
official premises. A copy of this Memorandum of
Information (MO) will be forwarded to the Jackson District

Office and the District Veterinary Medical Specialist
(DVMS)._ Respectfully, thay Ce:
[vay

Cf (66) |

P6651

Tyson Foods Inc.

MSO4012040 29APR2020 | 04C05 | Poultry Good Finalized
229G Commercial
Practices

At approximately at 12:06 hours on April 2, 2020 while
performing Good Commercial Practice verification task in
live hang | observed the following. | observed 5 carcasses
on the DOA belt directly under the live hang belt that were
stacked on top of each other. As | moved the carcasses to
verify that there were no live birds undemeath, | uncovered
one that was conscious, moving, and blinking its eyes. A
plant employee immediately hanged the chicken on the line
after seeing what | discovered. During the rest of the GCP
checks | saw no additional issues. | informed|_ (ha)

TAA of the observation at
berm nica 12:15 hours, and of the forthcoming GCP

Mol.

39


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P72

Tyson Foods, Inc

JPJ2603062
712G

12JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 6/12/20 at approximately 0112 hours while performing
my daily GCP task | observed the killing and stunning of
both kill lines. Kill line A failed with 17 birds missed by the
kill machine and kill line B only had 9 birds missed by the
kill machine but failed because 1 bird was hung by only 1
leg. | notified 6) who discussed with
me his opinions on possible Causes and proceeded to talk
to alll of the hangers believing the situation could be
resolved by the hangers making sure the birds were fully
pulled down in the shackles. | performed a retest at
approximately 0130 hours and kill line A failed with 11 birds
missed by the kill machine.|_(j)(a)__ | was present
during this check and notified ofthe findings. He then
adjusted the stunner, contributing the cause to be birds
excessively flapping their wings after stunning and causing
the birds to not feed into the kill machine properly. |
performed a second retest on kill line A at approximately
0152 hours which passed with 9 birds missed by the kill
machine.

P7485+V748
5

Wayne Farms LLC

QBM3721061
TMG

11JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

On Thursday, June 11, 2020, at approximately 2105 hours
at Wayne Farms, LLC Establishment number P7485
located in Jack, AL __(hiia)___Jobserved
two (2) live (conscious) birds, determined to be conscious
by sitting in an upright position with head up, eyes open
and blinking normally, and having conscious respiration,
resting on top of the DOA birds and the pile of litter in the

DOA dumpster. | immediately notified[_jhyal

GAZA the inconsistency with
Good Commercial Practices. Establishment personnel
elected to perform humane euthanasia of bath birds by
rapid cervical dislocation.

40


Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 55

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI! Agenda
P935 Allen Harim Foods, LLC. | YXA5011061 42JUN2020 | 04C05 | PoultryGood | Finalized | Ante-mortem check performed on lot 1 at about 9.10am No
712G Commercial concems. Verified GCP which followed regulations.

Practices Dumper and belts in good condition, Birds were housed
properly, humanely handled; Birds appeared to be in good
health. DOA’s removed and denatured properly, Stunning

and Killing was effective, no loose bird in live hang, live
hi . From: (b)(6).
06/12/2020

: Poultry Good Commercial
Practice/ MOI! Meeting Date. 06/12/2020 Meeting
Time ;12.30pm. Establishment: P 935 — Allen Harim
Foods, LLC +Comments: MOI. (Good Commercial

Practice) To: vad cc: (b)(6)
‘This memorandum of interview serves as
written notification of occurrence of one Cadaver found on

USDA line 3 station 4. At approximately 12.30 hour:
Inspector on line 3 station 4 called me for f
disposition which was hanged by | -}for veterinary

disposition, Observed cadaver carcasses with head
intact and no cut on the neck. The facial area was cherry
OC) red and swollen; skin around the neck was purple in color
while the rest of the body of the carcass was bright red in
color. The { (by6) “}was

notified, lid observe the cadaver carcasses.
assured \will be taking care of the employee (b)(6)
Th) || fesPonsible and make sure to correct and coach to avoid

reoccurrence. The agency regulations do require that
poultry must be slaughtered in accordance to good
commercial practices in manner that will result in thorough
bleeding of carcass and ensure that breathing was stopped
prior to scalding, so that birds do not drown or die other
than slaughter. Itis the agency expectation that all Good
Commercial Practices be correctly and effectively
implemented. The copy of this Memorandum will be
forwarded to DVMS Raleigh district and Front-Line
Supervisor (FLS) in case additional follow up is
recommended. A copy will be placed in the official USDA
file. Please feel free ion or
concern. Sincerely. (6)

ccf (oye) Jec]___ (66)

[Bye] Raleigh.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P46897 IHSAN FARMS, IC SVH4709061 47JUN2020 | 04C05 | PoultryGood | Finalized | A meeting was held between USDAL___ihsi__|
317G Commercial at P-46897) and plant management (Mr. Ted Zadeh,

