-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 1 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

M1015+P1 Poultry Holdings, LLC ARE180407 25JUL2019 04C05 Poultry Good Finalized 

015 0825G Commercial 

Practices 

DVMS GCP Verification Visit - Turkey Cages in 

Disrepair Est. P01015, Empire Kosher Poultry, 

Inc., July 24, 2019, 1340 hours. In attendance: 

and Plant Manager Mr. Chad 

Pannebaker. At approximately 1200 hours while 

observing receiving of turkeys 

and I observed two turkey trailers (#22 

and #23) with a total of six cages in disrepair.  Five 

(b) (6)

(b) (6)

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

of the cages had broken or damaged fiberglass 

bottoms which had bent down into the cage 

below due to the weight of the turkeys on top. 

The flimsy bottoms caused some of the turkeys in 

the upper cages to fall into the lower cages and 

become pinned between the bent fiberglass and 

side of the lower cage, resulting in injuries.  One 

of the turkeys was badly injured with a broken 

wing tip, and broken, bloody feathers on the wing 

and wing tip.  One of the back cages on trailer #23 

appeared to not close as indicated by the bungee 

strap which was not secured resulting in an open 

cage (no turkeys were observed falling from the 

trailer at that time).  The one damaged cage floor 

on trailer #22 was the fifth coop back on the right 

side and the third cage down.  The four damaged 

cage floors on trailer #23 were on both sides of 

the first coop, two floors on each side.  We 

notified Live of the 

deficiencies and discussed these issues with Plant 

(b) (6)

Manager Chad Pannebaker in the exit meeting. 

Mr. Pannebaker immediately discussed the 

findings with his employees and suspended the 

use of the damaged cages until new fiberglass 

floors arrive and are installed. Mr. Pannebaker 

was 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 Mr. Pannebaker 

review Federal Register Notice Vol. 70, No. 187, 

published September 2005 [Docket No. 04–037N] 
(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 2 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

for FSIS recommendations concerning treatment 

of live poultry before slaughter.  Mr. Pannebaker 

was reminded 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, 

Plant 1015, Empire Kosher 

Poultry. 
-

• 

-

-

-

-

3 

015 

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

EstNbr 

M1015+P1 

EstName 

Poultry Holdings, LLC 

MOINbr 

ARE231011 

4314G 

Date 

14NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Est. P01015, Poultry Holdings LLC, November 13, 

2019, 0700 hours. In attendance: 

Plant Manager Chad 

Pannebaker; 

On November 13, 2019 at approximately 

0346 hours, while performing ante-mortem 

inspection in the live room, and before the start of 

production that day, 

observed several young chickens from 

the previous day’s kill in a red condemn barrel. In 

addition, she noticed a leg moving from a chicken 

which  was covered by the other chickens. She 

immediately notified 

who instructed an employee to remove the 

chickens from the barrel. At that time,

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

 observed him pulling out four live 

chickens. The one with the leg sticking out  was 

dead at that time, and then he pulled out an 

additional five more dead birds. 

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

discussed this 

incident with Plant Manager Chad Pennebaker, 

during the 

(b) (6)

weekly meeting on November 13, 2019. 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. o4-037N] for FSIS recommendations 

concerning treatment of live poultry before 

slaughter.  Mr. Pannebaker was reminded that 

this MOI will be forwarded to the District 

Veterinarian Medical Specialist (DVMS) in case 

additional follow-up is recommended. 

Plant 1015, 

Poultry Holdings LLC. 

(b) (6)
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1111 

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4 

2 

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

EstNbr 

M112+P11 

M1234+P1 

234 

EstName 

Tyson Foods, Inc 

Mountaire Farms Inc. 

MOINbr 

VBL291206 

4426G 

QUI441307 

0003G 

Date 

26JUN2019 

03JUL2019 

Task 

Code 

04C05 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

Finalized 

MOI Agenda 

I observed a live chicken in one of the cages that 

was set aside for rework. I notified the lead to 

take corrective actions and discussed the issue 

with 

(b) (6)

See MOI VBL150061926G for details of discussion 

at weekly meeting with establishment. 

On July 3, 2019, I and 

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

preformed verification of the 

Poultry Good Commercial Practices (GCPs) task at 

1230. We were accompanied by 

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

from Raleigh District Office, who was 

preforming a GCP assessment and

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

 Est. P1234. At 

approximately 1250, we all observed a live 

chicken (blinking eyes and taking rhythmic 

breathes) on top of pile of dead birds in the dead 

chicken bin outdoors. The bird did not appear to 

be injured or in distress

 took the live bird from 

the pile and performed a cervical dislocation 

thereby euthanizing the bird. 

(b) (6)

later 

informed me of his plan to have a device installed 

that would aid plant employees with decapitation 

of each chicken before going into the dead 

chicken bin. 

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

-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 5 

EstNbr 

M13556+P 

13556 

EstName 

Tyson Foods Inc 

MOINbr 

TDB01230 

65903G 

Date 

03JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Establishment P13556, Tyson Foods, Inc.  June 3, 

2019,1943 hours.  In attendance 

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

. On June 3, 2019 

at approximately 1943 hours, while observing 

conditions in the DOA trailer bay in the poultry 

live hang department, I, 

(b) (6)

climbed 

the ladder and observed one live bird in the DOA 

trailer. I climbed back down the ladder notified 

(b) (6)

of my findings. She then 

climbed up the ladder to verify, then notified 

(b) (6)

that there was a live 

bird in the DOA trailer. 

(b) (6)

informed 

the live hang lead and requested him to remove 

the bird. 

(b) (6)

then took the bird and 

elected to euthanize the bird. On June 4,2019 at 

approximately 1845 hours 

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

and 

I went to speak with about the 

live bird in the DOA trailer. 

and I recommended that review 

Federal Register Notice Vol. 70, No. 187, 

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

for FSIS recommendations concerning treatment 

of live poultry before slaughter and provided him 

a copy of this document. 

(b) (6)

informed us 

that the employees were retrained on the 

handling of the birds. We notified 

(b) (6)

that 

this would be documented in a MOI. 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 6 

EstNbr 

M13556+P 

13556 

EstName 

Tyson Foods Inc 

MOINbr 

TDB15220 

71423G 

Date 

23JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Open 

MOI Agenda 

On July 23, 2019 at approximately 2135 hours, 

while observing conditions in the DOA trailer bay 

in the poultry live hang department, I, 

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

observed one live bird in the DOA 

trailer. I notified 

(b) (6)

that 

there was a live bird in the DOA trailer. 

Mr. removed the bird from the trailer and elected 

to hang it on the line as it was in good health.  I 

met with 

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

an informed him of my 

findings. I provided with Federal 

Register Notive Vol. 70, No. 187, published 

September 2005 [Docket No. 04-037N] for FSIS 

recommendations concerning treatment of live 

poultry before slaughter. I informed him that this 

would be documented in an MOI. 
--

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 7 

EstNbr 

M13556+P 

13556 

EstName 

Tyson Foods Inc 

MOINbr 

TDB14210 

93713G 

Date 

13SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Establishment P13556, Tyson Foods, Inc. 

September 13, 2019, 1915 hours. In attendance:

 On Friday September 13, 2019 

approximately 1908 hours, while observing 

conditions in the DOA trailer bay in the poultry 

live hang department I 

climbed the ladder and observed one live bird  in 

the DOA trailer. I climbed back down the ladder 

notified a team member of my findings. Team 

member notified 

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

, that there 

was a live bird in the DOA trailer, then 

(b) (6)

(b) (6)

of my findings. I reminded

(b) (6)

climbed up the ladder to verify 

informed the live hang lead and requested him to 

remove the bird. team member then took the bird 

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

and elected to euthanize the bird. 

(b) (6)

notified

(b) (6)

 and that the PPIA  and Agency 

regulations require that the live poultry be 

handled in a manner that is consistent with good 

commercial practices and that they not die from 

causes other than slaughter. I recommended that 

(b) (6)

review Federal Register Notice Vol. 70, 

No. 187, published September 2005 [Docket No. 

04-037N] for FSIS recommendations concerning 

treatment of live poultry before slaughter and 

provided him a copy of this document. I notified 

(b) (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, 

(b) (6) (b) (6)
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 8 

EstNbr 

M17250+P 

6+V6 

EstName 

Tyson Foods, Inc. 

MOINbr 

UQI431511 

5222G 

Date 

22NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On November 22, 2019 @ approximately 1503 

hours, I observed a less than good commercial 

practice while performing and Ante-mortem and 

Good Commercial Practices check at P-6. While 

performing a 500 bird count for live birds, I saw a 

live, non-stunned and uncut bird enter the scalder 

on line 2.  The bird was blinking with its head 

lifted and turned to the side. 

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

was immediately 

notified of this finding.  A copy of this 

Memorandum of Interview will be sent to the 

Jackson District Office for further review.  Thanks 

for your attention to this matter. 
-

-

9 

551 

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

EstNbr 

M18866+P 

EstName 

Jennie-O Turkey Store Sales, LLC 

MOINbr 

WJL54140 

63024G 

Date 

24JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Establishment p551, Jennie-O Turkey Store. At 

0345 on June 21, 2019, I 

made the following observation in live haul. The 

establishment uses a truck hoist for raising and 

lowering trucks and trailers to unload the live 

birds. While standing at the front of the truck on 

the driver side, I observed a bird that appeared to 

be wedged between the truck hoist and the wall. 

