Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1249 George's Chicken, LLC UVG1710085 26AUG2020 | 04C05 | PoultryGood | Finalized |The following Good Commercial Practices (GCP)
626G Commercial Memorandum of Interview (MOI) summarizes the events
Practices witnessed by me, favay________pn Tuesday,

August 25, 2020 while performing antemortem inspection
at P-1249. While performing antemortem checks of Lot
#9 at 1232 hours, | found a dead chicken on the ground in
the new receiving shed at P-1249, The bird was in the 2nd
trailer space from the left, about 8 feet from the front of the
shed. This trailer space was occupied by trailer #570 from
Lot #9, The bird's head was tilted to the side with visible
head and neck feathers appearing clean and white with
ingesta coming out of the mouth and along the side of the
head that was facing down. The bird was small, appeared
to have been healthy with no obvious signs of pathology in
observed viscera and body, did not appear to be
deteriorated (liver, spleen, gizzard, and intact

intestine were firm to the touch), and was cool to the touch.
Below the neck, the bird was badly crushed and tom open,
exposing meat and abdominal contents. | observed blood
on the floor under the bird, | observed tire tread marks on
the bird and surrounding contents near the bird, The bird
was lying directly in the path of the inner left tire of trailer
#570. When | checked the tires, | observed meat and
viscera pieces on the tread of the inner front left tire of

trailer #570. | informed both oye)

eye)

[b6) pf my findings and showed them the bird (1238

hours). Nahas 04 | checked trailer #570 and the
trailer to the left of trailer #570; neither of us observed an

open cage door or any other loose birds. | told
that | would contact [ib] for guidance and
would likely be issuing a GCP MOI.
the bird and cleaned the tires and ground.
informed me that trailer #570 had arrived at the
establishment at 1210 hours. | informed Plant Manager
‘Sam Groseclose about the incident at 1319 hours by
telephone. | told him that this finding was unacceptable, in
accordance with expectations of Good Commercial
Practices (9CFR 381.65(b)), it warranted a formal

interview and Memorandum of Interview, and that | would
need to provide a copy of this MOI to my
[nd to our eyey____rreview (in
accordance with Directive 6110.1: Verification of Poultry
Good Commercial Practices). | told Mr. Groseclose that
there was one previous incident of a bird run over by a
truck in receiving, documented in MO! #UVG3206035816G
on 3/16/2020. Mr. Groseclose told me he would get in
contact with me regarding any updates and findings.

20


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P39 Pine Manor Inc. ULLO821080 24AUG2020 | 04C05 | PoultryGood | Finalized | On Friday, August 21, 2020 at approximately 21:45 | [BY]
2246 Commercial Goering 2nd shift SPHV P00039) while performing a Good
Practices Commercial Practices (GCP) task observed the following

events: At the end of the slaughter kill there were three
chickens on either side of the hanging platform that had
regained consciousness after going through the CO2
stunning chambers, The chicken on the westside platform
was picked up and hung on the shackle line by a hanger
(plant employee who places the chickens on the shackle
line) at the hanging area {(6)(6)

eve) fn turned on the electrical

stunners, while two hangers picked up and carried the two
chickens from the eastside platform to an area near the
electrical stunners. The first hanger attempted to place the
first chicken on the shackle line but was unsuccessful, The
second hanger did successfully place the second chicken
‘on the shackle line in very close proximity to the quides
that direct the shackle line through the electrical stunners.
The chicken then suddenly began to move causing the
shackle to swing to the side causing the shackle and the
chicken to be pulled outside of the guide and become
entangled with the trailing shackle. The continued dragaing
of the chicken in the entangled shackles resulted in
fractures to its legs and the peeling of its skin from its

feet toward its body. Supervisor Baumgartner immediately
stopped the shackle line and the shackles were untangled
and the chicken removed from the line. The chicken did
not make a sound and quickly expired. The plant

then condemned and discarded the carcass. While these
unfortunate circumstances and events caused the painful
death of this chicken, | must remind the plant that the
Poultry Products Inspection Act (PPIA) and USDA/FSIS
regulations do 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 slaughter. |
advise that the plant review Federal Register Notice Vol.
70, No 187 published September 2005 [Docket No.
04-037N] for an outline of USDA/FSIS guidelines
conceming treatment of live poultry before slaughter.
USDA/FSIS recommends that Pine Manor implement
procedures that will prevent similar future

occurrences. Mr. Roger Stearns (Plant Manager) will
receive a copy of this Memorandum of Interview (MO!) and
will also be notified that this MO! will be forwarded to the
District Office and the District Veterinary Medical
‘Specialist (VMS) for review and any follow-up.

41


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P33900+V33 | Foster Farms NHH5104082 19AUG2020 | 04C05 | PoultryGood | Finalized | Est. P-33900, Foster Farms at Farmerville, LA in August
900 019G Commercial 19, 2020 at 0500 hours. in attendance: [da] (6)(6)
Practices (ey) nd [(6)(6)

= —— r Jat
approximately 0334-hours, 19th of August 2020, |, ava.
[EX6)__Jobserved the following while performing poultry
GCP verification task at the live hang room: | saw one
alive, breathing, young chicken in the condemned

jondola together with other dead young chicken. | notified
bye) accordingly.
v6) ‘saw for himself the live young chicken,
with its abdomen rhythmically moving as in breathing.
picked up the young chicken mistaken

to be dead and it righted itself by erecting its neck.
pv) [oYGH hang the young chicken in the shackle.

observed on the floor of live hang room, alive young
chicken, briefly paddled its feet but rhythmically moving its
abdomen on a pile of 10 dead young chicken. The live
young chicken is thrown in the gondola half full of dead
young chicken. | notified (aa)
[16Y accordingly. {wey Fea] saw for himself the
paddling feet and rhythmic abdominal movement of the live
young chicken mistaken to be dead. He picked it up and it
opened its eyes. favaY —]M5Y1E1] exsanguinated the
moribund young chicken. | reminded frye; ]
be J
[ex6)__Jhat 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. | also him that an MO! will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended. Hopefilly, this MOI serves to bring to the
establishment's attention that live poultry must be treated
in a manner consistent with good commercial practices.
Respectfully, [a] USDA Relief SPHV at

P-33900: Foster Farms at Farmerville, Louisiana.

Two days ago, August 17, 2020, |, foX(6)

37


Table: Noncompliance Reports in Response to FOIA2021-108 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
M1015+P101 | Poultry Holdings, | {12D49201-7A2D | ARES703 08/18/2020 | 04C05 | Poultry Good 381.65(b) On August 18, 2020, at approximately 1130 hours, while OPEN
5 LLC -4D4C-A270-CA1 | 085119N Commercial performing a Good Commercial Practice task in the
127E82701} A Practices chicken Live Room, | observed a significant number of

chickens smothered to death due to the excessive amount
of the birds being dumped onto the belt. Two of the three
slaughter lines were not running at the time and the Rabbi's
and plant employees were not able to kill and clear the belt
fast enough before more birds were dumped onto the belt.
Atone section of the belt, the chickens were piled on top of
each other at least two to three feet deep. A large majority
of the birds in that section of the belt had to be placed on
the DOA belt. | counted at least 100 birds in the space of
ten minutes being placed onto the DOA belt which all
appeared to have been smothered to death. There were
many more chickens that | did not individually count but
observed as employees cleared the belt. Consequently,
the DOA chute and bin were also completely clogged up
with birds as employees worked to get the excessive
amount of dead birds into barrels and then into the DOA
dumpster. | Immediately informed the live room supervisor
that no more birds were to be dumped onto the belt until the
belt was cleared. This incidents in violation of 9 CFR
381.65(b)The PPIA and Agency regulations require that
live poultry be handled in a manner that is consistent with
good commercial practices. We recommend that plant
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. This incident has been forwarded
to the District office and the District Veterinarian Medical
Specialist (DVMS) in case additional follow-up is
recommended.

6


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P445 Wayne Farms, LLC FKA4311072 47JUL2020:| 04C05 | PoultryGood | Finalized | Mr. Leia) [(6)(6)
117G Commercial Establishment P445_ Wayne Farms, LLC. Dobson, NC
Practices 27017 [eN6Y 7/17/2020, at approximately 1042

hours, while performing a Good Commercial Practices task
in the Kill Room, | noted a bird pass by the back-up killer
uncut and was heading towards the scalders. Atthe time
of my observations, the bird had normal rhythmic
breathing, eyes open and blinking with the head elevated.
No team member in the area had noticed that this bird
passed uncut and had | not intervened the bird would have
entered the scalder while stil alive. | saw
oye) and
alerted himto remove the bird from the line. 1confirmed
that there was no evidence of a cut on the neck to allow it
to bleed out completely before entering the scalder. The
bird was placed back on the line to go through the proper
slaughter process. | discussed my concems with Mr.
and informed him that had USDA not intervened, this
bird would have died by means other than slaughter. Mr.
informed me that as part of preventive measures, the
team member would be retrained. Following this
conversation, | repeated my Good Commercial Practices
task and verified that the number of stunned birds and
manually killed birds was appropriate, At approximately
1130 hours, | performed a follow-up GCP check to verify
the establishment's corrective actions and found no
additional nonconformances. 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.
Itis the establishment's responsibilty to ensure that birds
are slaughtered in accordance with 9 CFR 381.65(b). A
previous memorandum was written on 6/15/2020 for similar
findings. In that memorandum, see MOM
FKA3812060515G, three birds were observed entering the
scalder alive and breathing. In response to this MOI,
preventive measures cited included installation of an E-stop
prior (0 entrance to the scalder and retraining of the
responsible team members on proper welfare practices
and procedures. Previous preventative measures do not
appear to have been effective in ensuring that birds
entering the establishment do not die from causes other
than slaughter. If you have any questions or concerns

ct myself or
es) Respectfully,
ee ISsPHV-Case Farms of NC, Inc.,

Morganton

46


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M737+P737 | House of Raeford - [nial _] Div DHA0413085 49AUG2020 | 04C05 | Poultry Good | Finalized | P737 House of (BG I Division, August 19, 2020
119G Commercial at 12:35pm. In attendance: (BY) y
Practices and{\(6) ‘At 12:25 pm

exe Vand informed him what

While performing a Good Commercial Practices task, Iwas
attended by a plant appointed employee to observe
chickens as they came out from the bleed tank on line 1,
go up and over a drip pan protected walkway, then almost
immediately descend into the first scalder. As the birds
approach the scalder, there is very litle line space or time
for which the bird can be safely removed without stopping
the line. Over the space of about two minutes, two
chickens which were smaller than average, were bright,
alert, looking around and had no apparent cut on the neck
emerged from the bleed tank. For the first bird, the plant
employee stopped the line and was able to successfully
remove it from the line. The plant employee then started
the line again. About a minute later, the second live bird
came into view; the live bird was identified both myself and
the plant employee just as it emerged from the bleed tank.
The plant employee had adequate time to decide what to
do and chose to try to remove the bird without stopping the
line. He was able to remove one leg from a shackle but not
the other leg, The bird descended into the scalder. There
is no way to ‘reverse’ the line nor was there a way for the
plant employee to safely remove the bird once it was in the
scalder. This bird died by means other than slaughter. |
immediately notified the appointed plant employee that this
event would result in a MOI. | then went and found Live

happened and that an MO! would be written for this event,
as itis the establishment's responsibility to ensure that
birds are slaughtered in accordance with 9 CFR:
381.65(b). This MO! will be forwarded to the District
Office and the District Veterinary Medicine Specialist
(DVMS) in case additional follow up is recommended. If
you have any questions or concerms regarding this MOI,

lease feel free to contact me, or [(Bye)
NG) Respect

DVM _ P737 1st shift SPHY, IIC

4


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P7264+V726 | Sanderson Farms, Ine. VLB0715090 08SEP2020 | 04C05 | PoultryGood | Finalized | On September 4, 2020 at approximately 7:38 PM, | was
4 008G Commercial performing a Good Commercial Practices check. |
Practices observed a live bird in the dead on arrival (DOA) barrel in

the live hang area. The bird had been thrown into the
barrel as | stood right in front of it, There were several
DOAs present in the barrel. The bird had been thrown into
the barrel head down between 2 DOA birds. | noticed that
its leg was contracting and suspected it was still alive. |
summoned [b)(6) Jto
show bim the bird. He immediately removed the bird from
the barrel and saw that it was still alive. When the bird was
picked up out of the barrel, it held its head up and was
clearly alive. USDA expects that no live birds are to be
presentin barrels meant for DOA birds since they are in
danger of being smothered (dying by means other than
slaughter). tis expected that birds are screened
adequately to ensure live birds are not placed in a barrel
with DOAs. Itis highly likely that this bird would have
smothered since its head was down between DOASs in the

barrel.  [BI[BYGy

74


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P510 House Of Raeford Farms RHB3701085 03AUG2020 | 04C05 | PoultryGood | Finalized | Ms. Nicole Reynolds, Plant Manager, P-510 House of
303G Commercial Raeford Rose Hill, NC 28458  Ms.Reynolds At
Practices approximately 2225 while performing the Good Commercial

Practices Verification task, | observed a live bird about ta
enter the scalder. The bird at the time of my observation

had normal rhythmic breathing, eyes open and blinking
with the head elevated. |(b)(6)

ho was present GUTTg Thy SBSEWaOT
immediately removed the bird from the line before it could
enter the scalder. After the bird was removed from the
line, it was observed that there was no cut on the neck
which would not have allowed the bird to bleed out
Property. Gases the bird back to live hang to

show it to the backup cutter. placed the bird
back onto the kill line to allow it to go back through the

stunner and the kill blade to allow proper bleeding. Mr.
Wilson instructed the backup cutter to pay more attention

to all birds, large and small, going through. _{ discussed
my finding with FO)

[G1] notifying him of the pending MOT and the
establishment's failure to comply with 9 CFR 381.65 (b)
which states: Poultry must be slaughtered in accordance
with good commercial practices in a manner that will result
in thorough bleeding of the carcasses and ensure that
breathing has stopped prior to scalding. Mr. Hand stated
that he would also have maintenance check the kill blade
and to make any adjustment needed. [{(b)(6)

was also notified my findings. — Ms. Reynolds this MOT
will be forwarded to the District Veterinary Medical
‘Specialist (DVMS) in case additional follow-up is
recommended. —_ If you have any questions or concems:
regarding the above, please contact! 6)

or [O)(6), I
Respectiully, ~~ [0)(6) ]

56


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P476

Pilgrim's Pride Corporation

QDA1620091
608G

08SEP2020

04C05

Poultry Good
Commercial
Practices

Finalized

Daniel Shaw, Plant Manager Pilgrim's Pride Corporation
P-00476 616 Kingsbridge Rd. Carrollton, GA 30117 On
Friday, September 4, 2020 at approximately 0345 hours
while performing a Good Commercial Practices Task at
P-00467 |, a] aver 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 one alive. The bird was observed
alive, vocalizing, and blinking its eyes prior to entry into the
scald vat. There was no cut observed to the neck. Upon
exit from the scald vats, the floor attendant removed the
cadaver carcass from the line. | immediately notified Live
[(oy(6)
fave of this incident. They were also shown
the carcass that was pulled from the line. There were no
immediate corrective measures or preventatives taken by
the establishment at this time. Prior to this observation,
approximately five cadaver bird carcasses were found in
the Evisceration department. None of the birds found had
any visible cuts to the neck. Both the heads and necks of
the birds were intact and engorged and the bodies of the
carcasses appeared a dark red color. First Processing
was Immediately natied and
observed these findings. This observation prompted further
investigation into the pre-evisceration area where the live
bird entering the scald vat was observed. This matter is

of very seriaus_concern and a response is requested.
Respectfully, [E6)

P4gt

Tyson Foods, Inc.

VHF3209082
413G

13AUG2020

Finalized

At approximately 0720 hours, [a]EWaT and | were
performing antemortem at the live hang area of the
establishment. While observing birds coming in from the
dumping area, we observed a bird caught between the
motor drive shaft and the framework for the dumping
feeding belt. The bird was dead and appeared to be
mutilated by the shaft as it was turning. | asked a
production ee eet eee
this location (016)

arrived at this location and was notified of the issue. As we
were discussing and observing the issue, a live bird got
caught between the motor drive shaft and the framework
for the dumping feeding belt. Mutilation was observed on
the bird as it tumbled between the shaft and the framework.
At approximately 0740 hours, [a]fo)() find | met with
Donnie Warren, Production Manager, in the USDA office
to discuss the issue and notified him of the forthcoming
Good Commercial Practice MOI.

54


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P533 FreeBird Chicken AKB3207070 46JUL2020 | 04C05 | Poultry Good Finalized On July 16, 2020 at approximately 0645 hours |, (o)(6)
616G Commercial was performing a Poultry Good Commercial
Practices Practices task in the New York Room. As | was walking

through the New York room | observed two bright red
chicken carcasses laying on the floor behind the re
hangers. As | continued in the New York room | observed
another bright red chicken carcass going down the line
towards the rehang table and pointed it out to the
establishment hanger to remove if from the line. | continued
to observe the line and at approximately 0657 hours |

identified another carcass that had a bright red
appearance, at this time | informedfbN6)
pre the chicken was remove m the Tine.

Tae oth observed the carcass and found that the
neck had not been cut and confirmed that it was a
cadaver. As [iB\iél and | were discussing the issue |
continued to identify three additional carcasses that were
bright red in color and did not have their necks cut on the
aughter line, Afler observing the additional carcasses,
(eye) huis] informed me that he was going
to stop slaughter to identify the cause. At approximately
0701 hours slaughter was stopped, | continued to observe
the carcasses that were already on the line prior to
stopping slaughter and observed four additional carcasses
that did not have their necks cut and were bright red in
color. All cadavers observed were removed from the
slaughter line and condemned, Please note, during the
time of my observations there was one back up neck cutter
after the kill blade. _At approximately 0707 hours Live
fever Sl foyre]and |. fe had a brief
oT ommed me that the kill blade had been
loose and that ithad been fixed, slaughter was resumed at
approximately 0708 hours. The regulations (9 CFR
381.65(b)) require that poultry be slaughtered in
accordance with Good Commercial Practices (GCPs),
Poultry are to be slaughtered in a manner that ensures thal
breathing has stopped before scalding, so that the birds do
not drown, and that slaughter results in thorough bleeding
of the poultry carcass. This MO! serves as a written
notice that future oversight of this nature may result in the
taking of additional administrative actions. Please submit
documentation of corrective and preventative measures

relating to this incident. Respectfully, {(b)(6)
nc

g

60


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P6137A Foster Farms NJNO614073 25JUL2020 Finalized | On July 24, 2020 at 1227 hrs whilelbW61 J was
6256 performing Poultry Good Commercial Practice she noticed

movement in the DOA barrel in live hang area. An
establishment employee was asked fo remove carcasses
on top until moving animal could be identified. The same
plant personnel put the chicken on the ground and it was
Se walking (Sa Ty
was noted ofthis
concem, The establishment's immediate corrective actions
was too put the bird on the line. Per Dacket No.
04-037N -Treatment of Live Poultry Before
Slaughter(2005)-FSIS reminds all poultry slaughter
establishments that, under the Poultry Products Inspection
Act (PPIA) and Agency requlations, live poultry must be
handled in a manner that is consistent with good
commercial practices, which means they should be treated
humanely. FSIS considers humane methods of handling
animals and humane slaughter operations a high priority
and takes seriously any violations of applicable laws and
requiations. Although there is no specific federal humane
handling and slaughter statute for poultry, under the PPIA,
poultry products are more likely to be adulterated if, among
other circumstances, they are produced from birds that
have not been treated humanely, because such birds are
more likely to be bruised or to die other than by slaughter.
Moreover, the PPIA (21 U.S.C. 453(g)(5)), as well as the
Agency's regulations (9 CFR 381,90), provide that
carcasses of poultry showing evidence of having died from
causes other than slaughter are considered adulterated
and condemned. The requiations also require that poultry
be slaughtered in accordance with good commercial
practices, in a manner that results in thorough bleeding of
the poultry carcass, and ensures that breathing has
stopped before scalding so that the birds do not drown (9
CFR 381.65(b)). Compliance with these requirements
helps ensure that poultry are treated humanely. This MO!
will be sent up the chain of command within Alameda
District.