Practices

Plant Manager at P-46897) in the live hang area of the
establishment. _| informed Mr. Zadeh that while
performing a poultry good commercial practices check in
the live hang and slaughter areas, | observed an employee
of the establishment (tall male) moving two birds from the
live hang conveyor to the slaughter cone line. He had one
bird in each hand, with one of the two birds being carried
by one wing and the other being carried by its legs.
Handling birds by their wing(s) may cause injury and is not
considered good commercial practice. | 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 do not die from causes other than slaughter.

| 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. This MOI is associated with MOI
number SVH4811032304G, written in March 2020.
‘Addendum: At 1326 hours while performing another poultry
good commercial practices check, | observed a short,
male plant employee transferring birds between the live
hang conveyor and the slaughter cone line. | observed
that he was carrying one bird by its wings. | informed Mr.
Zadeh immediately. | attest that this memorandum includes
all of the information discussed duri e Meeting to the
bestofmy knowledge. (BMG) et

P-46897)

28


Table: Noncompliance Reports in Response to FOIA2020-434 11:13 Thursday, July 9, 2020 2

EstNbr EstName NR# Date Task TaskName Regs Description Status
P727+V727 | Simmons VCF4304 05/27/2020 | 04C05 | Poultry Good 381.65(b) At approximately 0330 hours on the morning of May 27, CLOSED
Prepared Foods, | 050527N Commercial 2020, | observed on the head belt leading to the drain 3

Inc. A Practices purple chicken heads, which at that time | decided to

investigate the birds going into the scalders. At
approximately 0333 On Kill line 2 | observed 5 smaller
sized birds going into the scalder in less than a minute
without any cuts on the neck and they did not appear to
have been stunned. The birds were lifting their heads,
blinking their eyes and a couple were chirping. |
immediately notified the nearest plant employee with a
radio and had them send a supervisor to the maintenance
hallway by the scalders. | went back to the scalder on kill
line 2 and | observed 2 more live birds enter into the
scalder. immediately notified! __fmay

stop the kill line on 2. {notified Plant manager
Ryland Haggard of the egregious act of live birds going
into the scalder. At that time, | allowed Mr. Haggard to clear
the scalders but not to hang any more birds until he found
out the cause and how they were going to prevent it. The
establishment is noncompliant with 9CFR 381.65(b). The
establishment failed to ensure poultry are slaughtered in
accordance with good commercial practices in a manner
that will result thorough bleeding, and that breathing has
stopped prior to the scalder. The 7 birds were condemned
at the rehang table.



Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 4

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
M4653A+P46 | Agri Star Meat and Poultry, LLC HRJ2608060 41JUN2020 | 04C05 | PoultryGood | Finalized | At approximately 1520 | observed a live turkey in the sump
53A+V4653A 811G Commercial well at the far end of the transfer room from the kill room.

Practices The bottom of the well is an approximately 7 foot drop. |
pointed out the birdto[ iia) ———d who.
retrieved the bird and returned it to the kill room. | then
looked in the picker room to observe birds entering the
pickers and noted that the consciousness checker,
stationed just before the picker, had several birds on the
ground that he had pulled off the line to allow them to finish
bleeding out before entering the picker. | entered the
picker room and as | watched, the checker was putting a
leg back into a shackle on one bird and did not notice that
another bird that had already passed him was displaying
signs of consciousness (head righted, eyes open and
looking around). As it entered the picker and came in
contact with the picker fingers it displayed further signs of
consciousness by trying to turn its body away and further
lifting its head and neck. As there was no line stop button
in the immediate area | was unable to stop the line, and
due to the noise in the picker area | was unable to alert the
consciousness checker. | then noted that a bird the
consciousness checker had pulled of the line was fully
conscious to where it was standing and able walk away. |
further noted another bird displaying signs of
consciousness was about to enter the picker and had the
consciousness checker remove it from the line. All birds
noted had received the ritual cut. | then went into the kill
room and had the line stopped. | relayed my observations
to who tumed the kill ine
speed down from 74 birds per minute to 65 birds per
minute. This seemed to resolve the issue as further
observations showed no further birds displaying signs of
consciousness prior to entering the picker. When | later
spoke to Plant Superintendent Drew Bernatz he said when
they added in the current line extension it was validated at
70 bpm.



Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda

P912 Wayne Farms, LLC SVF 4820064 19JUN2020 | 04C05 | Poultry Good Finalized Est. P-912, Wayne Farms LLC, June 19, 2020, 2045

019G Commercial hours, in attendance: fhyay

Practices At approximately

jours, while performing Good Commercial Practices
verification (GCP) at the pre-scald check point, | observed
alive bird that was about to enter the scalder. The bird was
lifting its head, eyes were blinking, and had no observed
cuts to the neck nor any observed bleeding. Since the bird
had passed all the establishment's intervention steps, itis
reasonable to conclude that the bird would have entered
the scalder alive. |immediately presented the bird to
(oye Jand

informed[=Jof the incident. Atapproximately 2045 hours

|necre day, | met with (YET inside the
USDA office to address the incident. [~7iaire_Jattributed
the incident to understaffing of the slaughter personnel and
indicated that in order to correct the situation and prevent
reoccurrence of a similar incident, two plant employees
were added to back up the slaughter process. Upon my
additional verifications no further deficiency, as described
in this MOI, was observed for the rest of the shift.
Respectfully [____(i/ai__P-912 Wayne.
Farms LLC [wa ChWAY