Looking closer I observed a bird was wedged 

between the hoist and the wall and was partially 

gutted with approximately 3 ft. of the bird's 

intestines hanging down on the outside of the 

bird carcass. I went to find 

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

, and showed him the bird 

that was still wedged between the truck hoist and 

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

the concrete wall. tried to pull the bird 

free with no success. then located 

lowered the truck hoist down as it was raised up 

to unload birds from the second from the bottom 

row on the trailer. A live hang employee then 

pulled on the bird, 

(b) (6)

had to raise and lower 

the lift while the employee pulled and pushed the 

bird to be able to get it free from between the 

truck hoist and the wall. This took approximately 

2 minutes of pushing and pulling the bird and a 

combination of raising and lowering the hoist to 

free said wedged bird. The bird was disposed of 

into the inedible trailer after it was freed. 

A similar incident happened on 04-04-19, where a 

bird was wedged between the truck hoist and the 

wall as mentioned in MOI WJL5815045904G. 

P551, Jennie-O 

Turkey Store Willmar, MN 56201 

(b) (6)
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551 

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

EstNbr 

M18866+P 

EstName 

Jennie-O Turkey Store Sales, LLC 

MOINbr 

WJL41050 

64527G 

Date 

27JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Good Commercial Practices Meeting of Interview 

Establishment P551, Jennie-O Turkey Store A 

meeting to discuss good commercial practices 

concern was held on 06/26/19 at 5:10 am. In 

attendance: 

A meeting to inform of 

good commercial practices concerns was held on 

06/26/2019 at 7:20 am. In attendance was 

On 06/24/2019 

(b) (6)

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

while observing live haul at 0505 hours, I found 

many coop doors of the trailer open. Two turkeys 

on the right side of the trailer and two turkeys on 

the left side of the trailer were out of their 

respective coops and sitting on the mezzanine. 

Other coop doors were open, but no additional 

turkeys had exited the trailer. The employees who 

unload the trailers were on a 30-minute break at 

the time of my inspection. I found the 

(b) (6)

and explained the 

(b) (6)

situation to him. He went to the truck and placed 

all turkeys back in the coops and shut all the coop 

doors which had been left open. The truck is on a 

hoist system which raises it or lowers it to enable 

unloading of the turkeys. The mezzanine is 

approximately 12 inches from the side of the 

trailer and is approximately 12 feet in height from 

the ground. On 06/25/2019 while observing live 

haul at 0515 hours, I again found many coop 

doors open while the unload employees were on 

break. There was a total of 2 turkeys out of cages 

on the right side of the trailer, and sitting on the 

mezzanine, close to the edge. One of the turkeys 

was upside down laying on his back.  The turkey 

was not breathing well. Respiration was shallow 

and diminished, less than 28 breaths per minute. I 

turned the turkey over, back on his feet, and he 

began taking deeper breaths with an increase in 
I 

-

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 11 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

live haul where I showed him the open coops and 

loose turkeys. He had an employee replace the 

turkeys into coops and shut all open coop doors. 

On 06/26/2019 while observing live haul while 

employees were on break, I found coop doors 

open on both sides of the trailer.  On the right 

side of the trailer, I found one loose turkey. It was 

located at the rear of the trailer. The turkey was 

suspended between the mezzanine and the trailer. 

Its tail was on the edge of the mezzanine while his 

legs were clutching a coop door and its head and 

neck were extended upward toward the next 

the respiration rate. I could not find live haul 

personnel, but did locate the 

and advised 

him of the conditions in live haul. He met me in 

higher coop. I immediately left the area and found 

a live haul employee, but also went to find

 was with 

and I asked both men to meet me in 

live haul immediately to witness the condition of 

(b) (6)

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

the turkey.  When they arrived, the turkey was 

still positioned as it had been. A live haul 

employee ran to the turkey and replaced it in the 

coop. He also shut all the coop doors. During the 

week of 06/16 to 06/20 I found coop doors open 

while employees were on break. I also found loose 

turkeys beneath the truck while it was hoisted in 

the air and being unloaded. There was a total of 3 

loose turkeys that I observed during that week. I 

was not present at the 06/21/19 weekly meeting, 

but I spoke with

(b) (6)

 about my concerns of 

the coop doors and loose turkeys. He brought 

these issues up at the weekly establishment 

meeting, along with his own concerns about the 

increase in loose turkeys in live hang that he had 

witnessed. Observations of this were recorded 

during the Des Moines District Veterinary Medical 

Specialist visit with

(b) (6)

 on 05/01/19. 

During her exit meeting she documented her 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 12 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

observation of “multiple open cage doors during 

unloading and uneven distribution of birds in 

some cages.” The above lists multiple 

occurrences of establishment P551 live haul 

failing to prevent and manage live birds in coops 

on a hoist above ground from exiting coops while 

unattended creating a significant risk of serious 

injury if a fall from the mezzanine occurred. It is 

the responsibility of the establishment to employ 

methods of handling and slaughter consistent 

with Good Commercial Practices in a way that 

minimizes injury to poultry. 
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551 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 13 

EstNbr 

M18866+P 

EstName 

Jennie-O Turkey Store Sales, LLC 

MOINbr 

WJL16161 

20026G 

Date 

26DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

December 26, 2019 I 

(b) (6) , 

went to live hang to do a good commercial 

practices verification task.  When I arrived in live 

hang, a truck was just coming off the hoist.  I 

stood to the side while the truck drove off the 

hoist.  It was about 3:37 pm.  Immediately after 

the truck drove off the hoist, I saw movement on 

the hoist.  I observed a turkey flapping and 

twitching on the end of the hoist.  The turkey was 

located directly in the path of the wheels.  The 

turkey was severely injured.  The head was 

missing.  The skin over the abdominal and 

thoracic cavities was torn away.  The abdomen 

was torn open and viscera hanging out.  The 

turkey was crushed and dead.  It appeared the 

turkey had been run over by the truck.  While I 

was present, I did not observe any establishment 

employees checking for live birds in the area, as 

outlined in their ante mortem program. 

An employee removed the turkey carcass from 

the hoist and set it aside.  I notified the 

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

and brought him 

back to the hoist at about 3:39 pm.  I showed him 

the carcass and where the carcass had been on 

the hoist.  I described my observations.  I 

informed

(b) (6)

 of the establishment’s 

failure to follow good commercial practices by 

allowing a live turkey to be run over by a truck.  I 

informed him of my intent to issue this MOI 

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

offered as a corrective measure to 

retrain the live hang crew. 
-

1111 

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551 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 14 

EstNbr 

M18866+P 

EstName 

Jennie-O Turkey Store Sales, LLC 

MOINbr 

WJL40220 

23004G 

Date 

04FEB2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

During night shift production the 29th of January 

2020 while performing Good Commercial Practice 

verification beginning at 4:40am, the following 

was observed: Observations were made of 5cm 

to 30+ cm bruising identified near the ankle joints 

and along the length of drums and fractured and 

bruised wings at elbow joints post pickers and 

post bleedout.  Over a 5 minute period with the 

line speed varying from 

(b) (4)

bpm, 65 carcasses 

had either drum bruising and/or wing fractures. 

The bruising was dark purple to red in color 

signifying an acute and recent ante-mortem event 

causing the bruising. Observations in the live 

haul offloading area included the four slides from 

the front passenger side offloading space on the 

catwalk in the live haul area missing.  Slides are 

used to decrease the force required for offloading 

and to assist transfer of live turkeys from the 

trailers to the conveyor leading to the CO2 gas 

stunner.  The live haul offloader was observed 

unloading turkeys without the use of the slides, 

with the turkeys repeatedly hitting the bar leading 

onto the conveyor with legs.  Compared to the 

other offloading crew, the crewmember was using 

more force to remove the turkeys: quicker 

movements with offloaded live birds having 

enough momentum to hit the back of the 

conveyor tunnel wall. The four missing slides 

were found beneath the CO2 stunner, and 

communication with 

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

identified the four slides as being out of 

commission due to needing maintenance repair. 

Over the course of 3 minutes, I demonstrated to 

him observations of bruising and fractured wings 

on the post-picking line and concerns with injury 

at offloading based on what I’d observed in live 

haul.  I also communicated with 

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

of the observations and 

GCP concerns. Verbal corrective actions given at 

5:20am included adding an additional two people 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 15 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

to the offloading crew so the offloader working 

without slides had additional support for the 

turkeys being offloaded. After a company break, 

I returned to live haul to observe corrective 

actions.  No corrective actions were instituted at 

5:45am and bruising continued to be observed 

post-pickers. Respectfully submitted by 

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

M18909+P Foster Farms JDD282206 12JUN2019 04C05 Poultry Good 

157 2012G Commercial 

Practices 

Finalized I met with

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

 for an exit meeting after my daytime 

GCP visit. The establishment was compliant to 9 

CFR 381.65(b) during my observations. We 

discussed my concern about the high 

temperatures in the holding shed, where I 

observed one trailer load of light hen turkeys held 

prior to entering the shackle barn. Nearly all the 

birds were breathing with beaks open and at an 

increased respiratory rate, and a lot were standing 

up instead of resting in the cages. I observed 

approximately 4 hen turkeys that were resting on 

their keel and not panting. The multiple 

thermometers in the holding barn registered 95 

degrees. The establishment has 4-5 fans per fan 

bank that cover 2 trailer-width sections. Water 

misters were on but there was minimal air and 

water flow on sides of the modules that were 

furthest away from the fans. Adequate measures 

for heat management are a concern for good 

commercial practices, and heat stress in turkeys 

can diminish meat quality on harvest. I have 

observed good climate management in other 

facilities. I recommended that the establishment 

veterinarian team evaluate the holding shed 

during hot weather to assess weather 

management

(b) (6)

 stated he would 

investigate this and consult with the corporate 

veterinarians. 
1111 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 16 

EstNbr 

M20322+P 

20322 

EstName 

Equity Group Eufaula Div LLC 

MOINbr 

ATF172208 

5128G 

Date 

28AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Wednesday, August 28, 2019, at 

approximately 0618 hours, I 

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

was conducting a Review and Observation 

of Good Commercial Practices in the small bird 

live hang area. The live hang belt had stopped. 