64


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P46826 SHENANDOAH VALLEY ORGANIC BOK0515083 24AUG2020 | 04C05 | PoultryGood | Finalized | To:[bV6) jand
124G Commercial Tay 46286 From: [il foe)
Practices TICISPHV P46826 Subject: Chicken crushed and killed

on crate conveyor On August 24, 2020, at approximately
14:50 pm, | met with you and Complex Production
Manager Robert Terrell to discuss the following incident:
At10:54,(0X6)_— Ss bbserved a chicken on the
crate conveyor near the exit end of the conveyor while the
conveyor was running. One leg of the chicken was caught
in the grating of the bottom drawer/module of a crate that
was moving toward the exit. As the crate continued moving,
the other leg of the chicken became trapped under the
crate, and the chicken was crushed to death, 9 CFR
381.65(b) requires that poultry be slaughtered according to
good commercial practices. Humane handling is a
critical factor of Good Commercial Practices, and all
precautions should be taken by the establishment to
adhere to such. On multiple occasions, FSIS in-plant
personnel have discussed with plant management
concems about conditions in the live hang operation:
During the weekly meeting of 06/24/20, | discussed
openings that allowed loose birds to descend to the lower
level underneath the live hang operation. During the
weekly meeting of 7/15/20, | discussed my observance of
14 loose birds at one point the previous day, and 11 at one
point on the day of the meeting: two loose birds in the
blood room on the day of the meeting; and multiple birds
getting to the lower level. On 07/28/20,
issued an MO! outlining animal welfare concems, including
28 loose birds on the lower level and multiple instances of
loose birds on the crate conveyor (including one that was
trapped between two crates on the conveyor). On
07/28/20, Tavet——Issued a separate GCP MOI
describing a dead bloody chicken he had observed on the
lower level that appeared to have been crushed. As |
explained during the weekly meeting of 07/15/20, loose
birds are at risk of being inadvertently stepped on by
employees, being crushed on the cage conveyor, getting
injured falling to the lower level, etc. The incident on
08/24/20 where a chicken was crushed to death is a case
in pointand is unacceptable. In response to the concems
previously communicated, the establishment has taken
measures such as retraining live hang employees in
proper handling of birds; adding screening on the far side
of the crate conveyor; and adding barriers to close the
openings underneath the crate conveyor. However, these
measures have not prevented loose chickens from getting
on the crate conveyor and being crushed and killed. A
copy of this MO! will be sent to the Raleigh District
Veterinary Medical Specialist.

52


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P165H OK Foods, tne. DAF1414083 47AUG2020 | 04C05 | Poultry Good | Finalized | At approximately 1054 on Monday 08-17-20, while
917G Commercial performing a good commercial practice examination, | [51]
Practices Daily) observed the following. A live haul trailer was pulled

and notified them of

approximately half-way out of the holding shed and |
noticed that two cages were missing from the center of the
trailer, Approximately three birds were loose, resting in the
framework of the trailer, | observed one cage resting
under the holding shed and began looking for the missing
cage. Walking around the other side of the trailer, |

noticed a full cage of live birds sticking partially out of the
cage repair shop. The bottom door from one cell of the
cage was missing and an employee was MIG welding on
the cage. The birds in that cell of the cage were pressing
themselves against the far wall of the cage and were
stacked on top of each other to get further away from the
welding arc. As | walked closer to the employee, he put
the finishing touches on iis weld and then began
re-installing the cage door. At approximately 1140 | met
with[o)(6)

my observation and concems. Mr. Houston later met with
fe who oversees the
cage repair operation, EAE\_—Informe({V(6) Ithat
he would address this problem.

24


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P39 Pine Manor Inc. ULL1422090 03SEP2020 | 04C05 | PoultryGood | Finalized | Atapproximately 17:45 on Thursday, September 3, 2020, |
703G Commercial Goering 2nd shift SPHV P00039) while performing a
Practices Good Commercial Practices (GCP) task observed multiple

{a f my observations and he

live chickens wedged between the conveyer belt and the
end barrier in the live hang area. The birds were obviously
distressed and moving their wings in an effort to free
themselves. |t should be noted that the plant was utilizing its
backup (electrical) stunning method instead of its CO2 gas
stunner as the plant had been unable to receive a shipment
CO2, Therefore all chickens on the live hang conveyor belt
were fully conscious prior to being hung on the shackle

line. | then informed

immediately went and had the birds removed and hung on
the shackle line[P)©) told me thathe
would continue to monitor the area To ensure that no other

chickens would become wedged and experience any undo
trauma prior to being hung on the shackle line. At
approximately 19:45, | retumed to live hang area and
observediniay —Hosely monitoring the
area. | did not observe any chickens wedged between the
live hang conveyor belt and the end barrier. | then
commended[iy(6) for the effort they
were making under difficult conditions to ensure the
humane treatment and handling of the chickens prior to
being hung on the shackle line for stunning and slaughter.

42


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P7101

Tyson Foods, Inc.

LUC1208071
517G

47JUL2020

Finalized

July,14, 2020 At 1038 hours while performing a directed
Good Commercial Practice task on A-Line in the pinning
area | observed the following. | observed 1 bird enter the
scalder still breathing. The Back up killer was having a
hard time keeping up with number of chickens he had to
kill and occasionally stopping the line. This lot of chickens
had a big variation in size of chickens. [by6r

MAY. ind fAvAY

TVA were informed of these issues. That
aftemoon both és] fey reported
no birds entered the scalder breathing on both of there

checks. Kenny Koch, CS!

P7264+V726
4

Sanderson Farms, Inc.

VLB4814083
003G

03AUG2020

Finalized

On 7/30/2020 at approximately 6:00 PM a call was routed
to the USDA office from a concerned citizen who wanted
to report that she had observed a loose chicken on one of

At approximately 6:30 PM after the truck had arrived at the
plant and was parked in the holding area, | an
pa) observed a loose bird on trailer # 307545.
Tequested at the trailer be brought to the live hang area
so that the bird could be observed for any possible injuries
resulting from it not being properly restrained in transit.
The trailer was brought to the live receiving area and when
the 2 coups on the right of the loose bird(s) were removed,
| observed that there were 4 birds loose on the trailer in
this same area. None of the birds seemed to have
suffered any injuries. When the 2 cages on the left side of
this area were removed, | observed one of the cages with
a missing door that had 4 birds inside. There was no
evidence of a door for this cage on the trailer. The coup
was wrapped in red tape by the plant and was put to the
side/not returned to the trailer, On July 23, 2020 at
approximately 4:30 PM while conducting a Good
Commercial Practices task, | observed one bird fall off the
dump system (appeared injured). | estimate this to be
about a six-foot drop to the ground. | also observed one
bird undemeath the dump system on the ground lying on
its back covered in black substance(s) and that it was still
breathing. It was removed by plant personnel but this bird
had been subjected to dying by means other than
slaughter. On July 31, 2020 at approximately 3:30PM |
met with Plant Manager Eric Erickson concerning the
above issues. He stated that he would contact the
production manager responsible for loading of the birds
into the coups. Although these crews have received
humane handling training, he would discuss the
importance of not placing any birds into a cage that does

nothaveadoor. [ib] foye)

the Sanderson Farms' trailers that was enroute to the plant.

73


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M27389+P27 | Pitman Farms NCO4810095 18SEP2020 | 04C05 | PoullryGood | Finalized | While inspecting at P2789, Pitman Farms on 09/18/2020,
389+V27389 918G Commercial between 08:08 and 08:14, in performance of Good
Practices Commercial Practices (GCP). Inspection Plant Personnel

(IPP) noted approximately 1 out of every 10 Buddhist
chickens after CO2 stunning were conscious. The back-up
electric stunner was operating, and IPP noted no
conscious chickens immediately after the electric stunner.
IPP observed 5 Buddhist chickens for Jine 3 in live hang
entering the water scalding tank conscious. At 08:09 IPP
observed 1, then a 2 minutes later 2 more, and the last 2
chickens approximately 2 minutes later entering scalder.
The chickens IPP observed appeared to have been cut for
bleeding. The birds were blinking, with tracking eye
movement, and looking around (i.e. moving their head
back and forth). It was also noted one chicken tried to right
itself. There was no one in charge near the scalder at
that time; IPP had to leave the area and to find a
supervisor. At 08:22 IPP found a blue hat with a radio and
requested him radio (vaya
08:23, IPP and[G81_Went over to the scalder to explain
what was observed. When we arrived, there was an
employee, not previously present by the scalder, looking
for conscious birds. We did not note anymore chickens
entering the scalding tank conscious. A few minutes later
the line was finished, and no more chickens entered the
scalding tank. |PP informed Ismael that a Memorandum of
Interview (MO!) would be documented and explained that
the isolated incident of 5 chickens that were entering the
water scalding tank conscious is a mistreatment of poultry
concem. Ismael acknowledged the low CO2 levels were an
issue, and planned to take further action the next time
these chickens were slaughtered on line 3 by reducing line
speed if necessary. IPP informed (i=ay————]
tam of the observation and the
documenting of the MOI.

5


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P7485+V748,
5

Wayne Farms LLC

QBM5822091
122G

22SEP2020

04C05

Poultry Good
Commercial
Practices

Finalized

On Tuesday, September 22, 2020, at approximately 2230
hours at Wayne Farms, LLC Establishment number P7485
located in Jack, AL [a] [aye —“Wnwetbbserved a
live and conscious bird in the DOA bin for the Evisceration
Departments lines 1 and 2. The bird was positioned with
its head down in the pile of dead birds and litter and with
the rear of the bird positioned upwards. The bird

appeared wet and appeared to be taking full deep breaths
ata slow rate. The kill was finished on lines 1 and 2 and
the Sanitation employee's clean up efforts were
inadvertently adding water to the DOA bi
member of Management available so [iB]
the bird from the DOA bin. Upon retrieval the bird was
very cold to the touch, wet, and had difficulty holding its
head upright. The line 3 kill remained active so Ea |by@)
took the bird to the line 3 Evisceration cage dump

area and requested Maintenance to call the line 3

ne I called for
er

to view the live bird. The bird was humanely euthanized by

yey in the presence offBY6) and
ial

P7485+V748
5

Wayne Farms LLC

QBM2923094
423G

23SEP2020

04C05

Poultry Good
Commercial
Practices

Finalized

On Wednesday, September 23, 2020, at approximately
2230 hours at Wayne Farms. LLC Establishment number
P7485 located in Jack, AL al
observed a small live and conscious birt! on the floor of the
Evisceration Department live hang room for lines 1 and 2.
The bird was breathing and was lying in sternal
recumbency in a pile of litter and feathers. The bird's
head, left wing, and left leq were partially covered by the
litter and feathers. Superintendent Megan Gibbs was
immediately notified of my observations and the
forthcoming GCP MOI, Establishment personnel elected to
perform humane euthanasia of the bird by rapid cervical
dislocation.

76


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P7342+V734 | Wayne Farms LLC S$CJ2705085 21AUG2020 | 04C05 | PoultryGood | Finalized | Tonight, during my evening GCP walkthrough | saw a bird
2 521G Commercial coming down on the shackles, before the stunner, in Live
Practices

hang line 2 that had been decapitated, blood was dripping,
and it was stil twitching, The{®)6)
as with me observing he Hangers. Tasked Tim to

fi 1ead, | wanted to find out where exactly it
happened in case there was some equipment damage or
something that needed repair that had caused the incident.
We turned the lights on to look for the head and found that
birds are being suffocated while coming down the live hang
conveyor belt when they are forced under the edge of the
backsplash. Multiple birds were open mouthed, heads blue
to colorless, and several more gasping for air. We watched
for several minutes and noted this was a consistent result
of the birds coming down the live hang conveyor belt. In
addition, there were also wings and limbs stuck under the
backsplash, One back leg was found with muscle attached
but no bird seen missing a limb. With a line speed of 175
birds a minute this could be causing significant additional

trauma to birds before they are hung. We called the

fo come andook at
the bel/Backsplash So that ts problem gets addressed
ASAP. | noted a bird that was placed in the discard pile
that had been completely eviscerated. | did not examine
the eviscerated bird enough to determine if it was due to a
missing limb, torn skin, etc. The back leg found may have
possibly been the cause of the evisceration. We headed
over to Line 1 live hang and noted that there was a similar
issue there but the gap between the belt and the
backsplash was wider and was not causing damage to the
same degree. | still asked for them (live hang
supervisor/maintenance) to. address it, but | didn't feel that
the birds on that line were in the same immediate danger.

| explained all of this to the [a)()
b)(6)_] and tet him know that Twas writing a GCP MOT.

75


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P806 Tyson Foods, Inc. GC2521072 46JUL2020 | 04C05 | Poultry Good | Finalized | Est. P806, Tyson Foods, Inc. July 16,2020 2115
2166 Commercial hours. _ In attendance: ib ypyar BYE)

Practices (ar bie) J
| AYER ]
At2115 hours on July 16, 2020 | met with
in his office to

discuss observations that | had just recently observed in
the live bird hanging area. At 2058 hours when | entered
the live bird hanging area, | observed a substantial number
(approximately forty) of dead on arrival (DOA) chickens at
the end of the DOA conveyor where it meets with the live
bird hanging belt. When | arrived, there was no individual
on the floor to address the DOA birds. The head and neck
of one live bird could be observed sticking up from within
the pile of DOA carcasses. After a period of time, the
Evisceration Receiving Supervisor came off of the hanging
line to address the accumulation of DOA carcasses that
were on the belt. The supervisor identified that there was a
live bird mixed in with the DOA’s and he properly removed
this bird and returned it to the live hang belt. He next went
around the DOA conveyor and started the belt to move the
group of DOA’s away from the junction with the live hang
belt. He then began sorting through the DOA carcasses
and during this process an additional seven live birds were
uncovered that had been buried within the pile of DOA
carcasses. In each instance the live bird was removed
from the DOA’s and then hung on the kill ine. The
presence of these live birds under the DOA carcasses
coul ing by being suffocated. | reviewed
with ()6) ie requirement that live poultry be
handled in a manner that is consistent with good
commercial practices to minimize any suffering ot harm to
the birds and ensure that they do not die from causes
other than slaughter. | also advised Mr. Washington thata
previous Good Commercial Practices MO! had been
issued approximately one month ago for a similar
observation in the live bird hanging area on the second
shift. | informed {EXT} that the actions taken in
response to the previous occurrence had not prevented the
recurrence of this issue as indicated by my observation
hie alled for [(6)(6)

tor
CG
to. come to the office and upon his arrival | reviewed with
him my observations in the live bird hanging area. FSIS.
recommendations concerning the treatment of live poultry
before slaughter are presented in Federal Register Notice
Vol. 70, No. 187 [Docket No. 04~037NJ, published
‘September 2005, and a copy of this document can be
provided to management upon request._Later that
evening, around 2200 hours, came to the
USDA office and reemphasized to me that the proper
handling of the live chickens is viewed as a serious matter

78


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P2686 Equity Group Georgia Division, LLC KBAQ513074 20JUL2020 Finalized | Mr. Robert Dowdy, Plant
620G Manager

Equity Group Ga Division, LLC 7220
U.S. Highway 19 North Camilla, GA 31730 To: Mr.
Robert Dowdy Atapproximately 0845 hour, on July 17,
2020 while |, CS! Culbreath was in the
Evisceration Live Hang Department the following
noncompliance was observed: Combine with both lines, |,
Tau cicaved c nascive stir of orvosses
(66) scattered, piled up, and being step on by the
employees throughout the floor from both lines. Four (4)
yellow condemn containers were also observed with a
numerous number of carcasses filled to the brim and
spilling over unto the floor. No management officials were
in the area during m ry dbearyaan At this time, Live Hang
Supervisor [(b)(6) | rem rr came out onto the floor and
begin retrieving birds from the floor. Evisceration
‘Superintendent da] [iil and QA Supervisor faxall

Poa Twas summoned {o the area and observed the
aforementioned deviation. Mr. summoned the lead
personnel of the department and |few=1————] observed
the carcasses on the floor, the carcasses out of the
containers, and five live (5) carcasses being pulled from
beneath the piles of carcasses of Line Two and hung back
unto the line by the establishment trained srplayee who

performs the cervical sislaratton|siianest) The

establishment maintains this are, rough their
SSOP et peers: (ONG) formed my
SPHV. [il [d¥/60] and notified her of the forthcoming

Mol. lesen was informed that a MO! would be
issued to the plant and that this MO! will be forwarded to
the District Office and the District Veterinary Medical
[awe] and Plant
Manager, Robert Dowdy in case additional follow-up is
recommended, Your response to this matter would be
appreciated. Sincerely, fara] (oye) Te]

35


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P1284

Pilgrim's Pride Corporation

GDA1510080
720G

20AUG2020

04C05

Poultry Good
Commercial
Practices

Finalized

Est. P-1284, Pilgrim's, August 19, 2020, 1430 hours. In
altendance: [ip iibv(G) Tone) _] ]
(orale At approximately
1225 hours while performing a Poultry Good Commercial
Practice verification in tet live vehana area of the poultry

receiving department, | [(b)) [dail [(5\6) —] and io)
ae observed live hang personnel mishandling
live birds. Live Hang personnel were observed throwing live
birds at the shackles instead of placing them in the shackle
and hanging forcefully. Because of the action of throwing
birds at the shackle by one of the establishment
employees, he missed the entire shackle. | took immediate
action and stopped the picking line and notified Lead

(b)(6) | We met with foyer ——_]
(b)(6)_|and reminded him that the Poultry Product
Inspections Act (PPIA) and Agency regulations do require
that live poultry be handled in a manner that is consistent
with good commercial practices (GCPs). This includes
employing humane handling that prevents needless injury
and suffering in compliance with these requirements to.
ensure that poultry are treated humanely. |

recommended that Mr. review Federal Register
Notice Vol. 70, No. 187, published September 2005.
[Docket No. 04-037N] for FSIS recommendations
conceming treatment of live poultry before slaughter and
provided him a copy of this document. Mr. stated
he would investigate the cause and provide any planned
action with a written response. Mr. was informed
that this mistreatment MO! will be forwarded fo the District
Office and the District Veterinary Medical Specialist
(DVMS) in the event additional follow-up is recommended.
A plant response is requested. Respectfully, [bh]

P1317+V131
7

Wayne Farms LLC

QUI3120074
016G

16JUL2020

04C05

Poultry Good
Commercial
Practices

Finalized

Dear Mr. Elrod, At approximately 20:05 hours, on July 16,
2020, while accompanying [a] Bosko Rak performing the
Review and Observation component of the PHIS task,
“Poultry Good Commercial Practices,” If)

Bye) |. observed two live birds covered by anacommgted
Witrrdead birds in a pile on the sliding chute at the end of
the live bird belt. During a meeting, with the second shift

WAY land\(b)(6) leld in
USDAVFSIS office pee ee a F20 hours Tinformed

him that a GCP MO! documentation of our meeting and

discussion of the observed deficiency would be
forthcoming. Cc: [a [(by6)

((o)(6)

21


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

LWA4615062823G for reference. Observance of cadavers
in Evisceration has been a recurring issue for the three
months. The establishment must ensure that itis following
all good commercial practices for the production of poultry
products.

P165S+V165,
Ss

OK Foods, Inc.

LWA562008
3625G

25AUG2020

Finalized

On Tuesday August 25, 2020 at approximately 1845 hours,
1 was performing Ante-Mortem to verify Good Commercial
Practices (GCP) according to instructions in FSIS
Directive 6100.3 Poultry Inspection. | noticed while
performing my task in the Live Hang room there was five
dead birds and one live bird on the floor. There was one
live bird inside the condemn barrel that was underneath a
couple of dead birds. | immediately informed the
supervisor at the time which was Jeanette Wilkins of what |
observed; she immediately took action and picked the
dead birds up off the floor area and placed them inside of
the condemn barrel, She then took the one live bird and
placed it back on the conveyor belt. And then a team
member took the live bird that was inside of the condemn
barrel and placed it back on the conveyor as well. This
MO is linked to NR# LWA4600081021 for a similar failure
in process control.

P165S+V165
Ss

OK Foods, Inc.