(V6)

(b)(6)

P9197 Perdue Foods, LLC. UAB5611044 02APR2020 | 04C05 | PoultryGood | Finalized | On 4/2/20 at approximately 0855 hours the inspector on
202G Commercial line #1 stand #4 presented me a cadaver bird. The bird
Practices had its head and neck attached which was bright red to
purple in color. The neck of the bird had no cut mark on it
and was fully intact, indicating that the bird was not bleed
‘out thoroughly in accordance with 9 CFR 381.65(b). |
informed] TRYAY |and {finan
[ (hVAy [about the bird that had been presented
tome. | showedf mara) Bnd[ hiya) _|the bird. After
informing the plant about the cadaver bird T went to where
the birds are slaughtered on Line #1 and observed the
birds going through the kill machine, past the backup killer,
and just before they entered the scalder. | observed these
areas for approximately 10 minutes total. During that time, |
did not see any birds go past that were not proper!
slaughtered. | also reminded (iy\(4)_} and
that the PPIA and Agency regulations require that live
poultry be handled in a manner that is consistent with good
commercial practices and that they not die from causes
other than slaughter. | referred them to Federal Register
Notice Vol. 70, No. 187, which they have, and |
recommended that they review it for FSIS
recommendations concerning treatment of live poultry
before slaughter. | notified them that this MOI will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P806 Tyson Foods, Inc. 0GC4818064 41JUN2020 | 04C05 | PoultryGood | Finalized
311G Commercial

Practices

Est. P806, Tyson Foods, Inc. June 10,2020 _In
attendance: (66)
{

thWAY | At2050 hours on
June 10, 2020 | met with| ThYV AN ]
WAN to discuss observations that

occurred earlier in the live bird hanging area. At 1755,
hours when | entered the live hang area | observed a
number of dead on arrival (DOA) carcasses at the end of
the DOA belt to the point where DOA’s (approximately 6)
had overflowed from the belt on to the floor. When |
arrived, there was no individual on the floor to address the
DOA birds. Two live birds were observed on the belt along
with the DOA's. After | arrived an employee came off of
the hanging line and picked up the DOA birds from the
floor and tossed them onto the DOA belt on top of the live
birds. | notified the employee of the presence of live birds
on the belt and then subsequently the employee removed
the two live birds and returned them to the hanging belt.
Later when | entered the live bird hanging area at 2038
hours | observed a larger number (approximately 50) of
DOA carcasses, piled up to three layers high, at the end of
the DOA belt. This time there was a greater number of
dead birds that had overflowed on to the floor. Similar to
the previous observation there was no one on the floor in
the hanging area at the time of my arrival. Only
subsequently did an employee come off of the hanging line
to address this large number of DOA birds. | could see two
live birds on the belt mixed in with the DOA carcasses.
Again, the first action taken by the employee was to pick
up the DOA’s from the floor and toss them onto the DOA
belt including on the live birds. Subsequently the employee
started removing the DOA carcasses from the pile and
placing them into the DOA container. During this process
of removing the DOA’s an additional three live birds were
uncovered that had been buried within the pile. With one of
these birds only the head and neck became visible when a
DOA carcass was removed that was on top of this bird.
The employee was then observed to grab the live bird by
the head and pull it free from under the DOA carcasses
and then place it on the live hang belt. Live birds being
covered by DOA carcasses could result in the birds dying
from suffocation. | discussed with|_(b)(6) _|the
requirement that live poultry be handled in a manner that is
consistent with good commercial practices to minimize any
suffering or harm to the birds and ensure that they do not
die from causes other than slaughter. Management can
refer to Federal Register Notice Vol. 70, No. 187 [Docket
No. 04-037N], published September 2005, that presents
FSIS recommendations concerning the treatment of live
poultry before slaughter. A copy of this document can be
provided upon request. The following day | met with Mr.
Reginald Cubbage, Plant Manager, at 1600 hours to review

45


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

15

EstNbr

EstName

Task

MOINbr Date Code | TaskName

Status

MOI Agenda

P1249

George's Chicken, LLC

UVG2109050 26MAY2020 | 04CO5 | Poultry Good
826G Commercial
Practices

Finalized

This Good Commercial Practices (GCP) Memorandum of
Interview (MOl) is to documenta finding during a GCP
Review and Observation task performed at P-1249 on
Tuesday, May 26, 2020 by me, At
0835 hours, | observed a live bird in the blood tunnel
leading from the kill machine and backup cutters under
both slaughter lines, where the tank turns a corner near the
back wall of slaughter and heads towards the secondary
stunner. The bird was completely covered in a layer of
blood, small in size, and had its head, neck, and the top
part of its back out of the blood that had pooled in the
tunnel. As | watched, | saw the bird turn its head. |
immediately went to look for a supervisor and informed
iat there was a live bird in the
(by6)_|safely removed the bird using a
iEto live hang to rehang it on the line. When
l observed the bird close up, it was still alive and moving,

and it had no visible mark of slaughter on its neck.
hung the bird on slaughter line 2, and he