At the beginning of the live hang belt, where the 

wide (dumping) belt meets the live hang belt, I 

observed a pile of birds, two to three deep. I 

observed several wings and feet from buried 

birds, During the subsequent 2-3 minutes, these 

feet and wings progressed from moving to 

motionless. After about 4 minutes, the live hang 

belt started to work, and I counted 48 dead birds. 

Considering the pile up of birds, it is a logical 

assumption that birds on the bottom had 

suffocated. Earlier, while performing ante 

mortem portion of Good Commercial Practices,

 at 0540 hours, I was outside at the big bird 

loading bay, and there was a trailer having cages 

removed, and placed on the outside dumping 

belt. The trailer had 3 live birds directly 

underneath on the ground, and one live bird, on 

the ground, about 3 feet from the trailer edge, in 

the fork lift's thoroughfare. There were 2 

additional free birds on the bed of the trailer. An 

employee  went around the back of the trailer and 

picked up the two birds on it, then walked around 

the front of the trailer. As he came into my view, 

he was holding each bird by their neck, one in 

each hand, having the birds weight sustained by 

only their necks. I told him to put the birds 

down, and carry them properly.  Then, at the big 

bird holding bay, a trailer had a cage with an 

open door. There were two birds sitting on the 

door, and one, live bird, on the ground 

underneath. 

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

was present and was informed to 

place the bird, on the ground, into the cage, and 

close the door. At approximately 0645 hours, I 

discussed my findings with Plant Manager Todd 
1111 

• 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 17 

EstNbr 

M20322+P 

20322 

EstName 

Equity Group Eufaula Div LLC 

MOINbr 

ATF040009 

2906G 

Date 

06SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

McMahen. Loose birds on the ground, under or 

near trailer, or fork lift operating area, in a trailer 

holding or loading bay, are susceptible to being 

run over, and, therefore would die by means other 

than slaughter. Birds that suffocate, are 

considered adulterated, as death by means other 

than slaughter has occurred. The Food Safety 

Inspection Service is reminding all poultry 

slaughter establishments operate within 

guidelines of the Poultry Inspection Act. Agency 

Regulations and those set forth within Poultry 

Good Commercial Practices, whereby live poultry 

are to be treated humanely and do not die from 

causes other than proper slaughter. 

On Thursday, September 5, 2019, at 

approximately 2105 hours, I, 

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

was conducting a Review and Observation 

of Good Commercial Practices in Medium bird 

Live Hang area. The line had been hanging for 62 

minutes, at 

(b) (4)

bpm. At the end of, and 

extending over onto the end of the live hang belt, 

there was a pile 3 feet high, and, about, 12 feet in 

diameter, of dead birds. There was, also, a full 

condemned barrel of DOAs. I found 2 live birds 

sitting on the side of the pile, and slightly covered 

with dead birds. I pointed out these live birds, and 

the live hang supervisor picked them up and 

placed them on the belt. Live birds, intermingled 

with dead ones may die by means other than 

proper slaughter.  The Establishment is to treat 

poultry in a manner consistent with good 

commercial practices and take steps to prevent 

the mistreatment, harm, and distress by means 

other than slaughter. Such abuse of poultry and 

treatment in a manner not consistent with good 

commercial practices, and death by other means 

than slaughter may render the poultry 

adulterated. 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 18 

EstNbr 

M20322+P 

20322 

EstName 

Equity Group Eufaula Div LLC 

MOINbr 

ATF292310 

1214G 

Date 

14OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Monday, October 14, 2019, at approximately 

0350 hours, I, 

(b) (6)

, was 

conducting a Review and Observation of Good 

Commercial Practices in the small bird live hang 

area. The live hang belt had stopped. At the 

beginning of the live hang belt, where the 

dumping belt meets perpendicularly, there is a 

barrier of about 3 feet high. There were birds on 

the belt, piled up to the barrier, and the pile 

extended for about 10 feet. The pile also extended 

up onto the dumping belt, and that area was 

about 3 birds deep. I could see portions of live 

birds, moving, and partially buried under other 

birds. Some of these birds were extricated, most 

were not, and died, being too numerous to count. 

A conservative estimate of birds involved would 

be 100 alive, and over 700 dead. That 

concentration of DOAs was not noted in the 6 

trailers observed during antemortem, as only one 

DOA was noted less than 2 hours earlier in the 

trailers. Considering the pile up of birds, and the 

lack of DOAs, and the observation of dying birds, 

it is a logical assumption that the buried birds 

died of suffocation. The Food Safety Inspection 

Service is reminding all poultry slaughter 

establishments operate within guidelines of the 

Poultry Inspection Act. Agency Regulations and 

those set forth within Poultry Good Commercial 

Practices, whereby live poultry are to be treated 

humanely, and do not die from causes other than 

proper slaughter. 

(b) (6)

, 3rd 

shift 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 19 

EstNbr 

M20322+P 

20322 

M2130+P2 

130 

EstName 

Equity Group Eufaula Div LLC 

Cooper Farms Processing 

MOINbr 

ATF480401 

3315G 

HEF260304 

3117G 

Date 

15JAN2020 

17APR2019 

Task 

Code 

04C05 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

Finalized 

MOI Agenda 

On Wednesday, January 15, 2020, at 

approximately 0348 hours, while performing 

Good Commercial Practices observations, on line 

3, at the entrance of the scalder, I observed a live 

bird enter the scalder. The bird had it's neck 

arched back, and slightly tucked towards the 

shoulders. The eyes were open, and blinking I 

observed the head moving, and it was aware of 

it's surroundings. It was breathing, and there was 

no noticeable blood or cut of the neck. There 

were no other additional live birds observed to 

enter the scalder. I immediately notified the 

(b) (6)

. The aforementioned 

observations were discussed with 

at approximately 0430 hours. 

Reference Federal Register Docker #04-037N. 

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

On April 15th 2019 at approximately 0330 hours, 

I, 

(b) (6)

while performing 

antemortem inspection outside in the cooling 

sheds, observed a trailer of live turkeys with a 

column of cages that were not properly secured 

by the metal bar that runs from top to bottom, 

allowing the doors of these cages to swing freely 

open. I observed one loose live turkey that was 

sitting on the ground directly beneath the 

unsecured cages. I informed a nearby live haul 

employee, who returned the live turkey to the 

cages before securing them properly. The topmost 

trailer cages are not reachable without the aid of 

steps or a ladder and present a significant 

distance from these cages to the concrete floor of 

the cooling sheds, and there is relatively heavy 

vehicle traffic in and around the area. 
I I I I I I I I l 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 20 

EstNbr 

M2130+P2 

EstName 

Cooper Farms Processing 

MOINbr 

HEF280301 

5122G 

Date 

22JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On January 22, 2020 at approximately 4:15 AM 

while performing a routine GCP task, I 

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

, was passing through the live hang 

area where stunned turkeys are shackled on a 

conveyor belt (approximately 3-4 feet in height 

from the floor), and observed an employee push a 

stun failure (fully conscious turkey) off of the belt, 

causing the turkey to fall on top of several other 

conscious turkeys that were already sitting on the 

concrete floor directly opposite the belt from the 

employee. I spoke with 

(b) (6)

about what 

I observed. An SOP for proper handling of 

conscious birds was to have been implemented in 

December 2017. 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 21 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

M248B+P2 Butterfield Foods Company GXN39150 31MAY2019 04C05 Poultry Good Finalized 

15 52031G Commercial 

Practices 

Est. P215, Butterfield Foods Co., May 31, 2019, 

0805 hours. In attendance: 

At approximately 0753 hours, while 

(b) (6)

(b) (6)

performing a routine Poultry Good Commercial 

Practices verification task in the picking room, just 

after the feather picker machines, I observed a 

bright red de-feathered bird carcass with a dark 

purple head and lower neck on the line 

immediately after exiting the picker. Upon further 

examination of the carcass, I did not observe a 

neck cut. I observed the line for approximately 

five minutes and observed two additional 

carcasses with no neck cuts and four carcasses 

with shallow neck cuts that did not sever 

the blood vessels in the neck. All of these 

carcasses were bright red with dark purple heads. 