LWA192209
4509G

O9SEP2020

Finalized

On Wednesday September Sth, 2020 at approximately
1510 hours, | was performing and verifying poultry good
commercial practices (GCPs) according to the instructions
set in FSIS Directive 6100.3 Poultry Inspection. | observed
5 live birds on the floor of the Live Hang Room. There
were also 3 live birds in the one Condemn Barrel pinned
underneath 3 dead birds. | immediately flashed my
flashlight into the condemn barrel and informed a team
member of my findings. He responded by picking up the
live birds off the floor and placing them back on the Live
Hang conveyor belt, then the 3 live birds in the condemn
barrel were removed and placed back onto the Conveyor
Belt. | then informed of
upcoming MOI. | informed
the issues and then had an informal discussion wil

about possible corrective
actions. This MOlis linked to MOI # LWA5620083625G
written on 8/25/2020 for similar issues.

of

27


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P15724

Case Farms, Processing

EVC5905081
7276

27AUG2020

Open

At approximately 1350 on August 24, 2020 SPHV was
conducting a routine good commercial practice task and
the made the observations described herein. The
automatic kill machine was not functioning properly. The
hourly establishment employee backing up the kill machine
was working fervently but was unable to keep up.

jadvised that the line needed stopped and
Subsequently stopped the line. Roberto Galvez arrived at
the area along with maintenance personnel and they were
advised the kill machine was not working and production
could not resume under the previously described condition
as there were numerous birds that had not been bled out
on the bleed chain. Management subsequently corrected
the issue with the non functioning kill machine, added
another employee to help back up the kill machine and
[facilitated bleedout of the live birds on the
bleed chain by cutting the neck. Approximately 8 minutes
later in the picking room observed a group of 50
birds on the kill line immediately after exiting picker #3 in
the group of 50 there were 9 cadavers of which 7 were in
a roo] determined the birds descried above
were cadavers due to the fact that the carcass was bright
cherry red, the neck has no visible cut and the head and

6)(6)
were informed of the less than ideal conditions that that this
would be documented.

P164

Tyson Foods Inc

1JM40210959,
07G

07SEP2020

04C05

Poultry Good
‘Commercial
Practices

Finalized

To: Mr. Steve Langford, Plant Manager Tyson Food,
P-164 Forest, MS Atapproximately 2215 hours, while
performing a portion of the Good Commercial Practice
Task as | was observing the birds entering the scalder in
the Picking reom.area in the Establishment’s Evisceration
observed a live bird
entering the scalaing tank Tor Picking Line # 2. The live
bird was small, and no cut was evident on the bird's neck
area. The bird was alert at this time. | informed APM Steve
((oN(6)

observations and the forthcoming GCP MOI.
)(6)

23


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P3

Mountaire Farms of Delaware, Inc.

0CG0417092
609G

09SEP2020

04C05

Poultry Good
Commercial
Practices

Finalized

On September 9, 2020 at approximately 1715 hours, while
yas completing
GCP/antemortem verifications, the following was observed.
Between the two conveyor lines at the forklift loading ends
there was a bent gate disconnected from a chicken cage
on the floor, and there was a severed chicken leg with part
of the gate twisted around the Tibia/metatarsus. The
chicken leg was complete from claw to thigh, and the
remainder of the bird was not present, nor was it in the
condemn barrel immediately next to the gate. | brought this
tofyar SS attention, and he took
pictures of the gate and chicken leg. Its plausible

that severing the chicken’s leg could have resulted in the
bird dying by means other than by slaughter. No other
significant findings were observed. It is 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.
‘Supervisor Maurice was notified that this MO! will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended. Sey, ror
Mountaire Farms of Delaware, Establishment P3_ 29005
John J Williams Highway Millsboro, DE 19966

P308

Koch Foods, Inc

SPL3809095
210G

10SEP2020

04C05

Poultry Good
Commercial
Practices

Finalized

THO) Jat
approximately 0623 hours, while performing a portion of
the Good Commercial Practice task and as | was
observing the conditions in the Live Hauling area, |,

(ee) —Tobserved a live bitd breathing, partially covered
by a pile of DOAs inside the large bird DOA bin. |
immediately notified nearby Koch team member[by6) _]
of my findings. He proceeded to remove the bird

from the DOA bin. The bird, once freed, began to move.
[oer humanely euthanized the bird by cervical

dislocation. | informed

Laxey J of this finding andthe torncommcussuance
of this GCP MOI, (0)(6)
Kby(6) real

36


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1243 Perdue Foods, LLC. XLB3410083 05AUG2020 Finalized | Atapproximately 9:35 am, | [)] tsar“) observed that
705G evisceration line #2 was down, due to this observation this

prompted me to the kill room to ensure live birds on the
picking line were being properly addressed. Once in the
kill room, | observed birds were regaining consciousness
that had previously exited the stun machine. The birds
were seen blinking, breathing, and aware of their
surroundings. At this time, | Started a timer on my
stopwatch to ensure establishment employees would arrive
to follow establishment procedure. After
approximately 5 minutes, an employee began to cut the
necks ofall birds that were previously stunned and that
regained consciousness. | continued fo observe and wait
for an employee to drain the water from the stun machine
inatimely manner, but no action was taken. Once the
timer on my stopwatch displayed {0 minutes and 30
seconds, | left the kill room to noti
approximately 9:49 am | notifed(bM@) |
Gbservaons,who hen hotitad an eriplovee wacko is,
matter, My stopwatch timer displayed 11 minutes and 30
seconds when an employee finally opened the drain cover
which allowed the water to drain fram the stun machine.
When the stun machine appeared to be fully drained below
the stunning grate my stopwatch timer displayed 13
imi A statement was provided to USDA

A oe states: “Handling of birds in
stunner during prolonged periods of downtime. In the
eventa line goes down for greater that 3 minutes and the
birds cannot be cleared thru the stunner the following
should occur. The water level will be drained below the
stunning grate, which will keep their heads out of water
plus power will be shut off tothe stunner. This addition to
our program will be implemented beginning Thursday night
November 21,2019.” The establishment failed to
implement the statement above, ‘Agency regulation
require that the poultry be handled in a manner that is
consistent with Good Commercial Practice, and that they
donot die from causes other than slaughter. ttis the
establishment's responsibility to ensure that the birds are
slaughtered in accordance with 9 CFR 381.65(b).

18


Table: Noncompliance Reports in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName.

NR Id

NR#

Date

Task

TaskName

Regs

Status

4

Description
bright red in color with dark red/purple swollen heads and
no signs of a cut. | notified aya; pho called
= 1

conferred with his employees and confirmed that he had
already been notified of the two cadavers and made further
corrective actions. He informed me that shortly after
company break (after 0515 hours) he added a third
employee in the kill room as an extra back up cutter. No
more cadavers were observed up unti of nightshift
at approximately 0705 hours. FLS [BJ lwas
informed of all findings. At approximately 0725 hours at the
start of dayshift, |, faray~——— -p16)] observed one
cadaver in the yellow barrel at the Line 1 pre-sorter station
and one cadaver in the yellow barrel at Line 2 pre-sorter
station. Both carcasses were bright red in color with dark
red/purple swollen heads and no signs of a cut. | showed
my findings to Supervisor el and Supervisor

(Bye) PG] informed me that

maintenance personnel were going to adjust the kill
machine on bath lines, and he was also going to keep the
third employee in the kill room as an extra back up cutter,
After conferring with [Y@)___————_sknd DVM [ia]
Anthenill, it was determined that a noncompliance would be
issued for the incident on 08/15/2020. There were three
instances that resulted in clusters of poultry dying by other
means that slaughter, even after corrective action were
taken by the establishment. The PPIA and Agency
Regulations require that live poultry are to be handled in a
manner that prevents needless injury and suffering and in

a manner that is consistent with good commercial
practices. At approximately 2233 hours on 8/16/2020, |
informed [oxe1_______]of the forthcoming
noncompliance report. Our findings indicate a
noncompliance with the regulatory requirements of 9 CFR
381.65(b).



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P7487 Koch Foods, LLC SPG3207085 49AUG2020 | 04C05 | Poultry Good | Finalized | On Tuesday, August 18, 2020, at 12:06 P.M, | [51]
619G Commercial VGN Hected to perform the good
Practices commercial practices check and observed the following in

picking room. | was standing before the 140 picking line
scalder. | observed two live birds with blinking eyes, lifting
their heads (arched neck), and did not observe cut to the
necks or any bleeding entered into scalding tank. | did not
find the live hanging supervisor, and immediately notified
pore) abonnrny

r Sincerely, [i]
487 Koch Foods of Chattanoox
TDS eksen istic Tl

|] Jackson Distict

7


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
p5e4 Pilgrim's Pride Corporation QLM2222082 20AUG2020 Finalized | On 08 17 20 at approximately 0135 hours, the following
5206 was observed in the Picking room: Line 2 was down due to

the line being hung up. | went to the area where
maintenance was working on the line. fAwal_—_]

]was in the area timing the line stoppage. 1 look at
her stopwatch and the line had been down for
approximately 7 minutes. informed her
lead to inform the back-dock Supervisor fo remove the
birds out of the stunner. | observed approximately ten birds
being removed out of the stunner. The birds were wet, had
not been euthanized and had drowned inside the stunner. |
lifted the head of one of the birds to confirmed it had

drowned. as verbally
rotted ofthe hirg EE" ras lso
notified of the finding. The establishment failed to
implement their written procedure,(Welfare) Procedure for

Line Stoppage/Power Outage(Policy No. 2700-240) which

tates in part, TAVAT
oye)

Koy) if the line has not re-started when

the backup knife operator gets to the stunner, the picking
room supervisor or designee will turn off the power to the
stunner and drain the water to a level that will allow birds in
the stunner to breathe.

62


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M4653A+P46 | Agri Star Meat and Poultry, LLC HRJ0017090 09SEP2020 | 04C05 | PoultryGood | Finalized | Throughout the day | noted the following issues and
53A+V4653A 609G Commercial relayed them to various members of management:
Practices Overnight temperatures were around 45 degrees and

itrained consistently through the night and all day today.
Birds were transported in from two hours away
overnight. On antemortem inspection and in observing the
kill room today there are an excessive number of DOAs, all
of which appear wet and recently dead (since loadout). On
trailer 201, all of the birds on the passenger side in the last
four mods were soaked and were all dead. DOAs were
arriving on the kill belt at a rate that they were being piled
on the floor in the kill room and at three different times
throughout the day | observed that dead birds were
completely blocking the walkway in the kill floor. Gray
barrels were overflowing with dead birds and either no one
was picking up and disposing of deads or when they were
they were not able to keep up to maintain sanitary
conditions. With so many birds coming in dead, agonal
but conscious/alive birds were being removed along with
deads and being thrown to the floor. When employees
noted live birds that needed euthanized their technique for
cervical dislocation was not done in a manner to render the
animal unconscious quickly and as painlessly as possible.
Further, | noted that several times birds coming in on the
kill belt were stacked on top of one another. Not all birds in
the bottom layer were DOAs. | went and observed the mod
dumper and noted that at times the dumper belt would be
running when the kill belt was not. When | relayed this to
he said that the two belts
are supposed fo be in sync to prevent this and that he
would notify maintenance of the issue. The total DOA
count for the day was 3207.

10


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P247 Sanderson Farms, Inc. (Procesing Div) | ETGO010081 17AUG2020 Finalized | At approximately 0920 hours, while observing conditions in
117G the live hang pen in the poultry receiving department, |,

[yelasl——Jobserved the following. There were

6 live young chickens comingled with approximately 20
dead-on-anivals (DOAs) that had been allowed to pile up at
the end of the live hang conveyor. All but 2 of the chickens
were completely covered by the dead chickens and could
have smothered. Upon observing this, | notified

who was present and he
immediately removed the live chickens from the pile and
hung them on the picking line._I then informed

of my findings. Za]
 euse
of the forthcoming GCP MO! for this less than ideal
management of live birds.

33


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P6638 Pilgrim's Pride Corporation UDG1414082 41AUG2020 | 04C05 | Poultry Good | Open At approximately 1226 hours, | entered the Live Hang Area
1W1G Commercial to notice 4 chicken legs/feet sticking out from underneath
Practices the white board that separates the moving Live Hang

conveyor belt and the DOA catch tray. |immediately tried
toalert the hourly employees hanging and no one
responded. | then saw[awar —_Joutside the
double doors to the back dock and notified him. He came
inside to address the situation. When the white board was
lifted, the chickens were brought through onto the DOA
catch tray, however one chicken was forcefully pulled
under the white board while it was only partially raised by
an hourly employee by its foot. The chicken was then let
go into the DOA catch tray with the other live chickens that
had been trapped under the white board in the live hang
area. [bY6) Was with me at the time of
observation. | informed {b)(6) that the
chickens trapped under the white board was less than
good commercial practices due to the undue excitement,
discomfort, and potential for injury caused by entrapment
between the white board and moving conveyor. | also
discussed the manner in which the hourly employee
mishandled the live chicken that was last to be retrieved
from under the white board. | informed Evisceration
‘Superintendent Paul Francis of my observations and the
forthcoming Less than Good Commercial Practices
Memorandum of Information (GCP MOl). Respectful
Submitted, KallBaI—————— TC:
(ey ]

69


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P7044 Tyson Foods, Inc. GJJ1309075 24JUL2020 Finalized | On July 24, 2020, at approximately 0411 while observing
024G (ovey conducting a Pre-operational

Sanitation task, (b)(6)
observed the following conditions in the Kil Room. There
was a live chicken standing behind the pump located in the
alcove on the south wall of the kill room. Production had
not started for dayshift, meaning the chicken had been
there all night._[pv6) immediately notified
eye) }fthe
concem with live bird left overnight. USDA inquired with
maintenance and multiple sanitation workers to ask if they
were comfortable retrieving the bird and no one was at that
time._At approximately 0435, located the

(bVG) He removed the bird and

euthanized it at approximately 0442. (BY)

[RR poke with alt approximately 0530
| and informed USDA that he would contact the Welfare
(exe ind discuss having him do more
animal welfare checks. He would also discuss the issue
with Gaya jo
verify that the area is being cleared at the end of the shift.
Allowing birds to be left in the establishment for an
extended period of time is inconsistent with the Agency's
expectations of Good Commercial Practices. The
establishment is asked to ensure no live birds are left
overnight and/or for an extended period of time to prevent
needless injury and suffering, consistent with Good
Commercial Practice (GCP) Employing humane methods
of handling consistent with Good Commercial Practices
can help produce an unadulterated product. Copies of
this Memorandum of interview will be distributed to the
establishment, inspection file and the District Veterinary
Medical Specialist per FSIS Directive 6100.3. The issue
will also be discussed at the next weekly meeting.

71


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P705

Pilgrim's Pride Corporation

FTJ2007075
327G

275UL2020

04C05

Poultry Good
Commercial
Practices

Finalized

Est. P705, Pilgrims_Friday, July 24, 2020 1150 hours in
attendance: CS! [vay i

Bay GIT This Memorandum

of Interview was written because of live birds being mixed
in with a pile of dead on arrival birds, at the end of the
dumping belt in live hanging room, on 7/24/2020 at 1150.
While IPP was performing Good Commercial Practices
(GCPs) in the live hang area, IPP observed a pile of DOAs
on the floor that was as high as the dumping belt. The pile
consisted of approximately 40+ birds. While IPP
observed an employee going through the pile of DOAs, the
employee found around 14 live birds mixed within the pile
and proceeded to hang them on the line. Some of the live
birds were right on top of the pile, while some of them had
2o0r 3 DOAs piled on top of them. The employee then went
to give breaks on the line, leaving the pile there for an
additional 15 minutes. While | was present, after the
employee left to give breaks, no other plant employee was
trying to pick up the large amount of DOAs, however more
were being added to the pile. At this time IPP had stayed
in the area approximately 20 minutes and was not able to
find anyone to contact a si hen went to look
for a supervisor and found| feats st Processing
‘Superintendent, at 1220. IPP told [pay Jof the
findings and explained that it would be documented under
a Good Commercial Practice MOI. IPP also informed QA
Manager, Sissy of the MOI. The birds pulled from
the pile looked weak and some were in a position that.
could cause suffocation, especially with the heat of
summer. The concem with the pile of DOAs at the end of
the live hang belts has been brought up in several weekly
meetings to the establishment. Some recent meetings were
held on 5/20/20, 6/04/20, 6/10/20, and 7/09/20.

P705

Pilgrim's Pride Corporation

FTJ5821081
917G

17AUG2020

Finalized

. August 17, 2020, 1955 hours, |, LC Morris, was

erforming Good Commercial Practices (GCP's) along with
ttl y jin the Live Hang Area. At the
transfer belon Alme between the cage dump and hanging
area, | observed several birds with their paws getting hung
up ina pinch point on the belt. | observed as the feet were
being trapped in the pinch point, finally being freed and
then other birds having their paws caught in the same
pinch point. A gap between the belt guide and belt was
allowing paws to be trapped which guided the paws to the
pinch point. | summoned[awar 7k and

maintenance to correct the guide issues.

72


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P20138 Bo-Bo Poultry Market Inc DQH2110093 11SEP2020 Finalized | Good Commercial Practices educational meeting: [BY6)
111G [HVG) as present in the meeting as representative of the

establishment. The topic discussed was the Good
Commercial Practices. The GCP also include the birds
handling when arrive and unload birds from transport.
During the unloading birds from transport the birds will be
not mishandled or mistreated. Transport truck with birds
should not be parked outside the plant for prolonged
periods. This exposes the birds to environmental elements
of excess heat /cold etc. Birds should notarrive in broken
crates leading to escape of the birds in the streets.
Sidewalks and outside should be properly cleaned to avoid
any insanitary conditions. Empty transport trucks or empty
crates (with dried fecal material) should not be left outside
of the plant or in the alleyways. This also creates insanitary
conditions which leads to foul smell and flies. The meeting
ended without further comment.

30


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P890 Peco Foods, Inc. cyb4603075 29JUL2020 | 0405 | PoultryGood | Finalized | Mr. Shannon Hendry Plant Manager Peco Foods,
529G Commercial Canton 1039W. Fulton St. Canton, MS 39046 Mr.

Practices

Hendry, Al approximately 0309 hours on July
29, 2020 while performing the routine PHIS Poultry Good
Commercial Practices (GCP), a live bird with uplifted head,
pupillary reflexes, rhythmic breathing, and no visible cut to
the neck entered the scald tank. A verification of a
subgroup of approximately 500 birds which had been

slaughtered was made at the scalder entrance. Mr.
(b)(6) was notified of my

observations, Controls to prevent birds from entering the
scald tank live were in place according to management

including a backup cutter in the case of mechanical failure
and an E stop to stop the line__A meeting was held in the
USDA office breakroom with{(b)(6)

BG) ack dock Supervistr-
visceration Superintendent representing management

and [by(6y ],and
myself representing FSIS. The incident and the issuance
of a GCP Memorandum of Interview (MO!) were discussed
with management. No corrective actions were brought
forth by management in this meeting. Plant management
was nolified of the forthcoming GCP MOI. A second
verification at the entrance of the scalder was performed at
approximately 0428 hours of a 500-bird subgroup. No live
birds were observed entering the scalder during this
observation. This GCP MOI will be discussed with plant
management a the next regularly scheduled week!
meeting with plant management, Respectfully, ra |
wer J |
Starkville Circuit’ Office of Field Operations, DO-90
Jackson Food Safety and Inspection Service, USDA
713 S. Pear OrchardliS] Ste. 402_Ridgeland, MS 39157

f(o)(6)



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M34078+P34 | Great Lakes Poultry, Inc. JCF3512073 09JUL2020 Finalized | Good Commercial Practices MO! This MO! is to
078 709G document the observation of the mistreatment of live

poultry prior to slaughter. The issue occurred at
establishment number 34078, Great Lakes Poultry, at
approximately 9:30 am on July 9, 2020. The issue was

. discussed with faa Vad Mr,
Steve Lilovich, plant owner. The meeting was held by [ib]
At approximately 8:30am while
conducting the Good Commercial Practices task, |, Ia]
observed 3 to 4 very small Comish hens
that appeared to be conscious in the condemn bin
containing dead poultry. Upon closer inspection, the birds
were alert and able to maintain posture. None appeared to
have had their necks cut in order to euthanize them. Mr.
(amas asked to come into the poultry slaughter
area and observe my findings.[oy) _pmoved the
birds from the barrel and confirmed Rat none of the birds
in question had been cut. He spoke with the slaughter
personnel who told him that those birds were too small to
hang. [O6) instructed the employees to euthanize
the biras—rreasd instructed the employees that no birds
were to ever go into the condemn bin without being
euthanized first Prior to leaving the facility, a meeting

with NYG) occurred where the above issue was.

discussed.

g


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M32130+P32 | Dakota Provisions LLC JEB1313090 29SEP2020 | 04C05 | PoultryGood | Finalized | Est. 32130, Dakota Provisions, 09/29/20, 1300 hours.
430+V32130 6296 Commercial Meeting Attendance: aye. >]
Practices (On 09/29/20 at approximately

0840 hours while performing and operational sanitation
inspection verification task in the Pick and Hang
department, | noticed a live bird on the bleed line before
the scalder that was arching his neck and trying to escape
the shackles. | immediately stopped the line and informed
plant personnel of the conscious bird about to enter the
scalder. While | observed this bird on the line, he was
able to arch his neck and blink his eyes. They grabbed a
portable ladder and pulled the bird off the line. The bird

did not appear to have a neck cut. The bird was then
immediately relocated back on the line before the neck
cutter fo start the process over. stated that
there was a new employee stationed as the backup for the
neck cutter, he had received training but the establishment
decided to move him to another position and place a more
experienced person in that position, The incident that took
place is a concer due to the neck cut miss and its path
Straight to the scalder to drown, as it was still breathing and
fully conscious. Employing humane methods of handling
and slaughtering that are consistent with good commercial
practices increase the likelihood of producing
unadulterated product. Poultry must be slaughtered in
accordance with good commercial practices in a manner
that will result in thorough bleeding of the carcass and
ensure that breathing has stopped prior to scalding.
Stunning of poultry, when performed, is also expected to
be done in a consistent and effective manner.