(b)(6)

followed the bird's progress to ensure it was slaughtered.
informed Everton | cne——
(who | encountered as |_cauai land | were following
the bird to the kill station) about the live bird in the blood
tunnel (0840 hours), and she followed us to observe the
bird. | saw the bird was not slaughtered by the kill
machine; but it was slaughtered by the backup cutter. |

spoke on the phone with Plant Manager Sam Groseclose
about the incident at 0921 hours and informed him | would

be issuing a GCP MOI. | told him | would provide a copy of
this MO to my Li eae and to cur
(hV4Ay for review (in accordance with

Directive 6110. /erification of Poultry Good Commercial
Practices). | also informed Mr. Groseclose that this is the
first time | have seen a live bird in the blood tunnel. Mr.
Groseclose told me he was going to discuss the incident



Table: Noncompliance Reports in Response to FOIA2020-434

11:13 Thursday, July 9, 2020

EstNbr

EstName

NR#

Date

Task

TaskName

Regs

Description

Status

P15724

Case Farms of
Ohio, Inc

EVc4005
060324N
a

06/19/2020

04CcOS

Poultry Good
Commercial
Practices

381.65(b)

Atapproximately 1705 on June 19, 2020|_(b)(6)

made the observations described herein. The
éstablishment P15724 had been broken down since
approximately 0940 and had not restarted at the time the
observations were made. Two live haul trailers numbered
38 and 43 were observed to be sitting outside with no fans
or misters on the birds. The birds on the trailers were
observed to be having signs of heat stress as evidenced
by the birds “panting’, sitting with their wings out from the
body, and trying to get to the edges were the wire mesh
was to get air. Upon review of the records it was
determined that trailer 43 arrived on the property at
approximately 1325 hours and trailer 38 arrived at

OPEN

wy)

approximately 1455. Both trailers had approximately|_—1 |
birds on and the birds were packed The live
weight of the birds was approximately 9 ince no

space was available in the cooling sheds the trailers were
placed outside. Upon review of weather records for June
19, 2020 the high temperature was 83 degrees Fahrenheit
with approximately 90% humidity. The same two trailers
were observed to be sitting outside at 0515 hours on June
20, 2020 with no fans and the temperature was 62 degrees
Fahrenheit with 92% humidity. It should be noted that the
trailers in the cooling sheds had both fans and misters on.
This observation represents a failure on the part of
establishment P15724 to take adequate measures to
protect the birds from the heat and handle them in
accordance with good commercial practices and is thus
non-compliant with 9CFR381.65 (b).|__(b\(6)__|was
informed of the observations and advised that a
non-compliance record would be issued.

1


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P1318 Perdue Foods, LLC EHL1818063 04JUN2020 | 04C05 | PoultryGood | Finalized | At approximately 1544 hours while performing Good
704G Commercial Commercial Practice verification | observed 4 heads of

Practices

birds under the entrance to the CO2 tunnel where each
individual cage is separated from the stack of cages.
Upon further investigation | observed that as the individual
cages are removed from the stack of cages, live birds are
able to stick their heads up out of the cage. At the time of
the investigation | observed 1 bird that was pushed out of
the cage to the floor below as the cage entered the CO2

system. This allows the opportunity for live birds to be
deeaplated, [oo TEL
notified of the observation of birds being handled in a wai
that resulted in death other than by slaughter.

investigated the issue and | discussed the issue with
ho stated that this

was an issue early on when the CO2 system was installed.
At that time, investigation revealed that the issue originates
at the farm by the catching crew and last November
modifications were put in place.[_7h\/a\ _Istated that
he will ensure that the catching crew is retrained and there
will also be follow-up after the training is completed. Its
recommended that establishment management review the
Federal Register on "Treatment of Live Poultry before
Slaughter", published September 2005 for FSIS.
recommendations conceming treatment of live poultry prior
to slaughter! (ha) _]was notified that this MOI will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended. Respectfully,

Perdue Foods, LLC P-1318 Milford, DE. 19963

17


Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 3

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
M4653A+P46 | Agri Star Meat and Poultry, LLC HRJ4612050 O8MAY2020 | 04C05 | PoultryGood | Finalized | During turkey kill operations in the morning | observed a
53A+V4653A 308G Commercial turkey kill room employee throw a non-kosher cut,

Practices conscious turkey across the kill belt to the floor on the
opposite side. Shortly thereafter | observed another
employee place a non-kosher cut, conscious bird directly
on the rendering bet. | immediately notified Plant
Superintendent Drew Bernatz, who removed the bird from
the rendering belt and instructed the employees to hand
non-kosher cut birds across the line to be hung in
designated shackles while they exanguinate. At
approximately 12:15, after turkey kill was finished and kill
room employees had left or were washing down at the far
end of the room, | found a live/uncut, conscious turkey on
its back on the rendering belt, wedged against the metal
frame from the stairs over the rendering belt at the far end
of the kill belt, with several turkey carcasses pinning it in
place by the continuous movement of the rendering belt.
No one was nearby so | removed the bird and notified

ie Pf the situation. | then
informed Plant Operations Manager Brent Beebe and Plant
Superintendent Drew Bernatz of the finding, and pointed
out that | had documented in several previous weekly
meetings that | was finding live chickens in the kill room
following end of kill. Mr. Bernatz said that for next week's
turkey kill they would place a barrier to prevent live birds
from being placed on the rendering belt and someone
would be designated to check for live birds at the end of
kill.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020 38