These birds entered the scald tank alive and died 

other than by slaughter. I observed an 

establishment employee place all seven cadaver 

birds in the red barrels in the pinning room. I 

immediately spoke with 

in the unloading 

room, who called for 

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

I spoke with at 

approximately 0805 hours regarding the seven 

cadaver birds. In response, 

(b) (6)

informed 

me that he slowed the kill line, increased the 

amperage on the stunner, and notified the 

back-up killers of the cadavers

(b) (6)

 stated 

that he had started the kill line slower than the 

normal speed at the start of the shift due to the 

size of the birds in the lot. He said that he had 

observed the kill line at the start of the shift and 

had not observed any cadaver birds. In the kill 

room following the stunner, I saw several birds 

with legs not completely in the shackles due to 

the size of the birds. This resulted in their heads 

being higher than the kill blade. These birds had 

to be cut by hand by the back-up cutters. 
-

(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 22 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

Following corrective actions, I 

observed the line after the picking machines for 

an additional five minutes and did not observe 

any cadaver birds. 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. Poultry must be slaughtered in a 

manner that will result in thorough bleeding of 

the carcasses and ensure that breathing has 

stopped prior to scalding. 
 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 23 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

M27389+P Pitman Farms NCO10120 07MAY2019 04C05 Poultry Good Finalized 

27389+V27 50507G Commercial 

389 Practices 

Est. P27389, Pitman Family Farms, April 24 and 

25, 2019. USDA & Est. personnel involved: 

The events in this GCP MOI span over two days 

(b) (6)

(b) (6)

and relate to delayed delivery of the CO2 supply 

for the Establishment.  Without CO2 for stunning, 

the birds were stunned using the backup electric 

stunner on Line #2

(b) (6)

 was in 

communication frequently with various 

Establishment personnel regarding these issues, 

but most frequently with the individuals listed 

above. On 4/24/19 at approximately 0919 hours 

I observed one awake bird while standing at a 

spot in the last 1/3 of the length of Line #2 that 

runs on the blood pit platform.  This position was 

before the head-puller and before the scalder, but 

after the autokill blade and three establishment 

employees used as back up stickers.  I noticed one 

bird’s head moving as if it were looking around.  I 

placed my hand lateral to the bird’s eye, without 

touching the head, and the bird moved its head 

away from my hand.  The bird passed through the 

head puller and did not enter the scalder alive.  I 

informed

 of my findings and suggested 

that if the CO2 gas levels were going to be altered 

(b) (6)

that the Establishment keep good records and be 

certain to follow any procedures in place. I 

observed multiple instances over the two days of 

birds that were still awake after coming through 

the electrical stunner on Line #2 in the live hang 

room: On 4/24/19 at approximately 0930 hours 

I counted 24/300 birds (8%) awake after leaving 

the electrical stunner and then entering the 

autokill blade.  The birds were lifting their heads 

and rapidly flapping their wings compared to the 

wing movements of the other birds.  I did not 

count it at this time, but these birds often were 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 24 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

the same birds that passed outside of the autokill 

blade path, evading the cut at the blade.  These 

birds going through the autokill received cuts to 

the cervical and head region that were not 

perpendicular to the major vessels of the neck, 

but instead transverse cuts through the sagittal 

plane of the head and neck.  I informed 

of my findings.  The 

Establishment moved the vertical level of the 

(b) (6)

(b) (6)

electric stunner in response to my findings.  On 

4/24/19 at approximately 1730 hours I counted 

10/300 birds (3.3%) awake between leaving the 

electrical stunner and entering the autokill blade. 

The birds were lifting their heads and rapidly 

flapping their wings compared to the wing 

movements of the other birds.  I counted 14/300 

birds (4.7%) that passed through the autokill 

outside of the path of the knife.  On 4/25/19 at 

approximately 1000 hours I counted 25/300 birds 

(8.3%) awake after leaving the electrical stunner 

and then entering the autokill blade.  The birds 

were lifting their heads and rapidly flapping their 

wings compared to the wing movements of the 

other birds.  I observed some of them vocalizing or 

attempting to vocalize.  I observed one bird sitting 

all the way up with its head touching the shackle 

and its own hocks.  I informed 

of my findings.  The 

Establishment moved the positions of the backup 

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

stickers and the extra monitor in response to the 

findings.  On 4/25/19 at 1000 hours I 

observed birds hanging from the shackle on just 

one leg as they left the electrical stunner.  I 

counted 4/300 birds (1.3%) hanging on one leg 

and then 3/300 (1%) in a second count completed 

a few minutes later.  I discussed my findings at the 

electrical stunner with 

at 1330 on 4/25/19. 

(b) (6) (b) (6) (b) (6) (b) (6)
I I I I I I I I l 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 25 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

explained that those hanging from one 

leg had a chance of not getting a full stun 

had evaluated the electrical stunners that 

day and informed me that they were working. 

On both 4/24/19 and 4/25/19 the Establishment 

responded to my findings by altering the 

arrangement of the backup stickers after the 

autokill and before the head puller and scalder. 

The Establishment also added an additional 

person in the same area as a spotter to take birds 

that appeared to still be awake after passing the 

autokill and backup stickers off the line for a short 

period until the spotter was certain the bird was 

dead.  The bird would then be put back onto Line 

#2 to go into the scalder.  The arrangement 

changed a few times, but the one that I observed 

that appeared to be most effective was to have 

two back up stickers on the first 1/3 of the blood 

pit portion of Line #2 and a spotter and another 

back up sticker in the middle of the platform on 

the last 1/3 of the blood pit portion of Line #2. 

This arrangement appeared to give the most 

amount of time to find and remove live birds 

before they passed through the head puller and 

scalder.  The two-person teams also appeared to 

offer the Establishment employees better support 

to be effective in removing live birds.  There is 

no FSIS regulatory requirement to stun birds 

before slaughter and no live birds were observed 

entering the scalder.  Est. P27389 is in regulatory 

compliance in these matters according to USDA 

FSIS.  The Establishment has a special label claim 

for animal welfare on some of its products and 

the observations listed in this MOI may show that 

the Global Animal Partnership (GAP) claims for 

these animals was not met for the slaughter 

portion, specifically that birds were observed 

hanging by one leg and that not all of their birds 

were stunned and rendered insensible prior to 

slaughter.  See page 37: 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 26 

EstNbr 

M32130+P 

32130+V32 

130 

EstName 

Dakota Provisions LLC 

MOINbr 

JEB070807 

2403G 

Date 

03JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

https://globalanimalpartnership.org/wp-content/ 

uploads/2018/04/ 

GAP-Standard-for-Meat-Chickens-v3.1-20180403. 

pdf.  USDA collected labels from product 

produced from the birds slaughtered on 4/24/19 

and 4/25/19 and some of these labels had GAP 

“Step 3” printed on the label.  If the label claims 

were not met, this could represent a potential 

misbranding regulatory non-compliance.  The 

Establishment has been informed of the USDA 

concerns and both parties are investigating the 

matter further at this time. 

At approximately 0500 while performing 

ante-mortem inspection, I observed a live bird on 

the ground beside trailer #29.  Upon closer 

examination, I noticed two open cage doors on 

the second to last row of cages, the fourth and 

fifth cages up from the bottom.  This is 

approximately an 8-10 foot drop to the concrete 

below.  The bird did not appear to have sustained 

any injuries.  Both open cage doors were on the 

drivers side and were fully functional. 

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

was immediately notified.  The 

bird was placed into a lower cage and the two 

open cages were closed. 

(b) (6)

and I discussed 

the open cage door and the consequences of 

doors not being shut when leaving the farms to 

the establishment. The establishment must 

employ humane methods of handling and 

slaughtering consistent with Good Commercial 

Practices in a way that minimizes injury to 

poultry. 
r- I I I I I I T 1 

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I I I I I I I I J 

130 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 27 

EstNbr 

M32130+P 

32130+V32 

EstName 

Dakota Provisions LLC 

MOINbr 

JEB391408 

1420G 

Date 

20AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 0455 hours, while performing 

ante-mortem inspection, I discovered several 

issues that impacted the health and wellbeing of 

the turkeys. On this morning, the ambient 

temperature was 73 degrees Fahrenheit and the 

humidity was elevated. In the live hang shed, 

there was one truck fully unloaded and staged for 

the CO2 stunner and one truck in the shed ready 

to unload. The batteries from the truck that was 

unloaded were stacked two high and were close 

together along the east end of the stunner. Both 

the east and west overhead doors to the live hang 

were open. This seemed appropriate, as I had 

been told the previous evening that Evisc would 

not start until 0515 hours. The area was warm, 

stagnant and there was no or very little air 

movement. Approximately 50% of the turkeys 

were open mouth breathing and panting.  I 

discovered, however, that Evisc was not to start 

until 0600. It seems that moving the birds into 

this warm poorly ventilated area so far ahead of 

start-up was not in keeping with the 

establishments routine practice. Also, during 

ante-mortem inspection I discovered a cluster of 

four trailers parked side-by-side on the lot (31, 25, 

10, and 27) with varying amounts of space 

between them (approximately 2.5 feet to about a 

foot). Nearly 100% of the birds on the two middle 

trailers (25 and 10) were in distress. These birds 

were drooping, open mouth breathing, necks 

extended with beaks touching the cage floor, all 

the birds examined were drooling and there was 

clear liquid running off their caruncles, wattle, and 

snood and most had their wings extended as best 

they could in the cage. The birds in the two outer 

trailers (31 and 27) were relatively comfortable 

with approximately 20%-30% of the birds open 

mouth breathing. I met with 

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

and discussed these findings. I also 

emphasized that in my medical opinion the birds 
I I I I I I I I -, - - ■ - - - -

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 28 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

in trailers 25 and 10 were  in environmental stress 

and would require immediate attention. 

advised with the delayed start for Evisc 

that things seemed to have gotten missed and the 

trailers did not get separated as usual. He also 

acknowledged that the birds were moved into live 

hang on time for a normal start time. He advised 

that they will delay bringing the birds in early 

tomorrow will also have the trailers 

moved immediately and may move trailer 10 and 

25 into the misters. I had a second 

proposed corrective actions. 

informational conversation with 

in which I reviewed my findings and 

my conversation with along with his 
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130 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 29 

EstNbr 

M32130+P 

32130+V32 

EstName 

Dakota Provisions LLC 

MOINbr 

JEB461111 

5015G 

Date 

15NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Est. 32130, Dakota Provisions, 11/15/19, 1110 

hours.  Meeting attendance: 

On 11/15/19 at approximately 

1051 hours while monitoring conditions in pick 

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

scalder that was arching his neck and trying to 

escape the shackles.  I notified 

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

of the conscious bird about to 

enter the scalder and had the line immediately 

stopped.  While I observed this bird on the line, he 

was able to arch his neck and blink his eyes. 