6


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1243 Perdue Foods, LLC. XLB0204093 21SEP2020 | 04C05 | PoultryGood | Finalized | At approximately 0325 hours while performing Good
721G Commercial Commercial Practice Verification Task in Live and
Practices Receiving, | observed the following issues of concem. |

observed a live bird still inside of the cage, the bird neck
was stuck in a hole in between the damage cages. Live
and (YG) |were
nolified and observed my observation and concer. He
had the bird removed from the hole in the cage, the bird
were still alive. | went to look at another truck that had
birds stil on it and observed another bird hanging out of a
damage cage that were broken, it looked dead. Live and
Receiving lead person came and pushed the bird back up
into the broken cage and there were no movement from
this bird. Thomas stated that the
cages would be repaired. | prepared this report on
09/21/2020 and | certify that this report has recorded in it
a summary of all pertinent matters discussed. This MOI is
associated with MOH#XLB5400042120G

19


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

TMM46070+P46
070

Marble City Meats LLC

KLE0410085
928G

28AUG2020

04C05

Poultry Good
Commercial
Practices

Finalized

On Thursday, August 27, 2020 at approximately 1:40PM,
while observing establishment employees handling
chickens to be placed in killing cones, establishment
employee kill employees informed 7 birds (3 from one
producer/grower, 4 from another) were dead in the crates.
IIC had performed an Antemortem inspection that moming
before the start of slaughtering and no birds showed signs
of any aliments, sickness, or lameness. This indicates that
birds died from heat stress. lIC informed establishment
owner Matthew Lawrence as well as poultry producer of
the issues, Establishment owner stated that he informed kill
employee to spray live poultry and cages with cold water
to ensure they remain at a cool comfortable temperature,

M46070+P46
070

Marble City Meats LLC

KLE1012095
915G

15SEP2020

04c0s

Poultry Good
Commercial
Practices

Finalized

On Tuesday, September 15, 2020 around 6:00am while
observing establishment employees handling chickens to
be placed in killing cones, establishment employee stated
that 6 birds were dead in the crates. lIC had performed an
‘Antemortem inspection that moming before the start of
slaughter operations and several birds were open mouth
breathing, indicating that they were possibly suffering from
heat stress, Establishment employees sprayed all crates of
birds with cold water to help cool down IIC informed
establishment owner and producer Matthew Lawrence of
issues.

M4653A+P46
53A+V4653A

Agri Star Meat and Poultry, LLC

HRJO610091
703G

03SEP2020

04c05

Poultry Good
Commercial
Practices

Finalized

At approximately 1000 | saw that about 20 birds were piled
atthe end of the kill belt, which had resulted in several
birds on the bottom layer being smothered. | pointed this
out to the handler at the end of the belt, and the supervisor
in the kill room. Several of the handlers said that the belt
was getting piled because the rabbis at the end of the line
were killing slow. | later spoke with

bv6) ind informed her that this was not the first time

this week | had seen this happen. The establishment
program states the employee running the kill belt must
make sure birds at the end of the line do not get piled up or
pushed against the plate at the end of the belt. She said
she would speak with(b)(6)

3


s

Table: Noncompliance Reports in Response to FOIA2021-108 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
P8107+V810 | Squab Producers | {7F56501B-754F- | DCF5613 07/15/2020 | 04C05 | Poultry Good 381.65(b) On Thursday, July 16, 2020 at approximately 11:10am CLOSED
7 Of California 4322-94A0-92A2 | 070316N Commercial while overseeing the establishment's squab slaughter
B95C7493} 4 Practices operations the following noncompliance was

noticed:Establishment P8107 began rendering squab
shortly afier finishing their evisceration for the day,
approximately 11:00am. IPP was observing the rendering
process to ensure good commercial practices and proper
disposal of squab carcasses. During observation
was positioned in the doorway that
separates the slaughter area and the production area. |
noticed a bird on the bleed rail was only hung on the
shackles by one leg and was moving in a way that was
atypical for stunned and slit birds. | entered the slaughter
area to observe handling of birds.It was unclear whether |
saw a live bird enter the scalder, so | waited to see if the
bird was properly bled after scalding. While standing in
front of the feather plucking machine, | was observing
birds entering/exiting the scalder and the employee who
slits the birds after stunning. | noticed the bird exiting the
scalder was moving its wings and alerted the two
employees nearby that | believed the bird was stil alive.
Establishment employee removed the bird from the
shackles to discover the bird was stil alive and the throat
was not slit. Employee took immediate action to euthanize
the bird. | found (66) Ho inform him of
the situation and the forthcoming noncompliance. This
finding represents a noncompliance with 9 CFR 381.65(b).
Failure to comply with regulatory requirements may result
in disciplinary and administrative actions.



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI Agenda

P9197

Perdue Foods, LLC.

UAB2612070
008G

O8JUL2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 7/7/20 at approximately 1145 hours, the inspector on
Line #1 Stand #2, 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 381.65(b). |
informed AIFood Safety Supervisor,
and [is bout the bird that had
been presented to me. | showed Mr. (56) ___]and Mr.
(GMB) the bird. | also reminded Mr. (06) _Jand Mr.
[V6 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 MO! will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended.

P9197

Perdue Foods, LLC.

UABO712073
608G

08JUL2020

04C05

Poultry Good
Commercial
Practices

Finalized

On 7/6/20 at approximately 1130 hours, the inspector on
Line #2 Stand #2, 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 381.65(b). |
informed [piggy pnd a]

Team Lead, about the bird that had been presented to me.
| showed Mr. and Mr. [60 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 thraugh 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 properly
slaughtered, | also reminded Mr. and Mr.

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 itfor 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.

84


1

Table: Noncompliance Reports in Response to FOIA2021-108 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
P1284 Pilgrim's Pride {B033D7CC-DSE | GDA261 08/19/2020 | 04C05 | Poultry Good 381.65(b) MO} documented in lieu of NR. MOI attached. CLOSED
Corporation 9-4E65-8£42-0D | 0085820 Commercial

17C859F7BE} NA Practices
P165S+V165 | OK Foods, Inc. | {9F32BED1-9D6 | LWA460 08/20/2020 | 04C05 | Poultry Good 381.65(b) On 8-20-2020 at approximately 2255 while performing a OPEN
s 0-4828-887D-F8 | 0081021 Commercial Good Commercial Practices check | observed 5 chickens

08A0B60184} NA Practices underneath the conveyor belts that move the full and empty

cages to and from the dumper. | immediately got with
(ONG) iets eee eg] about the birds and it was
| That one oF Ihe 5 were already dead. The live

birds were placed into cages that were traveling to be
dumped and the dead bird was condemned. | then
checked the production paperwork that involves the hourly
dumper and grounds check to find the last hour recorded
to be the 2100 hour the 2200 hour was missing at that time.
informed supervisor Leroy of the incoming
documentation. Atapproximately 2305 while walking
through the live hang room | observed a live bird fall into
the yellow condemn barrel at the end of the belt; | tried to
wave at the team member at the end of the line so the bird
could be retrieved but to no avail, he then proceeded to
throw a DOA bird on top of the bird at the bottom of the
barrel. | informe ind she retrieved the
still living bird from undemeath the dead one and placed it
back on the line to be processed. | informed her of the
upcoming NR. The establishmentis in violation of USDA
regulation 9 CFR 381.65(b) which requires that poultry
must be slaughtered in accordance with good commercial
practices in a manner that will result in thorough bleeding
of the carcasses and ensure that breathing has stopped
prior to scalding, By allowing a bird to be found dead
underneath the cage belts, means it was allowed to die ina
method other than humane slaughter. Itis also poor
practice to allow live birds to be potentially smothered to
death by DOAS as in the case that occurred in the live
hang room. This NR is linked to the MOI | documented on
2/10/2020 for birds found dead underneath the dumper. In
response to that MO! the establishment created an hourly
check sheet to be completed by a production team
member. Once implemented this check will be completed
hourly each day for each production shift.



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P165H OK Foods, tne. DAF5207095 15SEP2020 | 04C05 | PoultryGood | Finalized | At approximately 0651 on Tuesday, September 15, 2020,
415G Commercial while performing a good commercial practice check in the
Practices live hang room | observed the following. An employee

hanging live chickens on line 2 was repeatedly using
excessive force to hang the birds in the metal shackles.
The force being applied was such that | was easily able to
hear the metal shackles banging very loudly against the
metal guide bar as the employee used a rapid downward
motion slamming the birds legs into the leg loops of the
shackles. After observing this same forceful technique
used several times, | immediately proceeded to the cage
dumper and motioned for the operator to cease dumping
cages of live birds onto the transfer conveyor. US reject
tag B-45010660 was attached to the dumper. Mrs.
fata}. Back Dock Supervisor was notified af
the improper live bird handling technique. Mrs. Martinez
‘notified me that the live hang employee responsible was
removed from the live hang area and sent to the human
resource department. Shortly thereafter, | met with Mr.
Danny Houston, Plant Manager ania)
Key and explained my
observations. Mr, Houston proposed to make changes to
the establishment's animal welfare program. At
approximately 0700 | released regulatory control of the
cage dumper. Later in the morning, | toured the live hang
room again and observed all employees using the
appropriate hanging techniques. Later in the shift
(approximately 1100) | met with Mr. Houston and Mrs.
further discuss the
situation. Mr. Houston plans to begin having a supervisor
rather than a lead person monitor the
establishment's animal welfare program.

25


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

M1015+P101
5

Poultry Holdings, LLC

ARE4606082
919G

19AUG2020

Open

On August 18, 2020, at approximately 1130 hours, while
performing a Good Commercial Practice task in the
chicken Live Room, | observed a significant number of
chickens smothered to death due to the excessive amount
of the birds being dumped onto the belt. Two of the three
slaughter lines were not running at the time and the Rabbi's
and plant employees were not able to kill and clear the belt
fast enough before more birds were dumped onto the belt.
At one section of the belt, the chickens were piled on top

of each other at least two feet deep. A large majority of

the birds in that section of the belt had to be placed on the
DOA belt. | counted at least 100 birds in the space of ten
minutes being placed onto the DOA belt which all appeared
to have been smothered to death. There were many more
chickens that | did not individually count but observed as
employees cleared the belt. Consequently, the DOA
chute and bin were also completely clogged up with birds
as employees worked to get the excessive amount of dead
birds into barrels and then into the DOA dumpster. |
Immediately informed the live room supervisor that no more
birds were to be dumped onto the belt until the belt w;
cleared. [fo)(6) at —anckovia}
pve) Mv) Tdiscussed this incident with Plant

Kons)

oy) Tb) Jand HACCP Coordinator, Ive) Minar |
during the weekly meeting on August 19, 2020. This
incident was also documented in Noncompliance Record
Number ARE5S703085119N. They were reminded that the
PPIA and Agency regulations require that live poultry be
handled in a manner that is consistent with good
commercial practices. We recommend that plant
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. Plant Management was
reminded that this MOI will be forwarded to the District
Veterinarian Medical Specialist (DVMS) in case additional
follow-up is recommended. Respectfully, ((6)(6)

Plant 1015, Poultry Holdings LLC.

M13456+P13
456+V 13456,

Tyson Foods, Inc.

BQB3408073
331G

31JUL2020

Finalized

| William Watkins on 07-31-20 at 7:30 am while conducting
my GCP walk of establishment observed in the live hang
area overcrowding of birds on belt. The overcrowding
caused birds to be pushed on top of each other and over
the sides of the conveyor line onto the floor. | observed
‘one bird on ground and 3 more pushed over the sides as |
walked into live hang area. | notified Norma Armstrong the
supervisor who turned the line speed down to correct the
overcrowding of birds on the line, This was an issue that.
was covered with establishment during the weekly meeting
buts still present,

1


2

Table: Noncompliance Reports in Response to FOIA2021-108 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
P5787 Pilgrim's Pride | {47C10186-2ADS | DEB3114 08/07/2020 | 04C05 | Poultry Good 381.65(b) NR #145 At approximately 12:45pm on August 7, 2020, CLOSED
Corporation -42EE-9BD4-3FE | 081607N Commercial (oer [were
4800D91B0} 4 Practices performing a Poullty Good Commercial Practices (GCP)

verification task by observing poultry prior to entering the
scalding tank. Two live, breathing birds were observed
entering the scalding tank on line 1. The birds were not
stunned because their eyes were blinking, they were
flapping their wings, vocalizing, and they were all
breathing. Neither of their necks had evidence of being
cut. Three live, breathing birds were observed entering the
scalding tank on line 2. The birds were not stunned
because their eyes were blinking, they were flapping their
wings, some were vocalizing, and they were all breathing.
Their necks had no evidence of being cut. [a] Henderson
Notified Evisceration Superintendent Robert [b¥61 that
birds were breathing when they entered the scalding
tanks. Atapproximately 12:55pm, she removed four live,

breathing birds from line 2 prior to mene the
(8)

scalding tank and showed them to()
eve) Aa] andfawar iis is noncompliance
with 9 CFR 381.65(b). Since birds were repeatedly being

put into the scalding tank while they were still breathing, the
birds are dying otherwise than by slaughter, they are
adulterated, and the establishment's system is out of
control. A regulatory control action was not taken per 9
CFR 500.2(a)(2) & (3). (ONE)

(er (B) and Marly Guillory, Plant Manager,
were notified by lis] Henderson at approximately 1:25pm
thata Noncompliance Record (NR) would be issued.



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P44826 Case Farms Processing, Inc JOD1215091 09SEP2020 Finalized SeRY providing copy of this MO! to Pavey]
809G 1 On September
oth. 2020, 1G) vas performing Poultry Good

Commercial Practices task verification at approximately
315pm. SPHV observed normal operations in live hang,
cutting and bleeding, and scalder areas. While in scalder
area, SPHV suddenly observed only back feet (‘paws’) in
the shackles, with no live birds. SPHV checked live hang
department; birds were not being hung as shackles were
Still full of ‘paws!. SPHV went to scalder area where the
‘paw remover is and observed maintenance working on
that malfunctioning equipment. SPHV returned to USDA
office to address two separate, unrelated issues that
inspectors had brought to his attention. While in USDA
office, SPHY was approached byfaye1——_Jpproximately
25-30 minutes later. CS! informed him that salvage
department had a large number of red, cadaver birds that
employees were condemning/disposing of. CS! had
employees hold the carcasses until SPHV could examine.
Upon presentation to salvage department, SPHV observed
a large number (approximately 30) bright red poultry
carcasses on the salvage floor. Heads were intact; some
carcasses had no visible cuts to neck, other carcasses
had cuts that were improperly placed (ie at base of

skull) - evidence of improper bleeding. SPHV instructed
CSI to release carcasses to establishment control. SPHV

sought out establishment management. SPHV met with Mr
inthe FSIS CSI
offices to discuss these events, @ approximately 410pm,
informed SPHV that malfunction
— with ‘paw remover’, line was slowed to 200bpm

and issues with paw remover and blade were corrected.
Line speed retumed to normal function. After meeting with
(toy) has approached by QA
(one) Hiscussed findings with Mr
fal well, informed SPHV that
protocolin future will be to stop the line and clear/resolve
the problem before resuming slaughter. SPHV verified that

slaughter process was back in control with no further
recurrence.

48


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M6137+P613 | Foster Farms BXL4815083 28AUG2020 Finalized | This MOlis intended to document the discussion | had with
7 128G 1 FI | TTC Er
about the Poultry Good Commercial

Practices (GCP) incident that occurred on Friday, August
28th, 2020. While |, foN6) _[6)] was performing a
GCP task in Plant #1, | observed a live bird enter the
scalder on Line #2 kill line at approximately 0744 hours. |
observed the bird had no visible cut on the neck, the eyes
were blinking and the head was lifted up while moving
Sound: bee ie a the
picking room and | informed him of my observations. |
proceeded to the area of the Line #2 pre-sorter and at
approximately 0750 hours, | observed a bright red bird with
no visible cut on the neck, on the Line #2 kill ine.
[aja in the area and | pointed out the
cadaver that was approaching the Line #2 pre-sorter.
(eX) instructed the pre-sorter to condemn the
Cadaver and twas documented on the counter. | informed
[x1 Jof my observation of seeing the bird enter
the scalder with no visible neck cut and while still alive.
While | was on my way to the Plant 1 USDA office,
‘Supervisor avr [(6)(6)] inquired as to what had
happened. | informed Supervisor [(6(6)] of my
observations. | remindedPaWaY nd that
the PPIA and Agency Regulations do require that live
poultry are to be handled in a manner that prevents
needless injury and suffering and in a manner that is
consistent with good commercial practices. |
recommended 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. |
notified{®X6) __[aawey 1 [fby(6)] 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, [6)6][ox6) Mom

12


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M579+P579+ | Jennie-O Turkey Store UjO5808082 20AUG2020 | 04C05 | PoultryGood | Finalized | At approximately 0815, while performing eee Gord
v579 620G Commercial Commercial Practices Task in live hang |{O)(6)
Practices [)) | Lext6)] and [OYE [bvia\ I observed 4 heavy

tom carcasses hanging on the line with severe injuries,
including one carcass with the internal viscera exposed
due to a large wound on the back. The other carcasses
had large wounds on the backs of the carcasses with some
having the entire back affected. These wounds appeared
fresh as they were moist and had a large amount of bright
red blood on the surrounding feathers. | notified
Poros ae and showed him te

affected carcasses. He said that there was a clog in the

conveyor system, and they stopped as soon as the
iced the clog. | called (OG)

jand notified him of my findings and that | would
document these findings and discussions in a GCP MOI.
While observing the line at 0845 with PHV student intern
Ms. [DXG)] we observed approximately every fifth
carcass hanging on the line in live hang had injuries of
varying severity primarily affecting the backs and breasts
ofthe birds. We also observed employees taking
carcasses off the conveyor after the CO2 tunnel and
putting several injured carcasses in a large metal combo
Which is primarily used for DOAs. This large metal combo
was completely full and contained primarily turkey
carcasses with wounds that were moist and had a large
amaunt of blood on the surrounding feathers consistent
with recent injury, [Ever pbserved this combo and
stated that there was a motor out affecting the conveyor
belt and it was getting backed up. He stated that this motor
was fixed and should be working for the rest of the shift.
While walking into the establishment after this discussion,
we also observed approximately 15 injured turkey
carcasses on the floor directly behind the employees that
take the carcasses off the conveyors after they go through
the C02 tunnel. At 1000, while | and Ms. were
observing live hang no injuries were observed. Clogs of
birds in the conveyor system has been a rare but ongoing
issue at P579 as documented in GCP MO!s on 3/3/2020
and 5/30/2020.

nu


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P5787 Pilgrim's Pride Corporation DEB5401091 04SEP2020 | 04C05 | PoultryGood | Finalized | Est. P-5787 at Pilgrim's Pride, 0200 hours, September 4,
404G Commercial 2020 . In attendance are the following: [al
Practices [eyey Jand

one young chicken cadaver at USDA station 3, Line 2
while performing post mortem inspection. The head and

neck are intact with hematoma, with blackish and reddish
discoloration. The carcass exhibits reddish discoloration.