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P5787 Pilgrim's Pride Corporation DEB3505063 41JUN2020 | 04C05 | PoultryGood | Finalized | At 0226 on 11 June 2020, while performing the poultry
611G Commercial good commercial practices PHIS task, | observed two live

Practices

birds in the establishment's sorting bin for dead birds. One
bird was sitting upright on top of dead birds and was
sleeping. The other bird was dorsally recumbent with its
head and the cranial fourth of its thorax beneath two dead

birds, and its thorax was expanding and contracting as it
struggled to breathe. | immediately notified{ (ba)

|that | observed two live

b)(6)

(hV6y
birds in the sorting bin for dead birds.
accompanied me to the sorting bin and | showed 1e
two live birds. moved the dead birds off the live
bird that was struggling to breathe and sorted through all
the other birds to ensure that no other live birds were in the
bin. I said to[_@y/a\_|"“I thought all birds were
supposed to be rapidly decapitated before they were put
on the “dead” belt and got to the sorting bin. |” ()(6)
replied that was not always the case, which iS Why The
plant has the sorting bin in order to look at all the birds to
be certain they are dead before they are put in the DOA

dumpster. (v6) |
then arrived.| (by(@)_ [placed the two live birds on the
cage dump belt



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P40

Pilgrim's Pride Corporation

DAA3814044
409G

O9APR2020

04C05

Poultry Good
Commercial
Practices

Finalized

April 9th, 2020 To: Jake Ponder, Plant Manager From:
Subject: Poultry
Misteatment On Thursday, April 9th, 2020 at
approximately 0630 hours, while performing the Good

Commercial Practices task and observing the live birds

being hung in the hanging pen on “B” side, |, (bire)_]

Taal
TERNZAN ‘Observed the following. Thé Second

establishment employee hanging birds on the line,
forcefully threw a small ive bird into the barrier behind him
causing the barrier to vibrate and a “thud” was heard when
the bird contacted the barrier. The bird fell to the grate
below the barrier, flapped its wings several times, and
began to gasp for air eventually dying. | immediately went
to the office of the Supervisor of the live department

(5)(6) __|and informed Beep tay observations and
that this was unacceptable per Agency regulation;-whi

26

expects poultry to be handled in a manner consistent with
Good Commercial Practices and that they not die from

(oN6) |

causes other than slaughter. Furthermore, in many weekly
meetings with establishment management, | have
discussed the issue of live hang employees forcefully
throwing possible DOA birds. Ifthe bird is not a true DOA
and is just lethargic then there is the potential for
unnecessary injury and/or death by means other than
slaughter. A copy of this memorandum of interview will be

forwarded to the District Veterinary Medical Specialist in
the District Office. Sincerely, (b)(6)
TAY
(bW6)

P40345

Misty Lea Farm

BFY4607062
512G

12JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

(b)(4)

On June 11th, 2020 the establishment held over
approximately 170 chickens in crates to be slaughtered on
June 12th, 2020. These chickens were confined to the
crates and were not provided access to water or food for
19+ hours before slaughter. While this is not a
noncompliance, the failure to provide water and food can
lead to issues found on antemortem and postmortem
inspection including, but not limited to: increased
bruising, DOAs, leg and wing fractures, and increased
IP, etc. Also, dehydration can result in lower yields and
overall quality issues. FSIS strongly urges all
establishments to provide water and food to animals held
‘overnight and to provide adequate space for them to have
some level of comfort. The establishment held over

e)) |

approximately{—Ehickens on June Sth to be slaughtered
on June 10th and there were several broken wings and
legs. On June 10th the establishment held over
|_approximatelyi—__Jurkey to be slaughtered on June 11th.
Although they were held in a aaa ith water,

the ability to move and access the water was limited.



Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 2

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
M20322+P20 | Equity Group Eufaula Div LLC ATF3007062 05JUN2020 | 04C05 | PoultryGood | Finalized | On 06/05/2020, at approximately 0641 while performing my
322 305G Commercial Good Commercial Practices at the entrance of the scalder

Practices on the single kill line for Lines 1 & 2.1
observed four uncut, live birds pass by at approximately
0642 (2 birds approximately 15 birds apart) and 0643 (2
birds approximately 10 birds apart). | noted that the
birds were breathing and alert to their surroundings. At the
point of observation, the establishment has
no further humane measures in place to ensure that all
breathing has stopped prior to entering the scalder. |
Visually followed the birds as they entered and exited the
head puller (prior to the entrance of the scalder) and into
the scalder where all four birds entered stil breathing. |
immediately notfied 1st[_--fhYe\ and
of my observations.
stated the experienced backup killer
had gone on break and a less experienced backup killer
had taken their spot. He stated in the future, when the less
experienced employees are filing that position, they will
move a third person on the line to ensure that all birds are
appropriately cut. In addition, he stated that retraining
would be conducted with that particular employee. At
approximately 0714, once corrective actions were in place,
| performed an additional, extended GCP check to ensure
that corrective actions were effective. No further
deficiencies were observed. Equipment effectiveness was
also evaluated, and no obvious issues were noted (large
variation in bird size observed). No other vulnerabilities
were noted during today's production.



Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29, 2020
Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P9197 Perdue Foods, LLC. UAB2812053 18MAY2020 | 04C05 | PoultryGood | Finalized | On 5/15/20 at approximately 0800 hours the inspector on
2186 Commercial line #2 stand #3 presented me a cadaver bird. The bird

Practices

had its head and neck attached which was bright red to
purple in color. The neck of the bird had no cut mark on it
and was fully intact, indicating that the bird was not bleed
out thoroughly in accordance with 9 CFR 381.65(b). |
informed| (by(6) Jand| (oyr6y]
[___ (bye) labout the bird that had been presented
tome. | showed |_(h/a)_Jand|_(j))/s) | the bird. After
informing the plant about the cadaver bird | went to where
the birds are slaughtered on Line #2 and observed the
birds going through the kill machine, past the backup killer,
and just before they entered the scalder. | observed these
areas for approximately 5 minutes total. During that time, |
did not see any birds go past that were not proper!
lauphtered, | slso reminded aaa and GEE
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. | referred them to Federal Register
Notice Vol. 70, No. 187, which they have, and |
recommended that they review it for FSIS
recommendations conceming treatment of live poultry
before slaughter. | notified them that this MOI will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended.

50


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P48304 Lincoln Premium Poultry YOT0108045 21APR2020 | 04C05 | PoultryGood | Finalized | On Monday April 20, 2020, at approximately 1310 hours, |
821G Commercial observed an incident of poultry mistreatment while

Practices

performing a poultry Good Commercial Practices Task in
the live-hang area of Lincoln Premium Poultry, Est.
48304. On the north side of the Line 3 live hang station,
there was a red condemn tote containing two deceased
chickens and one live chicken. The live chicken was alert,
sittin itand lif 's head. | notified live hang
the good commercial practices
concern. He immediately and humanely retrieved the live
chicken and placed it back in a tray prior to controlled
atmospheric stunning. Itis not consistent with Poultry Good
Commercial Practices for live birds to be placed in
condemn barrels. Following this incident, | notified Renju
Simon, Director of Food Safety and Quality Assurance, of
the poultry Good Commercial Practices concem. 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 of GCP 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 treatment of live
poultry before slaughter. This MOI will be forwarded to the
District Office and the District Veterinary Medical

Specialist (DVMS) in case
(b)(6)

recommended. Sincerel

34


Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29, 2020
Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P764 Perdue Foods, LLC CUA3409062 22JUN2020 | 04C05 | Poultry Good Finalized A meeting was held ina) _loffice at P-764
322G Commercial

Practices

Perdue Foods, LLC in Salisbury, MD. (pX6) is the first

processi unit leader at P-764. Tidentified
myself to as (6) ___ Supervisory
Public Heal inarian and Inspector In Charge at

P-764. The meeting was held to discuss a poultry good
commercial practices (GCP) concern that | observed this
morning while performing my daily GCP check. At 0748
hours | observed a bird on kill ine 1 before it reached the
stunning or the killing/slaughter step in the process. This
bird had been hung on the line already and had no head:
its neck was missing some skin also and it was actively
bleeding (| had initially been drawn to look at birds on the
line when | saw blood drops beneath the line at the
pre-stun ar bird had died by means other than by
slaughter. jad been informed and had
investigate id he checked the entire line between
the live hang area and the stunner. He didn't find anything
that would cause decapitation or injury, however there was
something just after the last live hang person that could
potentially cause a problem and so he had this structure
raised. No other birds were seen without heads. Other
potential causes would be when birds were loaded onto
cages, they could get their heads stuck as the cage
drawer closed or something of that nature. He said they
have instructed the live hang crew to immediately notify the
if they find a bird without a head. | reminded

iat 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. |
notified that this MOI would be forwarded to the
District Veterinary Medical Specialist (DVMS) in case
additional follow-up is recommended. | attest that this
memorandum includes all the information discussed during

the meeting to the best of my knowledge.
(b\(6) ptP-764)

43


Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29,2020 29

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda

P476 Pilgrim's Pride Corporation ODA4619041 06APR2020 | 04C05 | PoultryGood | Finalized | Daniel Shaw, Plant Manager Pilgrim's Pride Corporation
106G Commercial P-00476 616 Kingsbridge Rd. Carrollton, GA 30117 On
Practices Sunday, April 5, 2020 at approximately 2321 hours while
performing a Good Commercial Practices Task at P-00467
VERTEX Jobserved an issue with the
implementation of Good Commercial Practices in the
pre-evisceration area. | observed one live bird enter the
scald vat on line number one alive. The bird was observed
alive and blinking its eyes prior to entry into the scald vat. |
immediately notified ey
Taz) [of this incident. nA)
thy) jand[ TAVAN ]
were notified shortly thereafter. [_/j,\/4\_} and | observed
the cadaver upon exit from scald vat number one and
again directly after picker number two[_aam=x |
removed the bird at this point. The cadaver was observed
with an engorged head intact with the neck to which there
was no cut visible. The body of the bird was also visibly
dark red. No other live birds were observed entering the
scald vat alive. This topic will also be discussed again at
the next UDSA weekly meeting on April 6, 2020 at
approximately 2330 hours and the minutes will be
documented in the corresponding MOI. Respectfully,