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

grabbed a portable ladder and pulled the 

bird off the line.  The bird had a superficial skin 

cut only.  No major vessels were severed.  The bird 

was then immediately relocated back on the line 

before the neck cutter to start the process over.  I 

then looked at the automatic cutter and noted 

that the blade was not functioning as intended. 

The blade stalled out and quit turning as the birds 

entered the neck cutter. 

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

placed another back up cutter (two 

total) behind the automatic blade.  The incident 

that took place is a concern due to the neck cut 

miss and its path straight to the scalder to drown, 

as it was still breathing and fully conscious.  I 

immediately notified 

, of 

the incident.  They called maintenance to 

investigate the faulty equipment.  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. 

(b) (6) (b) (6)
22 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 30 

EstNbr 

M322A+P3 

EstName 

Pilgrim's Pride Corporation 

MOINbr 

CNC23030 

12511G 

Date 

11JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Good Commercial Practice: Un-stunned, conscious 

birds through pre-scalder immersion dip tank 

During night shift production on the 6th of 

January, I observed live, un-stunned birds coming 

out of the line 2 stunner and hung online.  The 

back-up waterbath scalder was observed to not be 

in operation (stunner lowered out of line).  The 

live birds were missing the cut machine and the 

back-up cutter was trying to address the 

un-stunned and uncut birds.  I discovered two 

uncut birds having gone through the pre-scalder 

dip tank before the main scalder un-stunned. 

Both birds were observed to be agonal breathing 

with bright red skin. The good commercial 

practice observations were discussed during the 

7th of January weekly meeting and documented 

under Meeting with Establishment Management 

1/7/2020 MOI: CNC57070116071.  Establishment 

response at the time included disciplinary action 

of the back-up cutter. During night shift 

production on the 8th of January (9th January 

production date), another observation was made 

at 3:10am where un-stunned, conscious birds 

were observed out of the stunner, hung on the 

line, and without the back-up waterbath stunner 

up or in operation.  The live conscious birds were 

missing the cut machine, and the back-up cutter 

was addressing the missed birds.  No fewer than 

15 conscious birds were observed being addressed 

by the back-up cutter before the line was stopped 

by the back-up cutter and the notification bell 

was rung. I observed the line before the main 

scalder, where I identified an uncut, un-stunned 

bird through the pre-scalder dip tank, as the neck 

wasn’t cut, the bird was flaccid, and the skin was 

bright red.  I removed the bird from the line and 

notified the 

of my findings. Verbal discussion with 

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

occurred around 5:30am the 9th of January 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 31 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

including addition of a second back-up cutter to 

the line, each back-up cutter responsible for one 

line, and employees were notified to stop the line 

to address live birds through the cut process. 

Submitted with respect, 

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 32 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

M34145+P Kadejan, Inc. JQU16080 06JUN2019 04C05 Poultry Good Finalized On Wednesday June 5th, 2019 at 0830 hours 

34145 62106G Commercial 

Practices 

while performing a Good Commercial Practices 

Task, during slaughter I observed that there were 

eight DOA’s that the Establishment had separated 

from live birds at receiving. There were a total of 

nine batters in the storage area each batter holds 

fifteen drawers. Each cage is approximately three 

feet long by two feet wide by about 18 inches 

high. I observed a batter in the storage area with 

birds that were breathing heavy with their mouths 

open in the top row of cages and also in the next 

row down. The batter was in the building where 

the temperature seemed to be slightly higher than 

the outside temperature. There were only two 

fans, one of the fans was on the outside of the 

batters facing in toward the batters and there was 

also a fan in the center of the batters facing the 

batters, there was very little air movement in the 

storage area where the birds were. As I looked at 

the other cages I observed that approximately 

seventy percent of the birds were mouth 

breathing. The outside air temperature at that 

time was approximately 64° F. The temperature is 

expected to get up to around 84° F today. I went 

outside the building to observe the birds in the 

batters on the outside. The batters had been 

placed in a shaded area with a slight breeze. There 

were four batters on the West side of the building 

where they got the most shade. There were 

eleven batters on the North end of the building 

where there was still shade available. As it got 

later in the day the shade would give way to the 

sun and heat. In one batter I could see that there 

were at least five DOAs in two of cages outside 

located on the West side of the building. The birds 

were loaded so that not all the birds could lay 

down in the cage, some were forced to stand. This 

was because there was no room in the cage since 

the cage had no more room for the birds to lie 

down. By 1000 hours there had been 20 DOA’s 
-

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 33 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

separated from the incoming live birds. At the end 

of the day there were a total of 59 DOAs, 

trimmed birds and 16 condemned by USDA for a 

Total of birds in all. Birds must be loaded 

with room to lie down and not so tight that they 

are forced to stand.  The birds must have room 

from overcrowding (especially in temperate or hot 

weather) to prevent diminished ventilation and 

heat stress.  A lack of air low, ventilation, and 

sufficient space within a cage can lead to heat 

stress and the death of birds by means other than 

slaughter. The Establishment must employ 

humane methods of handling and slaughtering 

consistent with Good Commercial Practices in a 

way that minimizes injury to 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 increase the 

likelihood of producing unadulterated Product. 

The Establishment Management has stated they 

will send extra batters out on Thursday for 

Friday's slaughter, to give extra room to the birds 

and allow them better ventilation. Friday 

the two extra batters were sent out to the farm, 

allowing for more room for each bird. There were 

only nine batters inside the building the batters 

inside the building were staggered and spread 

further apart allowing the two fan to move air 

more affectively. There were four batters still 

outside on the north side of the building. These 

batters were also spread far enough apart to allow 

the breeze to get into the birds. Today's slaughter 

consisted of birds that were processed, 8 

DOAs, and 19 birds condemned by the plant or 

USDA inspection for a total of birds in all 

today. The plant has ordered two more fans for 

inside the building and expect them to arrive 

some time next week. 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 34 

EstNbr 

M34145+P 

34145 

M45134+P 

45134 

EstName 

Kadejan, Inc. 

Birdsboro Kosher Farms Corp. 

MOINbr 

JQU05111 

03802G 

FKJ541505 

4428G 

Date 

02OCT2019 

28MAY2019 

Task 

Code 

04C05 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

Finalized 

MOI Agenda 

At 0800 hours on October 2, 2019, while 

performing a Good Commercial Practice task I 

observed, one head caught in-between cage and 

frame work this number has dropped from earlier 

at this farm. There was one wing caught 

in-between the cage and framework. This happens 

on occasion when the cages are closed. There was 

one leg that had went through a hole in the 

bottom of the cage that had gotten wedged under 

the cage drawer and the framework. The Plant 

cleans these cage drawers after every use. I 

verbally informed 

(b) (6)

of the 

situation. 

At establishment #45134, Birdsboro Kosher 

Poultry, on May 28th at approximately 2:45 pm I 

(b) (6)

was called to the 

(b) (6)

stand on the turkey 

evisceration line.  Upon examination of the turkey 

carcass I saw that the skin incision was lengthwise 

(parallel to the line of the neck, not straight across 

under the chin) and asymmetrical (only on 

the right side of the neck), the left carotid artery 

had not been severed, and the other artery had 

only been nicked.  The entire neck was heavily 

hemorrhaged. There was a small amount of 

carcass bruising. The Plant Manager, Carlos 

Urieta, was notified and also examined the 

carcass.  I explained how my observations led me 

to believe the turkey was a cadaver and had not 

been slaughtered properly.  This is not consistent 

with good commercial practices which requires 

that live poultry cannot die from causes other 

than slaughter. He left to speak with the rabbi 

who was slaughtering at that time (the 

establishment slaughters one turkey at a time on 

a single line). Before he left, I informed Mr. Urieta 

that I would be issuing an MOI for the poultry 

mistreatment. 

(b) (6)
1111 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 35 

EstNbr 

M45134+P 

45134 

M45134+P 

45134 

EstName 

Birdsboro Kosher Farms Corp. 

Birdsboro Kosher Farms Corp. 

MOINbr 

FKJ121007 

4410G 

FKJ351507 

0417G 

Date 

10JUL2019 

17JUL2019 

Task 

Code 

04C05 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Poultry Good 

Commercial 

Practices 

Status 

Open 

Open 

MOI Agenda 

On July 10th at approximately 1015 hours when I 

was conducting Good commercial practice task, I 

observed loose bird outside the establishment 

close to the Rabbis building, and another bird 

close to the employees parking lot. I informed one 

of the plant managers, but he didn’t take any 

action so that I started looking for 

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

who caught 

them. The day before on July 9th there were 

many birds loose in killing department. The 

establishment needs to comply with regulation 9 

CFR 381.65). Compliance with these requirements 

helps ensure that poultry are treated humanely. In 

general, poultry should be handled in a manner 

that prevents needless injury and suffering in 

order to produce a commercially marketable 

product.  Birdsboro Kosher must ensure that all 

poultry are slaughtered according to regulations, 

This MOI will be forwarded to the District Office 

and the District Veterinary Medical Specialist 

(DVMS) in case additional follow up is 

recommended 

At approximately 1415 hours, I was conducting 

good commercial practice at killing area when I 

saw four not slaughtered alive chickens in DOA 

barrel above each others. two of them were in 

bad condition. I informed Carlos Urieta, the plant 

manager .  the corrective action is taken by 

disarticulation. The establishment needs to 

comply with regulation 9 CFR 381.65). 