[yey Jand

[exey kre notified
accordingly. | reminded [by(oy

[y(G)___ Jat the PPIA and Agency regulations require that
ive 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 Manager
Powell to review Federal Register Notice Vol. 70, No. 187,
published September 2005 [Docket No. 04-037N] for FSIS
recommendations conceming treatment of live poultry
before slaughter. {also told him that an MO! will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended. Hopefully, this MOI serves fo bring to the
establishment's attention that live poultry must be treated

in a manner consistent with good commercial practices.
Respectfully, a Kbve) hs

P-5787: Pilgrim's Pride at Natchitoches, Texas.

61


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P40183

Sanderson Farms, Inc.

PEH1417072
829G

29JUL2020

04C05

Poultry Good
Commercial
Practices

Finalized

P40345

Misty Lea Farm

BFY5610074
221G

21JUL2020

04C05

Poultry Good
Commercial
Practices

Finalized

On July 29, 2020 at approximately 1536 hours while
onductina a Good Commercial Practice task along with
eee i observed a id erter he seater
alive on Kill Line #1. | did not observe any lacerations to
the bird's cervical region when entering the scalder. The
bird was alert and active. [oY6)
exe) was notified of our observation but was
ot able to signal to the backup cutter fo stop the line in
time prior to it being completely submerged in water.
After the line was stopped by an establishment employee,
Bye) ‘as able to pull the bird out of the scalder.
| -onfirmed that the bird did not have any
Tacerations on its neck. The live bird was then taken to a
hang-back rack located near the back-up cutter. The bird
was observed thrashing on the rack and appeared to be
gasping for air. The bird was left there hanging. | asked
the Picking-Room Lead if they had any plans to dispatch
the bird after entering the scalder. The Picking- Room
Lead then had the back-up lacerate the neck of the bird.
PPIA and Agency regulations require that live poultry be
handled ina manner that is consistent with Good
Commercial Practices (GCP), and that they do not die
from causes other than slaughter. A copy of this MO!
may be forwarded to the Raleigh District Office and the
District Veterinary Medical Specialist (VMS) in the event
that an additional follow-up is recommended.

On July 20th, 2020 the establishment held over
approximately 340 chickens and 20 ducks in crates to be
slaughtered on July 21st, 2020. These chickens and ducks
were confined to the crates and were not provided access
to water or food for 16+ 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.

44


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P9197 Perdue Foods, LLC. UAB1610075 13JUL2020 | 04C05 | PoultryGood | Finalized | On 7/13/20 at approximately 0910 hours, the inspector on
713G Commercial Line #1 Stand #2, presented me with a cadaver bird, The
Practices bird had its head and neck attached which was bright red

to purple in color. The back of the neck of the bird had a
small, approximately % inch, tear in the skin, but none of
the underlying vessels were severed, indicating that the
bird was not bleed out thoroughly in accordance with 9

CER 381.65(b). | informed
foval (V6) al Bd)

[by(6) [Team Lead, about the bird that had been presented
to me. | showed [Gr and mr.

the bird. After informing the plant about the cadaver bird |
went to where the birds are slaughtered on Line #1. | was
only able to observe the birds exiting the scalder because
the establishment had stopped hanging birds for the lunch
break. | observed this area for approximately 5 minutes
total. During that time, | did not see any birds go past that
were not properly slaughtered. | also reminded Mr. Salley,
Mr. me | and Mr, Zo\(6] 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. | nolified them that this MO! will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended.

85


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P21234 Perdue Foods LLC XG14711093 28SEP2020 | 04C05 | PoultryGood | Finalized | Perdue Farms P-21234 9/28/2020 Time: 12:49 pm
028G Commercial On September 28, 2020, at approximately 12:36pm, | [ia]
Practices | \6y [LHXS) while performing a Good Commercial

Practices Verification task outside under the holding shed,
observed the follwing. There were 2 cages that did not
have barriers present to keep the birds from escaping out.
One cage on trailer 95489 had a section that was missing
doors on the battom row of the cage and most of the birds
had escaped from that section. Another cage on trailer
95478 had a section that was missing bars on the top row
of the cage, and there was a bird hanging out on the edge
ofthat section, There have been several other accasions
that | have observed the cages were not in good repair. On
September 26, 2020, | observed doors missing from a
section of a cage on trailer 95483. The birds were
escaping, On this same trailer, | observed large holes on
the sides of the cages with no bars present, as well as
holes in the flooring with birds falling through to other rows
of the cage. The same was seen on 9/12/2020, 8/28/2020,
8/26/2020, 8/10/2020, 8/7/2020, 7/23/2020, and 7/9/2020
with other cages on different trailers. Each time, | have
communicated my observations to Abo)

(ey J have also emailed (2X6)

foe) fe) GG) ] Jbout issues observed as
well when they have come up. There have also been
some instances where | have found several live birds on
the ground under the holding shed after they have escaped
from the cages. The live birds are seen sitting and roaming
around and underneath the trailers. The holding shed is a
high traffic area where trailers are constantly being pulled
in and out. This puts the birds at risk of being runover. |
have communicated this to plant management as well. |
informed Fray____Ithat | would be documenting my
findings in an MOl. This MO! will be forwarded to front line
supervisor [i] the District Office, and the
District Veterinary Medical Specialist in case additional

follow-up is recommended. Respectfully,
fee] sPrviie

32


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P45911+V45,
oni

Meridian Meat Packers

EWQ110909
54296

29SEP2020

04C05

Poultry Good
Commercial
Practices

Finalized

P4602A

NEW MARKET POULTRY, LLC

YCG3612082
818G

18AUG2020

04C05

Poultry Good
Commercial
Practices

Finalized

Atapproximately 0740 [ia] Himmel observed the

handling and bleeding process of chickens at P45911
Meridian Meat Packers. The operator placed a live
chicken in a metal cone and exsanguinated the bird with a
knife. The bird was allowed to bleed and later placed in the
scald tank, along with other exsanguinated chickens, and
the rotating paddle was activated. Atapproximately

one quarter rotation, the operator identified that one bird
was not unconscious. The bird was submerged in the
scald tank water and had flailed one wing. The operator
immediately stopped the unit and pulled the bird out of the
scald tank water. The bird was replaced in the metal
cone. The bird was breathing, blinking, and moving. The
operator allowed sufficient time for the bird to stop
breathing before it was retumed to the scald tank, FSIS
observations of the bleeding process of chickens before
and after this incident did not find other instances of
conscious birds entering the scald tank water.

On 8/18/2020 at approximately 1258 hours, Supervisory
Public Health Veterarian (SPH) Iiiiaten pitas
in the live hanging room verifying Good Commercial
Practices and conducting ante-mortem inspection on the
chickens of the second lot. While inspecting the contents
of the yellow condemned/inedible barrels used to store and
transport birds that were Dead on Arrival,

discovered a live chicken inside the barrel neares

shackle line. This chicken was in an upright roosting
posture with its head held up and demonstrated an overall
bright, alert, and responsive demeanor. It moved by refiex
when another dead bird was thrown into the DOA barrel
next to it. [do] [faBlacquired the attention of the area
supervisor and showed him the live chicken mixed in with
the DOAs, Because the chicken was in nominal condition,
itwas permitted to be hung ina vacant shackle, The barrel
of the kind the live chicken was discovered in are used to
store and transport DOA carcasses for rendering or
disposal. Had the SPHV not been presentto intervene, it
is reasonable to conclude a strong likelihood that the live
and fit chicken would have died by some means other that
stipulated in the Code of Federal Regulations [9 CFR
381.65(b)]. This would, by definition, have produced a
cadaver. Cadaver production is a metric by which control
of slaughter and dressing processes is assessed. A
pattem of assessed slippage of process control evinced by
Fepeat improper disposal of live chickens in DOA barrels
may be documented with a noncompliance record.

49


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P21234 Perdue Foods LLC XG10911070 44JUL2020 | 04C05 | Poultry Good | Open Perdue Farms P-21234 7/14/2020 Time: 12:99.0m_On
614G Commercial July 14, 2020, at approximately 11:25am, | [bl ((6(6)
Practices while performing a Good Commerci

Verification task in the picking room, observed the
following. While | was observing line 2, at approximately 48
seconds of timing the line, | began to notice birds moving
towards the scalder that were displaying signs of
consciousness. | observed 1 bird blinking, and | observed
another still breathing (| saw its belly flap moving up and
down). | noticed a few other birds approximately 3 were
flapping their wings and swinging their bodies back and
forth, The head puller was missing some of the birds,
however, | did notice neck cuts on all of the birds. |
observed t

ha 6)

observed the line with me for about 3 more minules and we
noticed another bite! go by that was still breathing and
twitching, pulled the bird off of the line. Ithad.a
neck cut on, but did not bleed out properly. Mike Dale
then went to the area of the back up neck cutters to do
some more investigation, while | stayed behind and
Continued to observe the birds going by on line 2. As | was
standing there, | observed a few more conscious birds
heading into the scalder. | then went to go find Mike Dale
to see how they were planning to address the issue. |
informed{by(6)_—_} 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. A
similar incident occurred on June 18, 2020,
MOI # XGI1408063318G. The preventative measure was
either not implemented or not effective. This MO! will be
forwarded to my frontline supervisor[OV@) __ [by] the
District Office, and the District Veterinary Medical

Specialist in case additional follow-up is recommended.
Respectiully, Malfoy.

31


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P6510

Peco Foods, Inc

WED201009
0715G

15SEP2020

04C05

Poultry Good
Commercial
Practices

Finalized

September 15,2020 Mr. Ronnie Tolbert Peco Farms,
Inc., Bay Springs, MS. Plant Manager 95 Commerce
Bay Springs, MS 39422 Mr. Tolbert, At approximately
0946 hours, while performing the Good Commercial
Practices verification task at P6510, Peco Foods, Bay
Springs, MS, the following less than GCP incident was
observed. One (1) live young chicken from an approximate
500 bird random sample containing an uplifted head,
pupillary reflexes, and no visible cut to the neck entered
the scald tank. ay@)

BNO) as -
approximately 1005hf{b16) entered the USDA office

and verbally informed Inspection Personnel pe
beran! cso srpinenced ceiiavee need
in the Kill Room, adjustments had been made to the kill
machine, and the responsible employee would receive
further training. | informed{(b)(6) that a GCP
Memorandum of information would be issued after review

by AIDS) Jackson District Office.
Respectfully submitted, [5\(6)

Inspector Food Safety and Inspection Service, USDA’
713 S. Pear Orchard Rd. Ridgeland, MS 39157. cc:

(al pe =
BO)

P6616+V661
6

Peco Foods, Inc.

IRESS190826
04G

04AUG2020

04C05

Poultry Good
Commercial
Practices

Finalized

At approximately 13:45 | was notified that a truck and
trailer had turned over on the premises of P-6616, Peco
Foods, Sebastopol, MS. | immediately went to investigate
and observed a truck with its front wheels off the ground
connected at 90 degrees to a trailer lying on its side on the
blacktop between the first live shed and the smoking area.
The cages on the trailer were full of live chickens bunched
up in the end of the cages which were on their side.
Maintenance personne! were working to free the cages
from the trailer in order to remove the chickens as quickly
as possible. The straps holding the cages to the trailer
were cut and personnel began to remove chickens from
the cages. [RVAT 1
xe Frere all
present supervising the actions which were complete at
about 15:00. {twas reported that 3040 chickens were on
the trailer and 2074 DOAs were removed from the cages
from the overturned trailer. Despite the fact that
establishment personnel immediately reacted to this
accident and attempted to remove birds as quick as
possible the accident lead to harm and death of chickens
‘on the regulated premises.

68


Table: MOlIs in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
M45599+P45 | Lake Haven Custom Meat Processing, LLC | DRZ1010091 09SEP2020 Open FSIS IPP discussed good commercial practices issues
599+V45599 809G with the establishment owners on 08/27/20. At

approximately 0745 hours on 08/27/20, while performing a
verification of good commercial practices, FSIS IPP was
informed by one of the establishment employees that there
were numerous dead on arrival (DOA) young chickens one
producer brought in that morning from a batch of
approximately 350 chickens. The chickens were packed
very tightly within plastic crates that were approximately 3 ft
long by 12 inches high. The chickens had limited space to
move around within the crates. When the establishment
observed the numerous deceased birds inside the crates,
they began to open each of the crates to improve
ventilation and determine the total number of DOAs. After
counting and verifying for all DOAs within the producer's
crates, the establishment counted a total of 75 DOAs from
a group of approximately 350 chickens. FSIS IPP was
informed by the establishment owner, Alan Hjelmberg, the
producer told the establishment owners, they had ordered
more crates but they had not arrived on time and so they
loaded the all chickens into the crates they had available. It
was not clear per the information FSIS IPP was able to
gather if the chickens were loaded into the crates the
previous night or the same moming. The producer had to
drive approximately two hours from their residence with the
chickens that moming. By the time the chickens arrived at
the establishment, there were many birds already
deceased in some of the crates where they were packed
with many birds. Given this information, tight spacing
between the birds, poor ventilation and higher ambient
temperatures, could be attributed to the higher numbers of
DOAs from the birds overheating. FSIS IPP informed the
establishment owners that they should have a conversation
with the producer about proper methods of loading the
trailer with poultry to ensure they have enough space to
move around and provide proper ventilation to avoid heat
stress in warm weather. FSIS understands this
establishment typically works with mainly small producers
but reminded the establishment owners that all producers
they work with should be informed of the good commercial
practice requirements for poultry. Poultry are to be

handled in a manner that prevents needless injury and
suffering. Employing humane methods of handling and
slaughtering that are consistent with good commercial
practices in poultry increases the likelihood of producing
unadulterated product.



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P1317+V131
7

Wayne Farms LLC

QUI5117090
608G

08SEP2020

04C05

Poultry Good
Commercial
Practices

Finalized

Dear Mr. Elrod, At approximately 17:30 hours, on
September 08, 2020, while performing the Review and
Observation component of the PHIS task, “Poultry Good
Commercial Practices,” |, [i] pe tserves
one live bird covered by and comingled with dead birds in
pile in the outside DOA barrel. During the meeting, with
the second shiftmanager (B)_———__—ind the Live
USDA/FSIS
office at approximately 17:35 hours | informed them that a
GCP MO! documentation of our meeting and discussion of
the observed deficiency would be forthcoming. [hb] Bosko

K(o)(6)

P1362

Tyson Foods, lnc.

LPC3716072
508G

08JUL2020

Finalized

P-1362 had a trailer arrive at Noel, MO on Tuesday, July
7th, 2020 with 5,905 birds. At8:15 pm while walking
through the yard area in front of the offal building |
observed that trailer #091077 had a higher than usual
number of dead birds in the cages. The birds on that
trailer appeared to be loaded a litte tighter than normal in
the cages, there seemed to be less of the cage floor visible
around the birds than usual. The live birds had
membranes that were paler looking than normal and the
birds appeared to be st'essed given their panting
behavior. | observed that the majority of cages had
deceased birds in them. The birds did not display signs of
respiratory illness —no sneezing, swollen eyes, etc. There
were 2 empty cages on back section of this traller that
were in good condition, but not used. | spoke with the

(b)(6)

(ewe) about the situation. When discussing and
‘observing the incident, | found that this trailer had just been,
received by the establishment and they took immediate
action to move trailer #091077 directly to the unloading
area when the condition of the birds was noticed. |
observed that the Live Hang department was quick to
remove the DOA's from the transfer belts, they insured that
no live birds were in the pile of carcasses, and no dead
birds Were hung on the line to be processed. When the
trailer was finally dumped, Line 1 was turned off for a short
time so that the Live Hang personnel could assist in the
disposal and clean up of the DOAs. There were|

at final count pe Jo] Ts is a Goo
Commercial Practices concer as Trany birds died other
than by slaughter.

22


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P9197 Perdue Foods, LLC. UAB1121084 OSAUG2020 Finalized | On 8/05/20 at approximately 1444 hours | was called to
405G Line 3, station 1, for an uncut cadaver bird. The bird's

head was stil attached, and both head and neck were dark
red in color and engorged with blood: the neck was
unusually short. The bird had a skin tear on the top of the
skull, but there was no indication of a cut mark on the front
or side of the neck, rendering the bird incapable of
bleeding out in accordance with 9 CFR 381.65(b). |
showed the bird toffaivey spent some time
observing the line afterward, but | saw no other birds with
identifiably uncut or discolored necks while | was
watching. Regulations require that birds shall have died
by bleeding out before entering the scalder, which could
not happen in this case. Itis a failure of Good Commercial
Practice to allow birds to enter the scalder without being
bled out, both because such birds are considered
adulterated, and because of the possibility of such birds
drowning in the scaler, which is inhumane. The
establishment has a zero tolerance policy for live birds
entering the scalder. The establishment also has a plan in
place for handling birds from the time they enter the
premises. The last MO! written regarding deviation from
Good Commercial Practices was received by the plant on
7/13/20, citing that the establishment failed to slaughter
poultry in accordance with Good Commercial Practices,



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

commercial practices. Respectfully, [af>\©)
(b)(6) SPHY at P-51 a

Farms at Palestine, Texas.

PS1179+V51
179

Sanderson Farms, inc.

RQE2209081
814G

14AUG2020

04c05

Poultry Good
Commercial
Practices

Finalized

At approximately 0502 on August 14, 2020, while
performing the Good Commercial Practicing task, |

ek observed the person that dumps the live
chickens onto a conveyer belt, intentionally, spray a
chicken out of the cage dumper chute with a high pressure
hose, | notified Evisceration Supervisor Jon Lucas of the
inhumane handling and the documentation of a
Memorandum of Interview.

P522

Sanderson Farms, Inc. (Processing Div)

1KB50120946
16G

16SEP2020

Finalized

At approximately 1233, on 09/16/2020, while doing a GCP
task, | observed one (1) live chicken enter the Scalder
from the inside line. It was lifting its head and had no
observed cuts to the neck nor observed bleeding. | did not
observe any additional birds enter the Scalder. | informed
eee las
of the observation and of the forthcoming GCP MOI,
documenting this incident.

59


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P9197 Perdue Foods, LLC. UAB5706073 07JUL2020 | 04C05 | PoultryGood | Finalized | On 6/30/20, the inspector on Line #1 Stand #2. presented
807G Commercial me with a cadaver bird. The bird had its head and neck
Practices attached which was bright red fo purple in color. The neck

of the bird had a small break in the skin on the left side of
the neck, approximately 1 inch in length, but none of the
underlying vessels were cut indicating that the bird was not
bleed out thoroughly in accordance with 9 CFR 381.65(b).

| informed b}6;

and [bveif(b)(6) about the bird that had
been presented to me. | showed|(b)(6) }he bird.
After informing the plant about the cadaver bird | 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 20 minutes total, During that
time, | observed 1 bird that was not cut enter the scalder.
After the uncut bird exited the scalder and went through the
pickers [(6)(6)__] was able to safely remove the bird
the bird from the line. The bird had its head and neck
attached which was bright red to purple in color. The neck
of the bird had a small break in the skin,

approximately % inch below the beak on the right side of
the neck. The tear was approximately % inch in length and
none of the underlying vessels were cut indicating that the
bird was not bleed out thoroughly in accordance with 9
CFR 381.65(b). After observing the scalder area |
observed the area wear where the chickens are dumped
onto the live hang conveyor. During my observation | saw
that there was a live bird that had its broken wing stuck in a
piece of fabric at the top of the dumper slide. Every time
that the plant employee used the dumper the bird would be
left dangling in the air held by its broken wing. |
immediately informed the establishment employee
controlling the dumper about the bird. The employee
dumped one mare load of birds before he stopped the
machine and removed the injured bird from the cloth. |
informed [p of this incident. | also reminded [ll
nd liail[(o)(6)__] that the PPIA and Agency
feguralons 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 |
provided a copy of to ail and | recommended
that they review it for FSIS recommendations conceming
treatment of live poultry before slaughter. | notified them
that this MO} will be forwarded to the District Office and the
District Veterinary Medical Specialist (DVMS) in case
additional follow-up is recommended.