476 Pilgrim's Pride Corporation DA2422045 16APR2020 | 04C05 | PoultryGood | Finalized | Daniel Shaw, Plant Manager Pilgrim's Pride Corporation
816G Commercial P-00476 616 Kingsbridge Rd. Carrollton, GA 30117 On
Practices Thursday, April 16, 2020 at approximately 0240 hours
while performing a Good Commercial Practices Task at
P-00467 jm 577- observed an issue with
the implementation of Good Commercial Practices in the
pre-evisceration area. | observed one live bird enter the
scald vat on line number two alive. The bird was observed
alive and blinking its eyes prior to entyy into the scald vat.
There was no cut observed to the neck. | immediately
notified| ThVAY of this
incident. (bV6)

and Shift Manager, Jonathan Hulsey were notified shortly
thereafter. There were no immediate corrective measures
or preventatives taken by the establishment at this time.
This topic will also be discussed at the next UDSA weekly
meeting on April 20, 2020 and the minutes will be
documented in the corresponding MOI. Respectfully,

(b)(6)



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P1249 George's Chicken, LLC UVG1112051 11MAY2020 | 04C05 | PoultryGood | Finalized | The following Good Commercial Practices (GCP)
511G Commercial Memorandum of Interview (MO!) summarizes the events
Practices witnessed by me, and

on Thursday May 7, 2020 during Good
Commercial Practices at P-1249. At approximately 0545
hours, | was informed by who was in the
process of performing a GCP task that there were a lot of
dead birds coming into live hang. | told to make
sure establishment employees were not piling DOAs and
that the process was in control, according to the
establishment's plan. | told | would go to
dumping. | arrived at dumping at approximately 0550
hours. | observed the birds going into live hang on the
conveyor belt leading from dumper #2. At the time, Trailer
#569 was being dumped; this was the first trailer on Lot #2,
had arrived at the establishment yesterday (May 6), and
had been on the establishment premises overnight. There
were DOAs scattered among the birds | saw on the belt.
When establishment dumped the third tier, there were
mostly dead birds in this tier. Therefore, there seemed to
be a pattern in which some tiers had fewer DOAs and
others had many DOAs. Establishment personnel in the
area and) V6)
also noticed a pattern to the tiers containing mostly live
birds and those containing mostly dead birds. When |
looked at the birds being sorted as DOAs in live hang and
at the DOA tables in live hang and slaughter, | observed
hundreds of dead birds. They appeared to be overall
well-fleshed birds with no overt signs of pathology. Overall,
they appeared darker in skin color, looking dark red to
purplish in hue. Overall, there were no obvious signs of
fatal injury. The DOAs | touched were cool or cold.
Establishment personnel and management were ensuring
the DOAs were spread out in a single layer, checked, and
removed and disposed as expeditiously as possible. To
provide more background on the affected trailers: There
were three trailers total that had stayed overnight at the
establishment — Trailer #770, which was a carryover from
Lot #8 from yesterday and now designated as Lot #1,
Trailer #569 (first trailer on Lot #2), and Trailer #526 (first
trailer on Lot #3). Trailer #569 (Lot #2), like Trailer #526
(Lot #3) had been housed in the new receiving shed,
whereas Trailer #770 (Lot #1) was housed in the old shed.
| also discovered all three trailers housed overnight were
from the same farm. | had watched the first trailer (#770,
Lot #1) being dumped at around 0518 hours. It had
noticeable DOAs on the conveyor belt, but there were not
excessive numbers of DOAs. According to the Poultry Lot
Information for Trailer #770, there were 175 DOAs out of
7376 birds. Lot #8 from May 6 (trailers from the same lot
run on the previous day) had a total recorded DOA count
of 10 heads. | observed the third trailer (#526, Lot #3),

13


Table: MOls in Response to FOIA2020-434 13:05 Monday, June 29, 2020
Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P9197 Perdue Foods, LLC. UAB3312055 18MAY2020 | 04C05 | PoultryGood | Finalized | On 5/18/20 at approximately 0805 hours, while giving
918G Commercial breaks on Line #2 Stand #1, | discovered a cadaver bird at
Practices my inspection stand. The bird had its head and neck

attached which was bright red to purple in color. The neck
of the bird had no cut mark on it and was fully intact,

indicating that the bird was not bleed out thoroughly in
accordance with 9 CFR 381.65(b). | informed =ZSZ2T
(ba) ]

(hv land | (by6) labout

the bird that had been presented to me. I showed|(b)(6)]

(ie Leves_| Litbire)_} and{cay67 fhe bird.
After informing the plant about the cadaver bird | went to
where the birds are slaughtered on Line #2 and observed
the birds going through the kill machine, past the backup
killer, and just before they entered the scalder. | observed
these areas for approximately 10 minutes total. During that
time, | did not see any birds go past that were not properly
slaughtered. | also reminded EME] and
that the PPIA and Agency regulations require that live
poultry be handled in a manner that is consistent with good
commercial practices and that they not die from causes
other than slaughter. | referred them to Federal Register
Notice Vol. 70, No. 187, which they have, and |
recommended that they review it for FSIS
recommendations conceming treatment of live poultry
before slaughter. | notified them that this MOI will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended.