Compliance with these requirements helps ensure 

that poultry are treated humanely. In general, 

poultry should be handled in a manner that 

prevents needless injury and suffering in order to 

produce a commercially marketable product. 

Birdsboro Kosher must ensure that all poultry are 

slaughtered according to regulations, This MOI 

will be forwarded to the District Office and the 

District Veterinary Medical Specialist (DVMS) in 

case additional follow up is recommended. 
-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 36 

EstNbr 

M4653A+P 

4653A+V4 

653A 

EstName 

Agri Star Meat and Poultry, LLC 

MOINbr 

HRJ040901 

1216G 

Date 

16JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 1330 I 

observed a poultry employee transferring birds 

from the dead/inedible barrel to the rendering 

belt. Twice, after starting with a full barrel and 

emptying about half the barrel, he removed a live, 

agonal bird. I informed 

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

of 

my observations. They said they would have a 

meeting with poultry kill employees. 

of my observations at the time. At 

approximately 1515 I observed two poultry 

employees emptying dead bird barrels at the end 

of kill. Each, after already removing several layers 

of dead birds, pulled a live bird from the barrel. I 

informed 

(b) (6)
 

-

-

1111 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 37 

EstNbr 

M51302+P 

51302 

EstName 

Belmont Meats LLC 

MOINbr 

YAY121208 

3421G 

Date 

21AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

To: P 51302, Belmont Meats, August 21, 2019. 

In attendance: 

, Mr. Amos 

(b) (6)

King, Plant Manager,

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

 At approximately 0650 hours, when 

going to the slaughter area , I observed the 

following conditions in the live hang area: Two 

employees, 

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

and another employee were unloading 

chickens from the carrier’s crates and placing 

them into the shackles and then stunning and 

bleeding them. As the line of shackles moved 

further forward, around three to four feet, 

chickens were falling from the shackles on to the 

cement floor. On the cement floor, there were 

already approximately ten chickens that were still 

conscious and bleeding. I immediately took 

regulatory control action and stopped operations. 

(b) (6)

then decided to use a funnel 

system mounted in a metal frame, which will 

allow birds to properly bleed and expire. I 

informed 

(b) (6)

and Amos King that the 

PPIA and Agency regulations require that live 

poultry be handled in a manner that is consistent 

with good commercial practices. I notified Mr. 

King that this MOI will be forwarded to the 

District Office and the District Veterinary Medical 

Specialist (DVMS) in case additional follow-up is 

recommended. Respectfully 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 38 

EstNbr EstName MOINbr 

M544+P54 Jennie-O Turkey Store IYW35120 

4 80907G 

Date 

07AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 12:00 pm, while verifying good commercial 

practices out in the live bird holding shelter, I 

observed the following. There were two trailers 

parked outside where they are exposed to direct 

sunlight, and where they would get no benefit of 

air movement from the fans in the shelter. 

Although it is a breezy day, there was very little 

breeze where they were parked.  Inside the shelter 

there were several trailers with live birds on them 

that were parked too far forward, rendering the 

front column of cages exposed to direct sunlight 

and not exposed to any of the air movement from 

the fans in the shelter.  Likewise, some of the rear 

most fans in the shelter were not benefiting any 

of the caged birds, because in those parking bays 

no part of the trailer was parked that far back. 

The birds in the cages that were exposed to 

sunlight were beginning to pant rapidly. Also, 

inside the shelter, approximately the west half of 

the shelter did not have any working misters.  The 

east half misters were working.  There was a deep 

and wide pool of water over the full length of the 

gutter in the shelter that may be an indication 

that the non-functioning misters were because of 

a blown water line somewhere. I brought these 

concerns to the attention of 

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

Within an hour later all trailers 

were out of the sun. 

confirmed that there had been a blown water line, 

causing the pool of water.  He also said that the 

truck drivers are parking so far forward because 

they don't want to be wading in the pool of water 

when they jack up the front of the trailer to pull 

their cab out from under the trailer.] 

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 39 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

M544+P54 

4 

Jennie-O Turkey Store IYW55051 

25927G 

27DEC2019 04C05 Poultry Good 

Commercial 

Practices 

Finalized On 12/26/2019 at 1308 hours while performing 

ante-mortem inspection in the stun and hang area 

I observed the following:  When I walked into the 

area there were 5 awake heavy hens in a 

wheelbarrow.  An establishment employee was 

placing the birds into one of the batters that holds 

about 50 to 60 birds.  I then proceeded to walk to 

the area where the stunned birds are hung on the 

line.  There were 5 batters at the exit of the cage 

washer.  The 3 center batters contained awake 

birds.  The top of these 3 batters the birds were 

soaking wet and shivering.  Mr. Jason Reuss the 

Plant Manager informed me that the CO2 stunner 

on line 2 had a malfunction resulting in the birds 

not being stunned after moving through the 

stunner.  The malfunction was corrected by the 

time I arrived. Mr. Reuss informed me that one of 

the batter of birds had gone through the cage 

wash and had been sprayed by 50 degree 

Fahrenheit water while they were awake because 

the bypass mechanism failed.  He informed me 

that the mechanism was corrected before the rest 

of the awake birds went through the cage wash.  I 

informed Mr. Reuss that I would be writing this 

MOI for failing to protect the awake birds from 

being sprayed in the cage wash. 
• 

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 40 

EstNbr 

M579+P57 

9+V579 

EstName 

Jennie-O Turkey Store 

MOINbr 

UIO100405 

4616G 

Date 

16MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

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

I, was notified by 

at approximately 

5:00 am this morning that the spotter dumped a 

truck containing a load of birds in the yard. When 

I arrived on the scene shortly after, I saw one of 

the trailers containing a full load of Turkeys 

(trailer # 1007) was tipped over and on its right 

side with the tractor up in the air (tires off the 

ground) about 6' in the air. I observed 

approximately 30-40 turkeys on the ground that 

had experienced injuries when the roof panels 

gave way from the top of the truck. I observed 

both injured and non-injured turkeys on the 

ground around the truck. Some turkeys were 

walking around as if nothing happened while 

others had varying degrees of injuries with some 

dead birds observed as well from the accident. 

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

stated that because of the way the 

tractor and trailer were positioned that they 

deemed the area too dangerous for employees to 

enter and address or unload the birds as the 

tractor trailer could shift at anytime and 

potentially injure someone. The establishment 

taped off the area to prevent establishment 

employees and other personnel from entering 

until the area could be made safe for employees 

to enter and deal with the birds and clean-up the 

scene. I observed 

at the site monitoring employee safety.  I was 

informed by 

(b) (6)

that establishment employees 

were not trained to deal with situations like this, 

so, the loading crew and a tow truck company 

were called to come-in and deal with the 

situation. The loading crew was called at 

approximately 5:10 AM.  The tow trucks didn't 

show until approximately 6:30 am.  I observed 

the loading crew personnel start remove some of 

the birds that spilled out from the top row of the 

truck onto the ground after the tow trucks 

arrived. They also cut the front panels and cut the 

(b) (6)
1111 

(b) (4)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 41 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

roof panels and extracted the birds from the top 

row of the truck. Many of the ones that had fallen 

to the bottom had suffocated and were dead at 

time of removal. They were able to save some of 

the birds, but, most observed had died from 

suffocation. At approximately 08:35 AM, I 

observed that the tow trucks had righted the 

truck. I observed loading crew personnel cutting 

coop doors in order to gain access to the birds. 

Many of the birds on the down side of the truck 

had died due to suffocation by birds above. The 

loading crew along with the assistance of plant 

personnel removed all dead birds, which were 

condemned and denatured as required. Any birds 

that were alive were diverted for slaughter.  At 

approximately 9:05 AM the loading crew was still 

working to sort birds (live birds from dead birds). 

The loading crew Supervisor informed me that 

they felt they would be able to transfer the live 

birds using the same trailer involved in the 

accident and would be placing the side panels 

back on the truck to contain the birds, since, the 

coop doors had been cut and removed; to prevent 

further injury to any of the birds during 

movement to the live hang area for slaughter. 

The establishment had addressed all the birds 

involved in the accident and cleaned-up the area 

by the end of 1 shift EVIS operations (12:45 pm). 