83


x

Table: Noncompliance Reports in Response to FOIA2021-108 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
M6137+P613 | Foster Farms {7C9DFF24-DC5 | BXL1707 08/14/2020 | 04C05 | Poultry Good 381.65(b) On 08/15/2020 at approximately 0207 hours in Plant 1, |, OPEN
7 C-4E35-B211-56 | 085817N Commercial SPHV Ib] Mehta was observing the carcasses prior to the
E34D0FD533) | 41 Practices pre-sorters on Line 1 and 2 when | observed a cadaver

emerging from the picker room on Line 1. As | went
around to Line 1 to examine the carcass, | observed that
the employee on the pre-sorter station for Line 1 already
had 5 cadavers on the side rack. Within another minute, |
observed another cadaver coming towards the Line 1
pre-sorter station. | examined all 7 carcasses, all of which
displayed signs of a classical cadaver. The carcasses
were bright red in color with dark red/ swollen heads
and ne signs ofa cut {BYE as
present and was being informed of the incident by the
employee on the Line 1 pre-sorter station. [yey]
[6)_ radioed for fayAT ee Jwho
arrived at the Line 1 pre-sorter station, observed the
findings, and then left to take corrective actions. Line 1
finished at 0215 hours for lunch and no more cadavers
were observed at this time. Superintendent Lellhame
informed me that the back-up cutter employees were
switching equipment as one of them needed to use the
restroom. During this time, the live birds bypassed the
employees as no one was tending to the line. He also
informed me that as part of their corrective actions he
would be going with maintenance as soon as the line
started back up to check that the auto-kill machinery was
functioning correctly. At approximately 0221 hours. |
notified that | would be
documenting my findings in a Memorandum of Interview
(MO)) that seven cadavers were observed with no signs of
a cut after consulting with the FLS and DVMS for their
recommendations. | asked G===—— to investigate the
establishment records for night shift. [(6)(@)

observed that at 2332 hours, the QC represen
documented a check for “killing" on Line 1. She observed
15/500 birds were missed by the auto-kill machinery. The
check failed and as a result the QC representative notified
production. It was not documented what corrective actions
were taken at that time.At approximately 0325 hours,
{a notified me the machinery itself
was functioning adequately; however, with the line not
being full, it allows for a fluctuation in birds feeding into the
auto-kill machinery. He also informed me that he put more
experienced employees at the head puller stations to
ensure any birds that are missed do not enter the scalder
alive. Regarding the back-up cutter employee, going
forward, the supervisor needed to be informed if the
employee needed to leave their position.At approximately
0636 hours, while | was on my way to the Plant 1 USDA
Office, | observed a cadaver on the side rack for the Line

1 pre-sorter station. | observed an employee dispose of
the cadaver in question into a condemn barrel. |
proceeded to investigate further and observed a total of two
cadavers in the condemn barrel. Both carcasses were



10

Table: Noncompliance Reports in Response to FOIA2021-108 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
P47016 The Best Dressed | {864AA661-8E3C | OFG3511 08/28/2020 | 04C05 | Poultry Good 381.65(b) On 08/28/2020, at approximately 0710 hours while CLOSED
Chicken, Inc. -4DB0-97ED-1E3 | 082231N Commercial completing a routine Good Commercial Practices
3DA480CB9) 4 Practices verification task, | observed live birds entering the scalder

with no incision or cut on their necks. | informed
De es————— my

observation. Approximately one in 10-15. birds entered the
scalder alive, conscious and alert. Sometimes they would
appear in a cluster or coupling, other times it would be one
alone. The issue of live birds entering the scalder
remained consistent for approximately 20-30 minutes until
the Evisceration Supervisor could appoint three people to
work as back up cutters while the problem with machinery
was repaired. The rehangers condemned most of them
and the sorters removed more so that few made it to the
inspection stand. During that time, the area behind the
rehang table and areas adjacent to condemn barrels were
littered with excess cadavers flowing out of the barrels;
causing unsanitary conditions. By approximately 0800
hours, the process was under control and sanitary
conditions were restored. After post lunch start up around
1240 hours, | observed the same thing and noticed that
there was no back up cutter present. Once one was, the
process came under control. In total, 19 cadavers made it
to the Inspection stand and were condemned by USDA
Food Safety Inspection Service. The establishment is not
preventing live birds from entering the scalder. On
08/27/2020, 152 cadavers were pulled off the line and
regulatory control of the line was taken twice, Corrective
actions have not prevented live birds from entering the
scalder. As of this date, four MOIs for Good Commercial
Practice have been documented and live chickens are still
entering the scald tank.PPIA and Food Safety Inspection
Service regulations require that live poultry be handled ina
manner consistent with good commercial practices which
includes dying by slaughter. Live chickens entering the
scald tank is not an acceptable method of
slaughter.Additionally, you are allowing cadavers into the
facility which creates insanitary conditions. After
consulting with the Frontline Supervisor and the District
Veterinary Medical Specialist, ithas been determined that
the Food Safety Inspection Service regulatory
requirements have not been met. The establishment is not
preventing live birds from entering the scalder.



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P6164A Foster Farms 01406150742 24JUL2020| 04C05 | PoultryGood | Finalized | On July 24, 2020, while performing a routine Good
24G Commercial Commercial Practices (GCP) inspection, | observed
Practices practices not consistent with GCP. Normally, the cage

dump operator tilts a cage module against a steel-framed
set of chutes so that the caged birds slide out of the cage
module and through a set of slick steel chutes to land in a
pit where a conveyer belt floor transports them for
hanging. After the birds are dumped, the cage module is
tilted right up, back into place and rolled away. To avoid
needless repeat trauma to live birds that are advertently
‘pinned’ in machinery, itis a good commercial practice
and establishment policy to neither 're-tilt nor ‘shake’
cages in which birds are pinned. (An exception of
‘double-dump' is allowed when a large number of birds
are safely trapped inside the cage when one or more
flip-doors does not open.) Establishment policy directs
employees to simply remove the cage away from the chute
frame and with two-hands, deposit the bird into the belt-pit.
Specific issues observed: At approximately 1253
hours, standing north of the cage dump, | observed the
cage dump operator ‘double-dump' a cage module with no
apparent extenuating reason. As the operator rolled the
next cage module into place, | walked through the live hang
room. At approximately 1256 hours, standing at a position
south of the cage dump, | observed a single bird lying
upon one of the chutes, apparently with wing/leg crushed
between the module frame and the chute frame. The
operator rolled the cage module away: however, instead of
humanely extracting the bird, he caused the next cage
module to slide into place, re-crushing the bird. | hailed
the operator and gestured for him to halt. Stepping into the
live-hang office, | found Evisceration Superintendent Fidel
and informed him of the issue. When we retumed,
the operator had rolled the cage module away. Mr.
mounted the cage operator stand and coached the
operator to correctly humanely retrieve the bird and
operate the equipment, This issue of re-traumatizing
pinned birds has accurred on repeated occasions within
the last ninety days and has been documented both in
weekly meetings (7/16/20) and a GCP MO! (7/14/20). |
informed Fewer bf the event and
Notified him that it would be documented in an MOI.

66


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P38466 Sensenig Turkey Farm LLC TWL3108070 30JUL2020| 04C05 | PoultryGood | Finalized | Est. P38466, Sensenig Turkey Farm LLC, July 28, 2020,
1306 Cainer 0600 hours. inatendance IRV) =]
Practices [J Plant Manager Manuel Reyes At
approximately 0615 hours, while observing cage unloading
outside Fray and | observed the following

good commercial practice (GCP) concern. We observed
most of the turkeys heavily panting as well as some turkeys
dead and dying from heat exhaustion. We also abserved
establishment employees removing a higher than normal
amount of dead on arrivals (DOAs) from the cages. |
explained to Plant Manager Manuel Reyes that the turkeys
were showing signs of heat exhaustion, He explained that
the turkeys were transported from Indiana on 7/27/2020. |
advised him that the over 90F, humid weather should be
taken into consideration while the turkeys were on the
official premises. These observations continued through
the remainder of the slaughter. 5.4% of the entire
slaughtered lot were DOAs. Mr. Reyes and | agreed that
the DOA percentage was higher than normal for this
establishment. | reminded Mr. Reyes 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. |
provided Mr. Reyes a copy of FSIS Directive 6110.1
Verification of Poultry Good Commercial Practices and
Federal Register Notice Vol. 70, No 187 Treatment of Live
P iew. Sincerely

39


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

Task

MOINbr Date Code | TaskName Status

MO! Agenda

and is not taken lightly and that personnel actions would be
taken for this occurrence. On July 17, 2020 at the
beginning of the second shift | went to the Plant Manager's
office intending to discuss with ffoy(6) y
observation the previous evening ToweverTwas mormned
that was on vacation. Around 1445 hours as |
was making my first observation for Good Commercial
Practices both the[by(6)

[aver came tome when | was

at the live bird hanging area to assure me that either the
supervisor or another designated individual would be on
the floor and assigned to address the operation at the DOA
carcass belt. This MOI has recorded in summary all the
pertinent matters discussed during the meetings with plant
ill be forwarded to the District

ist (DVMS) in the District Office
in case additional follow-up is recommended.
Respectiully, Est. P806,
Tyson Foods, Inc.

79


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P39 Pine Manor Inc. ULL3412073 07JUL2020.| 04C05 | PoultryGood | Finalized | On Tuesday, July 7, 2020, at approximately 0435 hours,
207G Commercial while | was performing the antemortem inspection on
Practices lot #1 at the live bird arrival/receiving area | observed

create a safety hazard. | notified [yer
BN) of my observations every time | noticed killed

excessive amount of blood on three (3) cages full of ive
chicken. After further investigation, | observed that three
(3) chicken were dead, and their body cavities were
forcibly opened, and their entrails were eaten, In addition,
some of the chicken were mutilated and their legs were
pulled off. Furthermore, pieces of the killed chicken were
eft laying around the cages. Several chicken were
attacked and killed with parts of one or more carcasses fed
upon on several occasions since 06/29/2020, and the plant
was notified of each incident. Raccoons were observed
attacking live chicken on the truck and around the area
multiple times and they are considered to be the culprits. It
seems that the raccoons return again and again to prey
upon easily accessible captive preys. These painful
attacks certainly cause unnecessary pain and suffering to
the five chicken. The FSIS would like the plant to implement
some measures to stop and limit these daily raccoons’
attacks. Raccoons are unlikely to attack humans.
However, some raccoons carry rabies, and when they get
trapped or comered they may become aggressive and
attack humans, Therefore, their presence could also

or mutilated chicken carcasses. Moreover, | reminded him
that the PPIA and Agency regulations do 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 the plant review
Federal Register Notice Vol. 70, No. 187, published
September 2005 [Docket No. 04-037NJ for FSIS
recommendations concerning treatment of live poultry
before slaughter, and providedfb)(6)

ey } 2 Copy of
this document. | notified [b6) }hat this MO!
will be forwarded to the District Office and the District
Veterinary Medical Specialist (DVMS) in case additional
follow-up is recommended.

40


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P48304 Lincoln Premium Poultry YOT0109083 25AUG2020 | 04C05 | PoultryGood | Finalized | On August 24, 2020, at approximately 1235 hours, while
025G Commercial conducting a routine Poultry Good Commercial Practices
Practices task at Lincoln Premium Poultry (Est. P48304), | observed

(by(6) of the Good Commercial Practices

a loose live young chicken under Line 3 in lairage. |
notified an establishment employee, who retrieved the
chicken and placed it back into a module. Walking further
through lairage, | observed a chicken with its wing crushed
in the latch of the tray above it. There was blood on a 1 cm
x 4 cm area of the wing, and blood dripped on the plastic
side panel. Another chicken's wing was stuck between two
trays, bent at an unnatural angle, with a small amount of
dried blood on the underside of the wing, and the chicken
could not lay down, There were two additional live chickens
in other modules with their wings stuck between the layers
of the module, Alll four birds with stuck wings were on Line
3. There was not a Supervisor in the area, so | notified

concern, showed him the chickens, and he said he would
speak to the live receiving employees to make sure they
were monitoring the modules for stuck birds when the
trailers are unloaded, The wings of the stuck chickens
were not able to be released because their location in the
modules presented an employee safety concem, At
approximately 1245 hours, there were an additional two
loose live young chickens under the de-stack machines of
Line 2 and 3 in the live hang room. After waiting for several
minutes, | did not observe any establishment employees
coming to retrieve the live chickens. 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 ina manner
that is consistent with GCPs. The establishmentis
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 injuty 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. | met with First
Processing Plant Manager Ariel Silverio at approximately
1345 hours to discuss the concems and notify him that a
GCP MO! would be documented. Mr. Silverio planned to
address the issue right away, and have the live receiving
employees more closely monitor the modules when they
are unloaded from the trailers. 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,

55


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P18860

Sing Wah Live Poultry Mkt Inc

XPD4305071
323G

23JUL2020

04C05

Poultry Good
Commercial
Practices

Finalized

met with Pe pround 10AM after
observing a yourig Chicken that had already had it's throat
cut walk out of the kill floor and into the processing room
while still bleeding out. When cutting the birds for
slaughter, the cut should be quick and deep enough to
allow for a quick and thorough bleed out in the cones that
renders the bird unconscious and dead within seconds.
The birds should not still be conscious enough to walk
around the establishment. Part of good commercial
practices is preventing prolonged suffering from the
slaughter process. Also, the birds MUST bleed outin the
cones and must not be moving and jumping out of the
buckets. It is your responsibility to ensure that all kill floor
employees are properly trained in the slaughter processes
and good commercial practices.

P192

Pilgrim's Pride Corporation

0082615081
107G

07AUG2020

04C05

Poultry Good
Commercial
Practices

Finalized

On August 7th, 2020 at approximately 15:20 while
performing the poultry good commercial processes
verification task, | observed a live bird enter the scalder on
line 1. The bird had its head up, was blinking, and looking
sible cut on the bird's neck. |

nosed AS)
notified KOE) ie Unit supervisor over live

receiving, of my findings.

28


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P51179+V51 | Sanderson Farms, Ine. RQE2118075 45JUL2020:| 04C05 | PoultryGood | Finalized | Est. P-51179 at Sanderson Farms, Palestine, Texas in
179 615G Commercial July 15, 2020 at approximately 1800 hours. In attendance
Practices are the following: lb firey)

and {bVay

At approximately 1930 hours, 14th of July 2020, |,
[(oy(6) observed the following while

performing poully GCP at live receiving dock; One cage
is put aside on the floor with one young chicken whose left
leg went through between the plastic flooring and the wire
cage wall and the feet is entangled in the wire cage. |
immediately notified the cage dumper. He continued to
dump 4 more cages, then, went down and tried for several
seconds to set free the young chicken, Unsuccessful, he
returned back dumping cages. The 2 fork lift operators
work as usual, unmindful of the suffering of the young
chicken entangled in the cage. (One of them must have
isolated the aforementioned cage.) | proceeded inspecting
2 trailers of young chicken while waiting for a supervisor.

There is no supervisor in the live hang area either. | found
by the automatic kill machine. |
immediately nothed bye) —__—__pf the young
chicken entangled in the cage. wat ]took
about a minute to set free the young chicken which appear
exhausted, whose left leg remained extended and did not
flinch at all. Iwas promptly retuned to production.
Earlier, on my way out to the live receiving dock, | met CSI
meal at the stunning area. She informed me that
nobody attended to the entangled young chicken while she
was performing ante mortem inspection for approximatel
5 frinutes af the Wve receiving dock.
said Supervisor Duffey is responsible to extricate a young
chicken entangled in the cage.
admitted that the dumper does not have a radio to call
(exe) whenever there is a young chicken
entangled in the cage. That is why, it took more than 10
minutes before the entangled young chicken is extricated
from the cage, Apparently, the aforementioned entangled
young chicken is not handled in a manner that prevented
needless injury and suffering. | reminded (OVO) |
{GGT Jat 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 Manager
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. | 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. Hopefully, this MOI
serves to bring to the establishment's attention that live
poultry must be treated in a manner consistent with good

58


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P6164A Foster Farms 01J20150901 11SEP2020 | 04C05 | PoultryGood | Finalized | While performing a routine Good Commercial Practices
1G Commercial inspection task on September 11, 2020 at P6164A Foster
Practices Farms, Ifb)(6) served practices not

consistent with GCPs. At approximately 11:20 pm | was
observing cage dumping of chickens from their metal cage
modules onto a conveyor belt that transports them fo the
hanging room. | observed two cages in a row which were
tilted and dumped once, the lowered horizontally. Both
times the employee operating the machine noticed a bird
still inside the module, and proceeded to lift the cage
vertically again and shake the module at the top of its tit. In
both cases the bird did not emerge from the cage because
it was trapped by a pinned wing or a leg, and after
lowering the module after its second dump, the machine
operator needed to retrieve the bird by hand, While | was
looking around fora supervisor, the operator raised a 3rd
cage, lowered it, noticed birds stil in the cage, lifted the
module vertically again, shook the cage, and lowered it.
This time there were two birds still pinned in the cage
which needed to be manually freed. 1st Processing
stepped outside and
| went over to him and informed him of the trend in
re-traumatizing trapped birds that | was observing. While
we were speaking, the cage operator again tilted a 4th
cage twice. No birds appeared to be trapped after this
double-dumping. Mr. immediately went over to the
machine operator and re-trained him to only dump the
cages once and proceed to manually remove any
remaining trapped birds. Mr. coached him through
dumping the next few modules of birds. | informed Mr.

that | would be issuing an MO! based on multiple
instances of mishandling pinned/rapped birds. He replied
that he would continue to shadow and personally coach the
cage dump operators. | also informedpyey
exe} the event and notified him that it would be

documented in an MOI. Similar GCP-inconsistent events
have occurred and been documented within the past 90
days, with the most recent MO! documented on 7/24/2020.

67


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M248B+P215 | Butterfield Foods Company GXN4912082 143AUG2020 | 04C05 | PoultryGood | Finalized | Est. P215, Butterfield Foods Co., August 11, 2020, 0900
213G Commercial hours. In attendance: [ia] {YG)
Practices At approximately 1200

hours on August 10](o)(6) alled to inform me that
he had observed, el birds in the barrels in the
unloading area, contacted me again at
approximately 1300 hours to inform me there was a
second trailer with many deceased birds. Upon review of
the establishment's records on August 11. trailer 120 had
4,305 dead-on-arrivals and trailer 121 had 4,155, The total
number of birds on these trailers was less than 9,000
each. The remaining seven trailers in the lot had 1,123
DOAs combined. At 0900 hours on. August 11th, | met
yh i 0 discuss trailers 120 and 121. Mr,
PRE) Informed me that the private company that drains
the shed pit had left a large hose lying across the entrance
of two spaces in the shed. When the two truck drivers saw
the hose blocking the entrance, they left the trailers outside
in the sun, The birds arrived between 1600 and 1900 hours
on Sunday and were left outside until Monday morning. Six
trailers arrived on Sunday, and all trailers should have
been in the shed. [6)(6) paid this has been
addressed in the establishment's humane handling binder.
He said they spoke with the owner of the private company
and informed them that the hose was left out. The drivers
were notified that they should pla they have.
any problems dropping off birds so ment
employee can be sentto the premises. The birds were
held on the premises for an extended period outside the
holding shed and were not protected from the warm
weather. The high temperature on Sunday was
approximately 86 degrees Fahrenheit. 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.

4


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P445 Wayne Farms, LLC FKA4216072 27JUL2020| 04C05 | PoultryGood | Finalized | Today July 27, 2020, at approximately 1657, while
027G Commercial performing a Good Commercial Practices check at the
Practices

who was in the area at the time of

[1G Jhad the bird cut by the back-up killer and allowed it

entrance to the kill hole, | observed a live bird headi
towards the entrance to the scalder. | hottiecl EEE]
the finding and we followed it down to the scalder

entrance. Immediately prior to the bird entering the

scalder, | stopped the line atapproximately 2min S5sec

into my check and showed(b)(6) Ihe bird. The bird
had its eyes open, was attempting to hold its head upright

and appeared alert and responsive, | did not observe any
evidence of cuts on or around the neck of the bird. Mr.

time to expire prior to entering the scalder before restarting
the line. Had | not stopped the line, itis reasonably likely
to. assume that the bird would have entered the scalder
breathing and died by means other than slaughter. A
similar MOI (FKA4311072117) was written on 7/17/2020
for finding a bird enter the scalder while still breathing.