51


Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29,2020 53

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P9197

Perdue Foods, LLC.

UAB1712064
812G

12JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 6/11/20 at approximately 0830 hours, the inspector on
Line #1 Stand #1, presented me with a cadaver bird. The
bird had its head and neck attached which was bright red
to purple in color. The neck of the bird had no cut mark on
it and was fully intact, indicating that the bird was not bleed
out thoroughly in accordance with 9 CFR. 65(b
[var Sco

labout the bird that had been presented to me.

d 6), |the bird. | was not able

to view the birds in the live hang area because the plant
had stopped production on line #1 for the Junch break. |
also reminded {_(b\(6)_|and that the PPIA
and Agency regulations require that live poultry be handled
in a manner that is consistent with good commercial
practices and that they not die from causes other than
slaughter. | referred them to Federal Register Notice Vol.
70, No. 187, which they have, and | recommended that
they review it for FSIS recommendations concerning
treatment of live poultry before slaughter. | notified them
that this MOI will be forwarded to the District Office and the
District Veterinary Medical Specialist (DVMS) in case
additional follow-up is recommended.

P935

Allen Harim Foods, LLC.

YXA0322065
908G

08JUN2020

04C05

Poultry Good
Commercial
Practices

Finalized

(b)(6)

At approximately 2004 hours while performing Good
Commercial Practice | observed the following: The medium
bird dumper operator moved a cage back from the

dumping position. The bottom door of the cage had not
‘opened during the dumping leaving live birds inside. The

i) |

dumper operator opened the door to the cage, took a live
[bain pods and threw the bird behind
‘conveyor belt that transports live birds into the hanging

pen. | observed the live bird hit the metal portion of the
dumper. | _-ibye)_—_ as notified

of the observation of birds being handled in a way that
could result in discomfort, injury or death while being
handled in connection with slaughter. The employee was
removed from the dumping station and (oy) ted that
the employee would receive disciplinary action. Itis
recommended that establishment management review the
Federal Register on “Treatment of Live Poultry before
Slaughter’, published September 2005 for FSIS
recommendations concerning treatment of live poultry prior
to slaughter.[jyyya)_ Was notified that this MOI will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
ended. Respect,

Allen Harim Foods, LLC. P935 Harbeson, DE.



Table: MOls in Response to FOIA2020-434

13:05 Monday, June 29, 2020

EstNbr

EstName

Task
MOINbr Date Code | TaskName

MOI Agenda

P1284

Pilgrim's Pride Corporation

GDA4701043
817G Commercial
Practices

17APR2020 | 04C05 | Poultry Good Finalized

Est. P1284, Pilgrim's, April 17, 2020, 0030 hours. In
attendance: TRWAY ]
(AWAY On 4/16/20, at
approximately 2225 hours, while performing Good
Commercial Practices verification in the live room, |
observed a live chicken in a condemn barrel that was
about half full of dead-on-arrival chickens (DOA). The live
chicken was on top of the DOAs and appeared healthy,
bright, and alert. | notified an employee in the area and the
lead employee and came to the live floor
and | notified them of my findings. The live chicken was
removed from the condemn barrel and the remaining

DOAs were checked for any other live chickens and none
were found. stated he believed the
chicken had jumped into the condemn barrel. | reminded
merce 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. | recommended

that! (h\(6) __ | review Federal Register Notice Vol.
70, No. 187, published September 2005 {Docket No.

16

((b)(6) |

04-037N} for FSIS recommendations conceming treat

of live poultry before slaughter and provided|_—E copy of
this document. | notified that this MOI will
be forwarded to the District Office and the District
Veterinary Medical Specialist (DVMS) in case additional

ip is recommended. Respectfully! ()\(4)

1284 Pilgrim's.

P1317+V131
7

Wayne Farms LLC

QUI5817060
402G Commercial
Practices

02JUN2020 | 04C05 | Poultry Good Finalized

Dear [Zhe | At approximately 17:20 hours, on June
02, 2020, while performing the Review and Observation
component of the PHIS task, “Poultry Good Commercial
Practices,” |, observed one live bird
covered by and comingled with dead birds in a pile on the

sliding chute at the end of the live bird belt. During a
meeting, with the
held in USDAVFSIS office at approximately 1 jours |
infor at a GCP MO! documentation of our
meeting and discussion of the observed deficiency would
be forthcoming. Cc: Dr. Kermit Harvey, DDM.

{ 6) ] L we) |

(oy(6)