I reviewed the establishments GCP paperwork on 

05/15/19 at approximately 12:00 pm and did not 

see any reference or documentation by the 

establishment surrounding the incident.  The 

plant had listed 567 birds as plant 

rejects/condemns from the affected lot with most 

if not all presumed to be coming from the trailer 

of birds involved in this incident. The birds 

involved were Fay 3, Flock # 200696, Lot # 479, 

birds/Lot. A typical truck holds 

approximately 850 to 880 turkeys. Based on this 

information USDA estimates that the 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 42 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

establishment lost a little over 60 % of the birds 

from the trailer due to suffocation or other 

traumatic injuries, with, most of the loss due to 

suffocation. 
-

-

- -

-

-

• 1111 

- 1111 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 43 

EstNbr 

M579+P57 

9+V579 

EstName 

Jennie-O Turkey Store 

MOINbr 

UIO382107 

4919G 

Date 

19JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Friday, July 19th, 2019, temperatures in 

Faribault, MN reached a high of 95 degrees 

Fahrenheit, and the heat index - a measure of how 

hot it feels when relative humidity is accounted 

for - reached at least as high as 112 degrees 

Fahrenheit. The amount of dead-on-arrival (DOA) 

turkeys for all three lots on 1st shift was not 

unusual, and none of those lots exceeded 

(b) (4)

DOA. The number of DOA turkeys was 

abnormally high on 2nd shift.  The first lot on 

2nd shift had

(b) (4)

 DOA (230 DOA turkeys out 

(b) (4)

).  A lot of turkeys on 1st shift from the same 

grower and flock/barn had 

(b) (4)

DOA (20 DOA 

turkeys out of 

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

). The second lot on 2nd shift 

(b) (4)

had DOA (563 DOA turkeys out of ).  A 

lot of turkeys on 1st shift from the same grower 

but a different flock/barn had 

(b) (4)

DOA (2 DOA 

turkeys out of 

(b) (4)

).  A lot of turkeys from 1st shift 

on 7/18/2019 from this same grower but a 

different flock/barn had 

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

DOA (17 DOA 

turkeys out of ). These results indicate that 

the most important determining factor for a high 

percent DOA was the processing shift (2nd shift 

on 7/19/2019) and not other differing factors 

like growers and flocks. Beginning at 

approximately 4:15pm and continuing through 

the end of the shift, at least 10 turkey carcasses 

presented at the USDA inspection stand showing 

signs of a DOA carcass, or cadaver.  These signs 

included diffusely hyperemic (red) skin with 

extensive petechial hemorrhages.  Visceral organs 

were congested with blood, especially the liver 

and spleen.  The vasculature of the intestines and 

hearts were also typically congested with blood. 

These signs indicate a turkey that did not bleed 

out properly.  All had received proper cuts to the 

throat, so it is likely that these 10 were already 

dead some time before they were cut, and they 

should not have been put into production. 

discussed my concerns with 

(b) (6)

I 
-

-

-

-

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 44 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda

 I asked if there were any company 

protocols or practices for coping with such 

extreme heat and humidity.  The cooling shed 

fans and misters were on and fully functional. 

Every turkey I observed in the cooling shed was 

team, which is responsible for collecting turkeys 

at the farm and bringing them to the 

establishment, does not operate when 

temperatures exceed 105 degrees Fahrenheit. 

The turkeys were loaded before conditions 

exceeded this threshold, and it was not expected 

that the conditions would become this extreme. 

reported that the protocol for 

responding to extreme heat is being updated. 

open-mouth breathing, a sign of overheating in 

birds.  I notified that I would be 

documenting a Poultry Good Commercial 

Practices MOI. I spoke with 

who reported that the live-haul 
-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 45 

EstNbr 

M579+P57 

9+V579 

EstName 

Jennie-O Turkey Store 

MOINbr 

UIO101807 

4525G 

Date 

25JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 16:45 hours while observing operations in the 

live hang area, I observed large gaps in the line of 

turkeys along with numerous injuries to the 

turkeys, and there was also an abnormal amount 

of blood on many of the turkeys.  This 

presentation is typical when there has been a clog 

of turkeys somewhere in the CO2 stunning 

system.  I observed 10 turkeys with fresh injuries. 

Five of the injured turkeys had torn-skin injuries 

over the hips, back and shoulders ranging in size 

from approximately 2 x 4 inches to 4 x 6 inches. 

One of the injured turkey had an approximately 4 

x 4 inch torn-skin injury over its left breast just 

lateral to midline.  Four of the injured turkeys 

were injured on the lateral aspect of their left 

legs.  One of these four had torn skin, mutilation 

of underlying muscle and an exposed femur.  Two 

had torn skin and muscle mutilation, and the 

fourth still had intact skin on the lateral aspect of 

its left leg, but it had a large patch of bright red 

skin extending from the hock, up the drum and 

over the left hip and thigh.  All feathers were 

missing from this patch.  These injuries are typical 

for a clog of turkeys in the CO2 system. I 

confirmed with an establishment employee that 

such a clog had occurred. In addition, I observed 

a length of fresh-looking small intestine draped 

over the shackle of a turkey.  The turkey in this 

shackle was intact, and I did not find the 

damaged turkey to which the intestine belonged, 

but its presence suggests that a turkey was 

eviscerated. Similar incidents have occurred 

recently.  Near the start of 2nd shift on both July 

9th and on June 18th, there were 

establishment-confirmed clogs in the CO2 system 

with resulting injuries to turkeys.  The causes of 

these clogs were not established. I 

notified 

(b) (6)

that I was 

documenting the incident in a Poultry Good 

Commercial Practices MOI. 

(b) (6)

reported 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 46 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

that a turkey's leg had become stuck in the 

conveyor system.  This stuck turkey caused the 

clog that resulted in the injuries reported here. 
1111 

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 47 

EstNbr 

M579+P57 

9+V579 

EstName 

Jennie-O Turkey Store 

MOINbr 

UIO342112 

0610G 

Date 

10DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

This GCP MOI documents acute injuries observed 

in the live-hang/bleed-out room on 12/03/2019, 

12/06/2019 and 12/09/2019.  Most injuries here 

described share certain characteristics: torn skin 

from the turkeys’ backs – extending on (or just 

lateral to) the dorsal midline anywhere between 

the base of the neck and the base of the tail; 

moist, fresh appearance to the torn skin and 

exposed underlying tissues; no evidence of old 

injuries (scabs, dried tissues).  There were no 

significant gaps in the line during these incidents. 

On 12/03/2019, beginning at 8:35pm, I observed 

three consecutive turkeys on the line with torn 

skin injuries ranging in size from approximately 4 

x 2 inches to 4 x 4 inches.  Shortly thereafter I 

observed a fourth turkey with a torn skin injury 

over its right shoulder that was approximately 4 x 

2 inches.  At approximately 8:38 pm, I observed a 

fifth turkey with a torn skin injury extending from 

its shoulders down its back that was 

approximately 4 x 8 inches.  I observed some of 

these injuries with 

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

who said he would inspect the CO2 tunnel 

conveyor system. On 12/06/2019, between 

3:40pm and 3:50pm, I observed 4 turkeys with 

torn skin injuries.  All four injuries were over the 

hips to mid-back and ranged in size from 

approximately 4 x 4 inches to 4 x 6 inches.  I later 

spoke with 

about my observations and informed him that I 

would be documenting a GCP MOI.  I also spoke 

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

with about my 

observations.  I spent time with 

(b) (6)

in the live-hang area looking at injuries 

on the turkeys.  While we did observe injuries at 

this time, we did not find any injuries that weren’t 

associated with an obvious scratch injury or old 

scabs. On 12/09/2019, between 2:44pm and 

2:49pm, I observed 4 turkeys with torn skin 

injuries.  The first turkey’s injury extended from its 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 48 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

shoulders down its back, and it was 

approximately 6 x 4 inches.  The second turkey’s 

injury was approximately 4 x 4 inches in size over 

the mid-back.  Both of the initial two injuries also 

included damage to underlying exposed muscle 

tissue.  The third turkey had an approximately 4 x 

2-inch injury near dorsal midline over the left 

thigh, and the fourth turkey and an approximately 

3 x 3-inch injury over its dorsal midline at the level 

of the hips. 
 

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 49 

EstNbr 

M5842+P5 

842+V5842 

EstName 

Tyson Foods, Inc. 

MOINbr 

NPF36210 

54704G 

Date 

04MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

GCP Poultry Mistreatment MOI Day, Date and 

Time of Meeting: Saturday May 4, 2019 from 

approximately 2025 until 2100 Place Meeting 

Held: Est. M5842 Evisceration GPM office 

Persons Attending: FSIS Attendees -

Tyson Foods Attendees 

Author(s) of this Meeting Report

 Date this Meeting Report was 

Written: Saturday May 4, 2019  Subject: GCP 

Poultry Mistreatment MOI. Background 

concerning this Poultry Good Commercial Practice 

(GCP) Non-Regulatory Issue: On Saturday May 4, 

2019, from 1947 to 1958 CST, I performed a 

station 1 Poultry Good Commercial Practices 

(GCP) PHIS task by observing carcasses entering 

the first scald tank on kill line 1 in the picking 

room. At 1950 during the check, I observed 1 live 

bird that had no cut on its neck, was conscious, 

eyes open, neck curved upward, looking around, 

and alert. This was a significantly smaller than 

average for the lot, young chicken. I removed this 

live bird from kill line 2 at 1950, immediately 

before the bird would have entered the first scald 

tank on kill line 1 and placed this young chicken 

on the ground where it sat upright, eyes open, 

and looking around. At this time, I noted that this 

bird was dry and had not been stunned.  I got the 

attention of the picking room attendant who 

requested 

be called to the picking room then resumed the 

station 1 check.  This check was completed at 

1958 with no more live birds observed. 

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

(b) (6)

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

arrived on 

the scene at approximately 1952 and was shown 

this 1 live young chicken. He then took this live 

young chicken back to the live hang room.  At 

1959 CST, there was 2 backup harvesters, each 

covering one kill line. 