47


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P419 Case Farms Processing, Inc. VDB1511081 31AUG2020 | 04C05 | PoultryGood | Finalized | Mr, Matthew Martin, Plant Manager Establishment P419
031G Commercial Case Farms of NC, Inéc Morganton, NC 28655. Mr.
Practices Martin, This MOI is being issued to document

[ElIEY Iwas advised of which employee had mishandled

mishandling of a loose bird in the Live Hang Area on
August 28,2020. At approximately 1345 hours, while
performing a Good Commercial Practice Task (GCP) in
Live Receiving, | observed an employee pick up a live bird
by the neck. The bird was in obvious distress, as
evidenced by the fact that its wings were continuously and
rapidly flapping. | attempted to get his attention but before |
could intervene, the employee shook the bird and
proceeded to transfer the bird to the hang table. As the
bird was transferred to the hang table, | saw the bird
contact the metal sheet guard along the front of the hang
table, The bird hit the metal sheet guard with enough force
to create an audible sound. | walked out of the Live
Hang Area and found [b)(6)

[x= standing at the fop the hill outside Live Hang
Area. | informed him of what | had just witnessed, and he
asked me to point out the employee to him. Once Mr.

the five bird, he immediately addressed the issue. | also
informed Mr. Matt Martin Plant Manager, to ensure that he
was apprised of the situation. Plant management is
reminded that the PPIA and Agency regulations require
that live poultry be handled in a manner that is consistent
with good commercial practices and that they not die from
causes other than slaughter. Please see the attached
Federal Register Notice Vol. 70, No. 187, published
September 2005 [Docket No. 04~037N] for FSIS
recommendations concerning treatment of live poultry
before slaughter.

4s


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P6638 Pilgrim's Pride Corporation UDG3007081 13AUG2020 | 04C05 | PoultryGood | Finalized | Atapproximately 1307 hours, | observed the following Less
1136 Commercial than Good Commercial Practice at P-6638 Pilgrim's in
Practices Enterprise, AL. | observed the hourly cage dumper

Wearing a gold hat dump a cage of live birds to be hung for
slaughter, The cage did not empty completely and 2 lives
birds were left in the bottom comer of the cage closest to
the employee. The employee then advanced the cage to
the side onto the retum belt for the forklift driver. He then
advanced the next cage to be dumped, The employee then
opened the gate and entered in front of the cage that had
just been dumped to retrieve the two live birds. The
employee then placed the birds on top (exterior) of the next
cage to be dumped and dumped it onto the conveyor belt.
The birds were placed freely on the cage with no
confinement to protect them from injury. These birds could
have been injured or trapped while standing on top of the
cage as it was being dumped. | could not find any
supervision on the area. | then looked in the Live Hang
pen and did not see anyone. | then proceeded to the
production offices and found Evisceration Supervisor
Rosalind Morris and informed her of my observation, |
then informed{b)(6)

‘Superintendent of my observations and the forthcoming
Less than Good Commercial Practices Memorandum of
Information (GCP MO)) for the less than ideal handling of
these birds. Respectfully Submitted, [fever

Key(6)

70


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1009 Wayne Farms LLC DSM1717075 02JUL2020 | 04C05 | Poultry Good | Finalized | This MO! is being documented to express a concern
202G Commercial relating to Good Commercial Practices. On July 2, 2020
Practices at 0351 hours eG) lle] foyer] was

accompanying N[o6) Janda)
Ten T whe they were performing
Cockout/Tagout in the back-dock area prior to
Pre-operational inspection. When we opened the door to
exitlive hang, we observed 2 live chickens outside the
mechanical room (MCC 5). Upon further investigation of
the back-dock area, | found another live chicken on the
ground near the dumper. (foyfMa!_Inotified alive hang
employee about the birds. Tre employee removed the
birds and they were humanely euthanized, At
ately 054 notified Dayshift Evisceration
of my findings and the
forthcoming MOI. As operations had not yet commenced
at the time of my observation, no trailers had been pulled
into the back-dock area, meaning these birds were left
over from the previous day's production. The
establishment's animal welfare program states that
designated personnel will check the area for loose birds at
the end of the shift and that no loose birds should be left in
the area at the end of the night. Leaving birds on the lot
over night can cause undue stress on them by exposing
them to the elements as well as increasing their risk of
injury. The establishment should ensure that their
designated personnel preform this check at the end of
production so that no more birds are left on the lot after
production has finished. [b)(6) stated that she would
speak with fEwat )
about making sure the lot is checked for loose
birds at the end of night shift

15


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P510 House Of Raeford Farms RHB2307085 08AUG2020 Finalized | Ms. Nicole Reynolds, Plant Manager, P-510 House of
408G Raeford Rose Hill, NC 28458 Ms.Reynolds At

approximately 0752hr while performing the Good
Commercial Practices Verification task, | observed two live
birds about to enter the scalder. The birds at the time of

my observation had normal rhythmic breathing, eyes open
and blinking with the head elevated.fpya, sid
fie ———_ as present during my
observation and he immediately removed the birds from the
line before they could enter the scalder. After the birds
were removed from the line, | observed that there were no
cuts on the necks which would not have allowed the birds
to bleed out properly[by¥61 _____} took the birds back to
live hang to show it to the backup cutter. [(6)(6)

placed the birds back onto the kill ine to a
back through the stunner and the kill blade to allow proper

OPA THOT
birds, large ic stall song throubhLdiseuseed me
finding with (oX6)

Manager, notifying him of the pending MOI and the
establishment’ failure to comply with 9 CFR 381.65 (b)
which states: Poultry must be slaughtered in accordance
with good commercial practices in a manner that will result
in thorough bleeding of the carcasses and ensure that
breathing has stopped prior to scalding. Mr. Trevino stated
that he removed the employee because her work
pertormance was poor, HEEB hac slag noted
my findings, Ms. Reynolds this MO! will be forwarded
to the District Veterinary Medical Specialist (DVMS) in
case additional follow-up is recommended. if you have
any questions or concerns regarding the above, please
contact a] Tony Stultz, IC, or
Respect,

CSI P510

57


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr Date

Task
Code

TaskName

Status

MO! Agenda

p584

Pilgrim's Pride Corporation

QLM3307080 28AUG2020
728G

Finalized

‘Subject: Humane Handling Incident On August 26, 2020
at 0810 hours, while performing a Good Commercial
Practices verification, the following observation was made:
Atlive hang belt 1, | observed two birds stuck under the
metal plate at the end of the belt on the opposite side of the
hangers. Both birds were dead. | also observed alive
bird, on the side of the belt nearest the hanger, pressed
against the metal plate with its head stuck through a hole in
the rubber/plastic divider that runs along the middle of the
belt. There were other birds pressed against (and on top
of) the bird. (DVO)

was present during the findings and he informed team
members not to place birds on the side of the belt opposite
the hangers. He instructed and motioned for the end
hanger to move the bird that was trapped at the end of the
belt. Mr. Perez and | observed the hanger push the birds
(that were on top of the trapped bird) off, pick the trapped
bird up and throw him down the belt. This occurrence is
notin keeping with Good Commercial Practices. | met with
Plant Manager Coppedge about this incident and he
informed me that the team member was suspended
pending further investigation. The Agency published a
Federal Register Notice, Docket No. 04-037N Treatment
of Live Poultry Before Slaughter. In that FR Notice,
humane handling terminology was used when describing
the live poultry being handled in a way consistent with good
commercial practices, FSIS went on to describe a
systematic approach for industry to use. The Agency
defined a “systematic approach” as one in which
establishments focus 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, The Establishment is asked to ensure that
team members are properly trained and monitored for
humane handling of birds presenting through the live hang
department. Documented by{b)(6)

63


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P1243 Perdue Foods, LLC. XLB0410083 04AUG2020 Finalized | Atapproximately 9:55 am, while performing a routine
2046 Poultry Good Commercial Practice verification, |

observed numerous (roughly 15 birds) DOA
ree the small enclosure at the DOA belt drop off.
During my observation, this area was unattended. Live
birds have been seen in this small enclosure, and due to
the number of carcasses | wanted to verify no live birds
were at the bottom of the DOA pile up. After removing 6
DOA carcasses from the pile up | observed 1 live bird
which was undemeath. After my observations
were made, an establishment employee began to properly
dispose of the DOAs into the DOA bin and place the live
birds in a cage to be dumped. | informed
[bYEI_Jof my findings. Agency regulation
require that the poultry be handled in a manner that is
consistent with Good Commercial Practice, and that they
do not die from causes other than slaughter. Ibis the
establishment's responsibility to ensure that the birds are
slaughtered in accordance with 9 CFR 381.65(b).

7


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M2130+P213 | Cooper Farms Processing HEF2003071 02JUL2020:| 04C05 | PoultryGood | Finalized | On June 29th 2020 at approximately 1:00 AM while
0 202G Commercial performing antemortem inspection on the live haul trailers
Practices

in the cooling sheds, |, observed a
loose, live turkey that was sifmg on the Ground directly
beneath a cage that was partially open. The height of the
cage was three cages up from the bottom of the trailer
(approximately 8 from the ground), and there were no
visible injuries on the bird. This type of cage door is hinged
in the middle, and the bottom half of the door was stuck in
the folded-up position. There were multiple other live
turkeys still present in the cage. | informed an
establishment supervisor of this finding, and the bird was
placed back into the trailer by live hang employees.
Previously, | have observed multiple instances of live
turkeys being able to open this type of cage door from the
inside. In each case, the turkey is on its back with its head
facing the cage door and with its feet over its head,
grasping the bars on the bottom half of the door. As the
turkey pulls with its feet in this position, it causes the cage
door to fold up and inwards at the hinge in the middle,
allowing the turkey to begin pushing itself out of the cage
While on its back. This type of cage door is only present on
the newer live haul trailers.

3


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P33900+V33
900

Foster Farms

NHHO0905081
627G

27AUG2020

04C05

Poultry Good
Commercial
Practices

Finalized

Est. P-33900, Foster Farms at Farmerville. LA in August
27,2020 at 0530 hours. In lieu of face to fac: o
e-mails are exchanged with the following: iefote)

Bye) _]USDA ffby(e)
ne
[ever At approximately 0430
hours, 27the of August 2020, |,
[b\(61 —} observed the following while performing poultry
GCP verification task: Two young chicken crushed and
killed by the chain and sprocket tuming the unloading belt
atthe unloading dock. There are 3 live young chicken
found in the housing of the same chain and sprocket
tuming the unloading belt. There is another young chicken
found on the floor underneath the unloading dock platform
with the anterior half of the body crushed. Supervisor Eric
[nxG] is notified accordingly. | reminded
and [{syai__ 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. | also
recommended to both of them to review Federal Register
Notice Vol. 70, No. 187, published September 2005
[Docket No. 04-0371] for FSIS recommendations
conceming 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 MO! will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended. Respectfully, I(0)(6) USDA
Relief SPHV at P-33900 Foster Farms, Farmerville, LA.

P34508

Kam Fung Wong

LRR5407092
504G

O04SEP2020

Finalized

Good Commercial Practices educational meeting:
[xq Iwas present in the meeting as
representative of the establishment. The topic discussed
was the Good Commercial Practices. The GCP also
include the birds handling when arrive and unload birds
from transport, During the unloading birds from transport
the birds will be not mishandled or mistreated. Transport
truck with birds should not be parked outside the plant for
prolonged periods. This exposes the birds to environmental
elements of excess heat /cold etc.. Birds should not arrive
in broken crates leading to escape of the birds in the
streets. Sidewalks and outside should be properly cleaned
to avoid any insanitary conditions. Empty transport trucks
‘or empty crates (with dried fecal material) should not be
left outside of the plant or in the alleyways. This also
creates insanitary conditions which leads to foul smell and
flies. The meeting ended without further comment.

38


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P806 Tyson Foods, Inc. OGC0815071 24JUL2020 Finalized | A meeting was held at USDA office with plant's
324G management [by By fio),

and [bar [py6)_ J |
pispase\at PB06 to address some poultry welfare
concems observed by USDA at evisceration rehang area.
At approximately 0835 hours on July 22, 2020 dayshift,
USDA observed many birds (17 total) on the rehang table
that were beet red with their heads engorged with blood.
Upon examining the birds, it was noticed that the necks did
not have slaughter cut. some other birds on the table were
noticed very small and covered with many feathers and
also reddish in color but they were headless or with the
heads but the necks had slaughter cuts. These
observations are consistent with cadaver carcasses as
birds did not have a proper slaughter cut, nor thoroughly
bled indicated that they did not die by means of slaughter.
USDA immediately sent for Eric day shift General
Production Manager of evisceration; and Stanford Hunter,
Live hang supervisor to show them these carcasses. At
that time, renova said that the carcasses should have
not been hung on the line and he would talk to the
hangers. threw these birds into the condemn
caddy. Some other carcasses were mutilated to be hung
on the line for USDA to condemn. At the meeting,
thought was that this may happened because one
of the hungers was new hired and was hanging some
DOAs online! He admitted that corrective action included
dispelling of that hunger. [ia] and [ey
stated that the supervisor in the area will monitor and
insure this does not happen in the future.
replied that he will be off (on vacation) next week and he
will further investigate after coming back from his vacation
to provide USDA with the details of corrective actions. |
discussed with Il) and [el the
requirement 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. |
recommended that management review the Federal
Register Notice Vol. 70, No. 187, published September
2005 [Docket No. 04-037N) that presents FSIS.
recommendations concerning the treatment of live poultry
before slaughter and offered to provide him a copy of this
document. In addition, | notified them that this MOL will be
forwarded to the District Office and the District Veterinary
Medical Specialist (DVMS) in case additional follow-up is
recommended. Meeting concluded. The MO! has
recorded in a summary all the pertinent matters discussed
during the meeting. Signed, [teve)
Est. P-806

80


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P165S+V165 | OK Foods, Inc. LWA291307 20JUL2020 Finalized |
s 5020G

Attending: OK Foods attendees: (OG)
USDA attendees hyper sd
to document the discussion between USDA
and OK Foods supervisory staff regarding a Good
Commercial Practices issue that occurred on 7/20/2020.
The location was the Rehang area on the Evisceration
production floor. At 1150 on 7/20/2020 while walking the
Evisceration lines due to a Cl finding, | observed two
carcasses on the Line 2 Rehang belt that appeared to be
cadavers. The first carcass still had its head on which was
heavily congested. | could not find any cuts to the head or
neck on this bird. The second carcass had a shallow cut
on the back of its very congested head which was also still
present on the carcass. The cut to the back of the head
did not appear to sever any major vessels. These birds
were not properly slaughtered prior to entering the scald
tanks where they drowned, making them cadavers. |
informed[(OX6) bfthe
issue and showed him both carcasses. He brought one of
them to the backup killers to show them they were missing
birds. | moved to just prior to the Rehang area to better
watch both lines as they entered the Evisceration
department. Within a few minutes | observed another
carcass on Line 2 that appeared to be a cadaver and had
it taken off the Picking line. This carcass also had a very
congested head which was still attached to its body. There
was a roughly ¥4" shallow cut on the back of its head which
did not appear to have severed any major vessels. This
bird was also a cadaver. This carcass was also shown to
moved to the Kill machine to observe
operations there. | saw birds being entirely missed by the
kill machine coming at an interval of about once every
15-20 seconds, though the backup killer did seem to catch
them all. | noted that many of the missed birds were
substantially smaller than the rest of the flock around them,
The kill machine also appeared to be constantly twisting the
heads of the birds as they entered the machine which was.
causing cuts to the side and back of the chickens’ necks.
I retumed to the Rehang station and saw a carcass had
been put into a condemn barrel that appeared to also be a
cadaver, The carcass had a heavily congested head that
was still attached like the previous cadavers. There was a
small, shallow cut on one side of its neck that did not
appear to lacerate any major vessels, This carcass was
shown to [(6)(IbYWE1_]| stayed in the area for several more
minutes a notobserve any more cadavers enter into
Evisceration, Mr, [M1] stated that he had slowed the
picking lines down in response to the cadaver issue until
they could get it under control. He also stated he had put
another backup killer on Line 2 to help out. A similar
instance of cadavers entering the facility was abserved
and documented on 6-23-2020. See MOM#:

26


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda

M13456+P13 | Tyson Foods, Inc. BQB5316084 43AUG2020 Finalized | At 2050hrs on August 12, 2020, while performing Good

A56+V 13456 413G Commercial Practices in the dumping area; | observed 2
loose birds sitting in between the cages on a trailer. These
birds fell from broken cage doors on the trailer. |
immediately notified GPM Jerry Lankford of my findings.
GPM Jerry Lankford notified the live hang supervisor and
the birds was moved to the dumper.

M18866+P55 | Jennie-O Turkey Store Sales, LLC WJL0512081 10AUG2020 | 04C05 | PoultryGood | Finalized | Atabout 1530 on August 7, 2020, [GHIBYGE observed

1 810G Commercial at least 8 cadavers in condemn barrels in the picking

Practices room. The birds had gone through the pickers and were

then pulled off the line by a company employee and
disposed of by the establishment. | discussed the
numerous cadavers with the department supervisor,
DG) and the assistant supervisor,

| told them this was unacceptable and needed to
be corrected, They informed me it was a new person in
the role of the back up killer. It was someone | had never
seen do that job. The supervisor said he would work with
and retrain the new back up killer employee. I dida
recheck at 1630. At that time | found 10 additional
cadavers set aside in the picking room. A company
employee pulled two carcasses off the line in front of me at
1630. | spoke to the supervisor again and the supervisor
said that employee would not be in the role of back up killer
again, At 1630 the end of the line was already coming
through the plant. The end of the line was past the auto
killer and back up killer, but birds were still in the blood
tunnel. | informed the supervisor | would document the
occurrence of numerous cadavers. Many of the birds
had no neck cut at all, some had partial cuts or a miscut to.
the neck. The carcasses had enlarged swollen heads and
necks, with heads, necks, and shoulders that were dark
red in color, consistent with cadavers.

2


3

Table: Noncompliance Reports in Response to FOIA2021-108 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
p44947 Two Brothers for | {86B97834-F5D2 | TRRS712 07/07/2020 | 04C05 | Poultry Good 381.65(b) On 07/07/2020, while performing Good Commercial CLOSED
Wholesale -4C4C-9E2C-D8_ | 071908N Commercial Practice's verification, |e) ] observed
Chicken, Inc. 8DDE73C629} | 1 Practices the following noncompliance: At 1400 hours, entering the

Scald/Pick Area and viewing the Slaughter Area from the
enty way, | observed multiple carcasses (approximately
10-15) stacked on top of the furthest from view Cone-Bleed
Table, also observed with the Cone-Bleed slots completely
full of carcasses. After noticing my observance of the
activities, slaughter-designated personnel immediately
began throwing poultry carcasses into a barrel designated
for carcass transportation from slaughter to scalding.
However, as the employee was throwing the carcasses. |
observed a single bird from the bottom of the pile flap its
wings profusely and cluck excessively in obvious distress.
Slaughter personnel were immediately instructed to halt all
slaughter activities until management notification and
process control could be properly addressed by
management. The live carcass in conversation was
identified quickly by inspection in the barrel and was
immediately properly cutand bled. [oy@) id
(ee, ]
were notified of the nonconformance immediately and
informed of the importance of the implementation and
verification of Good Commercial Practice's. Management
was also strongly encouraged by me fo monitor
establishment employees’ slaughtering practices ona more
frequent and routine basis. The establishment did provide
written corrective actions which may be found attached to
this official record.



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P4602A NEW MARKET POULTRY, LLC YCG2512091 17SEP2020 | 04C05 | PoultryGood | Finalized | On 9/17/2020 at approximately 1220 hours, [a] Gaia]
017G Commercial (Supervisory Public Health Veterinarian) while
Practices verifying the establishment's maintenance of Good

Commercial Practices assessed the efficacy of the
stunner and the automatic Kill knife in the live hang area.
SPHV calculated success rates of 95% for chickens that
had their throats cut to effectively cause exsanguination by
the automatic knife and 92% for chickens stunned. The
establishment's written Animal Welfare Policy documents
and expectation of 98% stunned and 99% killed by the
knife rather than the human "backup killer" employee. The
saltwater tank that supplies the stunner with electrolyte was
nearly empty. SPHV informed the Receiving Supervisor of
the failure rates and state of the saltwater tank.

Regulations governing poultry slaughter and processing in
section 381 of chapter 9 in the Code of Federal
Regulations do not require stunning or specify a means of
killing to achieve lethal exsanguination, however itis the
standing interpretation of FSIS that any elective component
of the slaughter process is to be assessed for functionality
as part of determining control for the process that assures
compliance with 9 CFR 381.65(b), Weekly memoranda of
interview document a recent decline in the consistency of
calculated working order for the stunner and automatic kill
knife referencing the approximate expectations of the plant
as documented in its AWP. In addition, a review of the
same day's Lot Tally Sheets at 1315 hours revealed that
each of the two attendant Food Inspectors at the two
stations of Evisceration Line 1 had condemned three (3)
chickens as cadavers [total of six (6)]. This is an atypical
valuie compared fo the amount of cadavers generally
recorded in the establishment's Animal Disposition
Records. This memorandum serves as notice that
continued failure to maintain and prevent a decline in the
control of the slaughter process, particularly when
correlating with the production of cadaver birds, may be
documented in a Noncompliance Record citing 9 CFR
381.65(b).

50


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P2686 Equity Group Georgia Division, LLC KBA2716073 45JUL2020 Finalized | Mr. Robert Dowdy, Plant
915G Manager

Equity Group Ga Division, LLC 7220
U.S. Highway 19 North Camilla, GA 31730. To: Mr.
Robert Dowdy Est. P2686, Equity Group GA Division
LLC. July 15, 2020. At approximately 1015 hours, while
performing a Good Commercial Practice Task and

observing conditions in the evisceration picking room area,
pola) served ane (1) ive young
chicken with ts eyes opened and wings flipping

approximately nine pounds in weight. | observed the bird
as it proceeded to the scald room entrance window,
approximately (2) minutes. In my observation[{by6) _]
(oye), id not observe the appropriated cut for
_—«»' ING OME TON or sides of the bird neck. | also
checked the stunner voltage for each line and the voltage
for Line One was (A)29 and (D) 32. away
took a regulatory control action and requested Line One be
stopped. | requested for the Live Hang Supervisor or other
member of Management to immediately report to the area.
The live hang lead personnel informed me that he had
contacted management. He further asked me if there was
a problem; | informed him of a live bird on-line one headed

to the scalder. The bird opened his eyes and flapped his
wings again as fayAWb\6) —_] waited for management.
Pavey Tie) | i] was notified of the

aforementioned situation and taken to the area of the
concern. feydinlbbserved the live bird open its
(exGLEwe —_Tshined my flashlight onto the bird
summoned an establishment maintenance employ:
immediately removed the bird from the shackles, the bird
was then placed back onto the conveyor belt to be hun
back into production. | proceeded to inform my SPHV,
[(o)(6)_[(pV69) and notified her of the forthcoming MOI.
[pvalbidwas informed that a MO! would be issued to the
plant. The PPIA and Agency regulations do require that
poultry be handled in a manner that is consistent with good
commercial practices, and that they do not die from
causes other than slaughter. | recommend that the plant
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. | informed Ms. [bi] that this MOI will be
forwarded to the District Office and the District Veterinary
(oye) “pkexe)_ Tawar) and
Plant Manager, Robert Dowdy 1n case additional follow-up

is recommended. Your response to this matter would be
appreciated. Respectuly, (MSL HEYG— I)

34


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P40 Pilgrim's Pride Corporation DAA4410095 11SEP2020 Finalized | September 11th, 2020 To: Jake Ponder, Plant Manager
S11G From: [da] {2}(6) Subject: Poultry

Mistreatment On Friday, September 11th, 2020 at
approximately 1038 hours, while performing the Good
Commercial Practices task and observing the live birds
being hung in the hanging pen on A” side, |, [I] Jennifer
‘Seawright, Supervisory Public Heath Veterinarian,
Inspector-in-Charge, observed the following. The sixth
establishment employee hanging birds on the line,
forcefully threw a small live bird onto the grated walkway
behind him. The bird Jie there on its back aggressively
flapping its wings with an increased respiratory rate and a
crooked neck. The seventh establishment employee
hanging birds, picked up the bird and | motioned for him to
hand me the bird. | began to take the bird to the
‘Supervisor's office and in walking from the dark live hang
room into the lit picking room, | observed the bird
attempting to raise its head and neck, its respiratory rate
decreased, and the bird died prior to me reaching the
office. | took the bird into the office and showed
Supervisor, Flowers, and informed him of my
observations and that this was unacceptable. Per Agency
regulation, poultry are required to be handled in a manner
consistent with Good Commercial Practices and not die
from causes other than slaughter. A copy of this
memorandum of interview will be forwarded to the District
Veterinary Medical Specialist in the District Office.
Sincerely, [bl invay

| fre)

43


Table: Noncompliance Reports in Response to FOIA2021-108 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
M10038+P10 | Scotts {£096849E-72D6 | RSH4710 07/06/2020 | 04C05 | Poultry Good 381.65(b) While performing the Good Commercial Practices taskon | CLOSED
038+V10038 | Hook & Cleaver | -4103-AE9C-DB3 | 072108N Commercial 07/06/2020, | found a noncompliance with 9CFR
Inc. 381A825F4} A Practices 381.65(b). At approximately 7:00am | observed around 550

chickens split between two trailers; one trailer was an
enclosed bumper pull hog trailer, and the other was a flat
bed trailer with no overhead coverage sitting directly in the
sunlight. At this time, | could notice only 3-4 chickens dead
per trailer, Plant management voiced to me that the
chickens had been in the trailers and at the plant since
3:30 am. When | first checked the chickens at 7am |
noticed the temperature was approximately 70 degrees F.
My next periodical check on the chickens was at
approximately 10am, at which time the temperature had
risen to about 80 degrees F. The flatbed trailer was the first
trailer to be unloaded, as unloading continued | noticed an
increase in the number of deceased chickens. | could
count at that time approximately 50 or more lifeless
chickens on only the flatbed trailer. Plant management had
made a comment that there is an increasing number of
chickens dying, but no action was taken at that time. At
approximately 11:15am, with the temperature being
approximately 90degrees, | did another check on the
chickens and found the flatbed trailer had been almost
completely unloaded with only about 10 live chickens left
onit. | then noticed an alarming number of deceased
chickens. | did not do an exact count at this time, |
immediately informed plant management, but the rough
estimate was around 150 dead chickens between the two
trailers. The live chickens left on the trailers were all
showing signs of heat stress, they were breathing heavily
with mouths open and raised, while others were laying on
the trailer floor barely able to breath and lift themselves.
Plant owner Bob Gibson and plant manager Darla Pertin
began to emply the trailers of the remaining live chickens
into the poultry antemortem room, which is separate and
adjacent to the poultry slaughter room. After they finished
unloading the live chickens, they began to take care of the
deceased, the approximate number of dead chickens was
200. The final number of dead chickens prior to slaughter
was 199 with a total brought of 564. These findings are not
in accordance with poultry good commercial practices and
with 9CFR 381.65(b). Plant manager Darla Perrin was
informed of the noncompliance at approximately 12:00pm
after she became available.

7


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P19688+V19 | Sanderson Farms, Ine. KJA4519084 05AUG2020 | 04C05 | PoultryGood | Finalized | Est. P-19688 at Sanderson Farms, Bryan, Texas_in
688 705G Commercial August 5, 2020 . In attendance are the followina:
Practices (area

[(b\6)

& approximately 1600 hours, 4th of August 2020, 1, nae
ee Tobserved the following while
performing poultry GCP verification task: When | walked
in the live hang room, there are approximately 20 dead and
live young chicken on the floor. By the end of the live
hang belt, | saw a plant worker throwing in an open drain
young chicken that collected on the floor as fast as he
can. There are 5 young chicken left when | noticed one of
them is lying on its back that flapped its wings and with its
vent rhythmically moving. Iwas waiting to see the
establishment procedure of verifying the dead from the
live. However, in just few seconds, all the young chicken
on the floor are gone before my eyes, thrown in the drain
together with the one breathing bird. | exclaimed to the
plant worker, “you threw in the drain a live bird!” The plant
worker | was observing did not perform a procedure to
verify ifthe bird thrown on the floor by the live bird hangers
is dead or simply moribund or weakened. Apparently, he
assumes non ambulatory bird on the floor is dead and
automatically thrown in the drain. | notified 2nd Shift
foe) Jor rm
observation. | reminded |(b\(6)

(Be)_—_—_Jpat tne PPIA and Agency regulations require

at Ive 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 Manager
Pustejovsky 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. also told him that an MO! will
be forwarded to the District Office and the District
Veterinary Medical Specialist (DVMS) in case additional
follow-up is recommended. Hopefully, this MOI serves to
bring (o the establishment's attention that live poultry must
be treated in a manner consistent with good commercial
practices. Respectfully, IbJfmver J, USDA.
Relief SPHV at P-19688: Sanderson Farms at Bryan,
Texas.

29


8

Table: Noncompliance Reports in Response to FOIA2021-108 08:56 Thursday, January 7, 2021
EstNbr EstName NR Id NR# Date Task TaskName Regs Description Status
p44947 Two Brothers for | {683CCDC72-BA1 | TRRO213 07/06/2020 | 04C05 | Poultry Good 381.65(b) On 07/06/2020, while performing the verification of the CLOSED
Wholesale 2-4721-B22D-22 | 072508N Commercial implementation of the Poultry Good Commercial Practices,
Chicken, Inc. 7351B67E43} 4 Practices (exey }, at approximately 1138 hours,

observed the following noncompliance: Upon entering the
establishment's Slaughter Area, | observed, inside of a
“Kill? designated employees carcass transfer barrel
(transferring occurs from bleeding cones to barrel for
transport, and then to scalding) one live flapping and
cawing chicken beneath two deceased carcasses, The
designated “kill” employee was notified of the observation
immediately, instructed to stop the slaughtering process,
and to properly bleed the carcass via the proper coning
method which is the allowance of bleed-out from the
carcass which should result in the deceasing of the bird
itself. The employee did immediately comply with the
regulatory control act and production resumed at

approximately 1143 hours. (66)
was also notified of this noncompliant observation.



Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
M6137+P613 | Foster Farms BXL1108092 17SEP2020 Finalized | On 09-17-20 at approximately 0115 hours while performing
7 7G a routine coon Commercial Practice (GCP) task in Plant

% z feokexen foun the following: While

the live hang area | was observing
the DOA’s that are placed in the stainless-steel tanks. On
this particular moming the tank contained both DOA's and
paws, as the paw kicker was not functioning properly on
Line 3 at the time. The employee tasked with collecting,
condemning and denaturing the DOA's was preparing
to dump a yellow barrel, full of carcasses. | observed him
placing 5-6 carcasses in the tank and then proceed to pick
up the yellow barrel and dump the rest of the carcasses
into the condemn tank, one of which was still alive and
moving. The live bird had been placed at the bottom of the
yellow condemn barre! while it was still alive and breathing
Dead carcasses had been stacked on top of it, essentially
leaving the live bird in the bottom of the condemn barrel to
suffocate. At this time | took regulatory control action and
took possession of the live bird, which had been placed
back in the yellow condemn barrel by the establishment
employee. The bird was moving its wing and legs and was
still breathing. When | removed the bird from the condemn
barrel it was holding its head in an upright position. At this
J rhcoring
MOL Soon after this. Tee fone flan rived
and | nolified him of my findings, the canna i MOI and
showed him the live bird, which was still holding its head
up, moving and breathing. Superintendent asked for the
bird. which | relinquished controLof. | requested that Live
p61 | remove the remaining
carcasses from the condemn tank in order to verify that
there were no other live pads that were not visible to me. |
contacted [BY6)____)\(6)|to notify her of the situation
immediately following 7 findings.
was reminded that the PPIA and Agency Regulations do
require that live poultry be handled in a manner that is
consistent with Poultry Good Commercial Practices, and
that they not die from causes other than slaughter. Please
review Federal Register Notice Vol. 70, No.187, published
September 2005 (Docket No. 04-037N) for FSIS
recommendations concerinn treatment of live poultry
before slaughter. [(0X6) as
informed that this MOTwill be Torwarded to the District
Office and the District Veterinary Medical Specialist
(DVMS) in case additional follow-up is recommended.
Respectfully,

13


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P6164A Foster Farms 0151140736 14JUL2020.| 04C05 | PoultryGood | Finalized | On July 14, 2020, at approximately 0601 hours, while
14G Commercial performing a routine Good Commercial Practices
Practices (GCPs) inspection, | observed practices not consistent

with GCP. Normally, the cage dump operator tilts a cage
module against a steel-framed set of chutes so that the
caged birds slide out of the cage module and through a set
of slick steel chutes to land in a pit where a conveyer belt
floor transports them for hanging, After the birds are
dumped, the cage module is tilted right up, back into place
and rolled away, To avoid needless repeat trauma to live
birds that are advertently ‘pinned! in machinery, itis a good
commercial practice and establishment policy to neither
‘rest’ nor 'shake! cages in which birds are pinned, (An
exception of ‘double-dump' is allowed when a large number
of birds are safely trapped inside the cage when one or
more flip-doors does not open.) Establishment policy
directs employees to simply remove the cage away from
the chute frame and with two-hands, deposit the bird into
the belt-pit. This time, however, a single, live bird was
pinned between the steel frame of the dump chutes and the
steel frame of the cage module. In response, the operator:
paused the operation in the maximurilted position for
approximately forty seconds, apparently attempting to allow
the pinned bird to ‘break free’; instead, the bird remained

in place and endured needless sustained pain, tilted the
cage back up and down again (‘double-dumping’) thereby
repeating injury and pain, and, (observing the bird was stil
pinned) tiled the cage upright, pulled it away, then shoved
the bird off the edge of the platform with one hand. |
attempted to find an establishment lead employee or
supervisor; however, unable to find either in the live hang

offices, the live hai ration rooms, or the scalding
rooms, JinformegAHBY of
the event. A single bird event does not serve as any
indication of loss of process control (or regulatory
non-compliance); however, this type of GCP-inconsistent
event (mishandling of pinned/trapped birds) has been
observed on other recent occasions, as documented in the
most recent establishment meeting MOI. In said
meeting, the establishment reaffirmed their dedication to
achieving and maintaining strict adherence to humane
handling and GCP practices.

65


Table: MOlIs in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MOI! Agenda

P8107+V810
7

Squab Producers Of California

DCF4011085
111G

11AUG2020

Finalized

On August 11, 2020 at approximately 5:35am, while
conducting a good commercial practices task, the following
was observed: |, {(5)(6) was watching the
establishment employee do The live hanging of chickens. |
noticed 2 DOA birds on the floor near the yellow DOA
barrel. When | looked inside the barrel, | saw several
chickens that were DOA’s and one live chicken in the
barrel. The live chicken was standing on top of the others
and was very alert. | went out the sliding door to the
unloading area to find Armando Sanchez to report my
findings. By the time we went back to the live hang area
the live chicken had been removed from the barrel and the
two DOA's on the floor had been placed into the barrel.
Live birds are not to be placed in the DOA bin.

P824+V824

Crescent Duck Farm

GCA5S712093
118G

18SEP2020

Finalized

Good Commercial Practices & Face Mask educational
meeting: Ea" Iwas present as representative
of the establishment. The topics discussed was the Good
Commercial Practices and the face mask requirement. All
employs should wear a face mask as requirement by law.
The GCP include the birds handling when arrive and
unload birds from transport. During the unloading birds
from transport the birds will be not mishandled or
mistreated. Transport with birds should not be parked
outside the plant for prolonged periods. This exposes the
birds to environmental elements of excess heat /cold

etc.. , outside should be properly cleaned to avoid any
insanitary conditions. The Crescent Duck farm have no
issues or concerns about these topics and no other topics
were discussed at this time. The meeting ended without
further comment.

81


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MO! Agenda
P46826 SHENANDOAH VALLEY ORGANIC BOKO214075 29JUL2020| 04C05 | PoultryGood | Finalized | This Memorandum of Interview is a summary of my
029G Commercial findings today (07/28/18) and discussions with
Practices establishment (P-46826) management. At approximately

0715 hours, while performing good commercial practices
verification, | Pi entered the Lower level of
the live hang Department and observed 1 dead, bloody
chicken that appeared to have been crushed. _ | notified
Robert Terrell (Plant Manager) and (b)(6)

Tait who informed me that an
investigation would take place to see if physical alterations
could be made to prevent this from happening in the future,
Mr. Terrell later told me, that a wire mesh would be
constructed in front of the “rollers”. Mr. Terrell then asked
me to accompany him to live hang. While there he
explained in detail what the alterations would be. He also
stated this work would be accomplished over the coming
weekend. 9 CFR 381.65(b) requires that poultry be
slaughtered in accordance with good commercial
practices, Compliance with these requirements helps
ensure that poultry are treated humanely. In general,
poultry should be handled in a manner that prevents
needless injuty and suffering in order to produce a
commercially marketable product.

51


Table: MOlIs in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

Task
EstNbr EstName MOINbr Date Code | TaskName Status MOI Agenda
P47016 The Best Dressed Chicken, Inc. OFG4315084 27AUG2020 | 04C05 | PoultryGood | Finalized | At approximately 0715 hours after removing approximately
127G Commercial 15 cadavers from the line at the inspection station, | took
Practices regulatory control of the line and requested that the line be

slowed until the process was under control. Shortly
thereafter, the condemn barrels behind the sorter helpers
and rehang table were full of cadavers and some made it to
the inspection station. After removing over 100 cadavers
from the line, and seeing the amount of cadavers coming
from the picking room into evisceration at the rehang table,
| took regulatory control of the hang line for 10 minutes so
that the needed repairs/adjustments could be made to
prevent live birds from entering the scalder. The
establishment took additional time and believed that they
had repaired the issue and started slaughter. Again, |
started removing numerous cadavers from the line at the
inspection station. The condemn barrels at the

rehang area were also full of cadaver and several we on
the floor behind beside the barrels. Regulatory control of
the line was taken at approximately 0800 hours. In the first
hour of operation, | condemned 152 cadavers and had to
take regulatory control of the line twice. The establishment
did not prevent live birds from entering the scald tank nor
were initial corrective actions effective. Corrective
actions have continually failed to be effective in preventing
live chickens from entering the scald tank. Three Good
Commercial Practice MO!s have been previously
documented for the same findings on March 11, 2020,
(OFG5817032811), January 27th, 2020
(QOFG36080141271), and January 23rd, 2020
(OFG12140113231). Additionally, the issue of live birds
entering the scald tank has been brought up at meetings
with the establishment. Live chickens entering the scald
tank and dying by means other than slaughter is not
following PPIA and Agency regulations requiring that live
poultry be handled in a manner consistent with good
commercial practices. This MOI will be forwarded to the
Frontline Supervisor and the District Veterinary Medical
Specialist.

53


Table: MOls in Response to FOIA2021-108

08:56 Thursday, January 7, 2021

EstNbr

EstName

MOINbr

Date

Task
Code

TaskName

Status

MO! Agenda

P1009

Wayne Farms LLC

DSM0520091
110G

JOSEP2020

Open

On Wednesday September 9, 2020 at approximately 20:25
while watching cage dump, | saw approximately 10 birds
fall onto the conveyor. The door was broken on the cage
and the birds fell out onto the conveyor. The cage

dump employee did not run them over or cause any harm
to the birds and put them down the shoot fo live hang. The
cage with the broken door was then placed back on the
truck with no marking, | then wentto look at cages on the
truck being unloaded and found a loose bird. A lead was
contacted to get the bird at which time | showed him the
broken cage door. The cage was taken off the truck and
put off to the side for repair. As | continued inspection of
cages containing live birds, | identified 3 more cages with
defects. All 3 had plastic floors warping and either pushing
on birds below or creating a small area for birds to become

partially trapped in. | had =}
YY called out to take pictures of the cages
in question and asked about their marking system for

cages that were in need of repair. Currently itis the duty

of the forklift driver to remove damaged cages and leave
them aside [51 ]counseled both the cage dump
operator and forklift driver regarding cage repair
identification .

P1243

Perdue Foods, LLC.

XLB4100075
920G

205UL2020

04c05

Poultry Good
Commercial
Practices

Finalized

At approximately 0130 hours while preforming a Poultry
Good Commercial Practices Task the following issue Was
observed: In live receiving on the DOA belt a live bird was
seen standing on the belt drop. | observed 2 DOA birds
come down the belt knocking the live bird onto the

DOA pile (appx. 10-15 birds) and falling on top of the live
bird. There was also 2 other live birds commingled in the
pile of DOAs. The belt was unattended so | proceeded

‘inside to find the lead employee. When we arrived to the
eS ee par avady picking up the
live birds and putting them into holding cages. | notified Mr.
Tame pnd of my observations

16