(b) (6)

then 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 50 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

performed a GCP Station 1 follow up check #1 on 

kill line 2 from 2001 to 2010 with no more live 

birds observed. performed 

follow up check #2 on kill line 1 from 2011 to 

2021 and observed no live birds. No GCP NCs or 

non-regulatory concerns were observed during 

these 2 follow up checks. Discussion notes for 

the meeting with Plant management on Friday 

April 5, 2019 from 1508 to 1530 concerning this 

GCP poultry mistreatment incident: I met with 

already been informed of this incident. During this 

meeting I described my observations concerning 

this incident as outlined above. I then told 

that due to the results of the 2 follow up 

checks on 5/4/19 (see above) the 1 live bird I had 

observed and removed from kill line 2 at 0748 

before it entered the first scald tank during the 

GCP check that day was deemed by IPP to be an 

isolated incident and not a loss of plant killing 

process control. Thus, IPP will issue a Poultry 

Mistreatment MOI in lieu of a GCP NR concerning 

this incident as per guidance in FSIS Directive 

6110.1 dated 7/3/2018. 

both stated they are working on plans to 

make identification of significantly undersized and 

un-stunned birds easier.  They stated they would 

keep IPP informed on the progress of these plans. 

establishmen

 in the SPHV’s office 

from 2025 to 2100 on Saturday May 4, 2019. We 

were joined by 

at approximately 2040.  -

informed me that he and had 

- ■ 

-

(b) (6)

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 51 

EstNbr 

M5842+P5 

842+V5842 

EstName 

Tyson Foods, Inc. 

MOINbr 

NPF55180 

72301G 

Date 

01JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Poultry Good Commercial Practice MOI Day, 

Date and Time of Meeting: Monday July 1, 2019, 

from approximately 1513 until 1516 and 

1525-1530. Place Meeting Held: Est. M5842 Live 

hang area and Evisceration GPM office, 

respectively Persons Attending: FSIS 

(b) (6)

Attendee – 

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

Attendee - . Tyson Foods 

. Author(s) of this Meeting 

Report: Date this Meeting 

Report was Written:  Monday, July 1, 2019 

Subject: Poultry Good Commercial Practice MOI. 

Background concerning this Poultry Good 

Commercial Practice (GCP) Non-Regulatory Issue: 

On Monday July 1, 2019 from 1500 to 1509 hours 

CST, I performed a station 1 Poultry Good 

Commercial Practices (GCP) PHIS task by 

observing carcasses entering the first scald tank 

on kill line 1 in the picking room. At 1509 during 

the check, I observed 1 bird that entered the 

pre-scald area after the backup head puller that 

was moving vigorously.  Closer examination 

determined that the head was still attached, and 

the eyes were open.  This was a significantly 

smaller than average for the lot, young chicken. I 

removed this live bird from kill line 2 at 1509, 

immediately before the bird would have entered 

the first scald tank on kill line 1 and placed this 

young chicken on the ground where it continued 

flapping and was breathing and both eyes were 

open. This bird did have a neck cut, but no jugular 

veins or carotid arteries were noted to be cut at 

this time.  I continued my station 1 GCP check and 

no more live birds were seen on line 1. I then 

took this chicken to the live hang room and had 

paged to 

the area. 

arrived in the live hang 

room at 1513.  By this time, the chicken had 

died. 

(b) (6)

examined the cut and took the 

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

(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 52 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

chicken to his office.  At 1510 hours CST, there 

was 1 backup harvester, covering both kill lines. I 

performed a GCP Station 1 follow up check #1 on 

kill line 2 from 1607 to 1622 with no more live 

birds observed. performed 

follow up check #2 on kill line 1 from 1626 to 

1636 and observed no live birds. No GCP NCs or 

non-regulatory concerns were observed during 

these 2 follow up checks. Discussion notes for 

the meetings with Plant management on Monday 

July 1, 2019 between 1513 and 1530 hours CST 

concerning this poultry good commercial 

practices incident: I met with establishment

 in the live hang room from 

(b) (6)

1513-1516 hours CST and again from 1525-1530 

hours CST in the evisceration GPM office on 

Monday July 1, 2019.  During this meeting I 

described my observations concerning this 

incident as outlined above. He and I examined the 

cut on the neck of the bird and only 1 jugular vein 

had been cut.  I then told 

(b) (6)

that pending 

the results of 2 follow up checks on 7/1/19 (see 

above) the 1 live bird I had observed and removed 

from kill line 1 at 1509 before it entered the first 

scald tank during the GCP check that day would 

be deemed by IPP to be an isolated incident and 

not a loss of plant killing process control. Thus, 

IPP will issue a Poultry Mistreatment MOI in lieu 

of a GCP non-compliance record concerning this 

incident as per guidance in FSIS Directive 6110.1 

dated 7/3/2018. 
■ 

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 53 

EstNbr 

M5842+P5 

842+V5842 

EstName 

Tyson Foods, Inc. 

MOINbr 

NPF04220 

90027G 

Date 

27SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Open 

MOI Agenda 

GCP Poultry Mistreatment MOI Day, Date and 

Time of Meeting: Friday September 27, 2019 from 

approximately 2135 until 2145 Place Meeting 

Held: Est. M5842 Live Receiving area Persons 

Attending: FSIS Attendees 

. Tyson Foods Attendees -

Author(s) 

of this Meeting Report: Date 

(b) (6)

(b) (6)

(b) (6)

(b) (6)

this Meeting Report was Written: Friday 

September 27, 2019 Subject: GCP Poultry 

Mistreatment MOI. Background concerning this 

Poultry Good Commercial Practice (GCP) NonRegulatory Issue: On Friday September 27, 2019, 

from 2118 to 2129 CST, I performed a station 1 

Poultry Good Commercial Practices (GCP) PHIS 

task by observing carcasses entering the first scald 

tank on kill line 2 in the picking room. At 2123 

during the check, I observed 1 live bird that had 

no cut on its neck, was conscious, eyes open, neck 

curved upward, looking around, and alert. This 

was a slightly smaller than average for the lot, 

young chicken. I removed this live bird from kill 

line 2 at 2123, immediately before the bird 

would have entered the first scald tank on kill line 

2 and placed this young chicken on the ground 

where it sat upright, eyes open, and looking 

around. I completed my observation of 1000 

birds entering the first scald tank on kill line 2 

with no more live birds observed.  At 2129 after 

the check was finished, I got the attention of the 

picking room attendant who requested 

be called to the 

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

picking room. , shift 2 

arrived on the scene at 

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

approximately 2130 and was shown this 1 live 

young chicken. He then took this live young 

chicken back to the live hang room. At 2130 CST, 

there were 2 backup harvesters, each covering 

one kill line.  I observed the stun and kill process 
- ■ 

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 54 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

and noted no abnormalities on either line. 

Discussion notes for the meeting with Plant 

management on Friday September 27, 2019 

from 2135 to 2145 concerning this GCP poultry 

mistreatment incident: I met with establishment 

n the live receiving area from 2135 to 

(b) (6)

2145 on Friday September 27, 2019. During this 

meeting I described my observations concerning 

this incident as outlined above. I then told 

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

that due to the results of observation of 

the stunning process, the 1 live bird I had 

observed and removed from kill line 2 at 2123 

before it entered the first scald tank during the 

GCP check that day was deemed by IPP to be an 

isolated incident and not a loss of plant killing 

process control. Thus, IPP will issue a Poultry 

Mistreatment MOI in lieu of a GCP NR concerning 

this incident as per guidance in FSIS Directive 

6110.1 dated 7/3/2018 

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

both stated they will observe the stunners 

and make the needed adjustments. They also 

stated they would keep IPP informed on the 

progress of these plans 
--

- -

- ■ 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 55 

EstNbr 

M5842+P5 

842+V5842 

EstName 

Tyson Foods, Inc. 

MOINbr 

NPF52181 

20912G 

Date 

12DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

GCP Good Commercial Practice MOI Day, Date 

and Time of Meeting: Thursday 12/12/2019 from 

approximately 1224 to 1228 with 

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

, 

1240-1250 with , and 1420-1425 

and 1505-1515 with Hunter Wray (CST) Place 

Meeting Held: Est. M5842 Picking Room

(b) (6)

 rehang area 

(b) (6)

plant manager’s 

office and SPHV office (Wray) Persons Attending: 

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

(b) (6)

(b) (6)

FSIS Attendees - . Tyson 

Foods Attendees – Hunter Wray, PM; 

of this Meeting Report: Date 

this Meeting Report was Written: Thursday 

12/12/2019 Subject: GCP Good Commercial 

Practice MOI. Background concerning this Poultry 

Good Commercial Practice (GCP) Non-Regulatory 

Issue: On Thursday December 12, 2019 from 

1213 to 1224 CST, I performed a station 1 Poultry 

Good Commercial Practices (GCP) PHIS task by 

observing carcasses entering the first scald tank 

on kill line 2 in the picking room. At 1219 during 

the check, I observed 1 live bird that had no cut 

on its neck, was conscious, eyes open, neck 

curved upward, looking around, and alert. This 

was a smaller than average for the lot, young 

chicken. I removed this live bird from kill line 2 at 

2123, immediately before the bird would have 

entered the first scald tank on kill line 2 and gave 

it to 

(b) (6)

who was 

present for this check.  At this time, I noted that 

this bird was dry and had not been stunned. 

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

then took this live young chicken back to 

the live hang room.  I completed my observation 

of an additional 500 birds entering the first scald 

tank on kill line 2 with no more live birds 

observed.  During the entire check I did note that 

the bird size was very variable at this time.  In 

addition, numerous birds were small enough to 

miss the head pulling equipment.  At 1224 after 
-

-

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 56 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

the check was finished, I spoke with 

and asked him if he saw any evidence of a cut on 

the neck of that chicken.  He stated he did not. 

During this check line 1 was not operational.  At 

1225 CST, there were 2 backup harvesters, both 

covering kill line 2.  I observed the stun and kill 

process and noted several birds small enough to 

miss the stun process and automatic knife.  No 

live chickens made it past the backup killers 

during this observation. Discussion notes for the 

meeting with Plant management on Thursday 

December 12,2019 between 1224 and 1515 hrs 

concerning this GCP incident: I met with 

stunning process and the 2nd 500 carcasses just 

prior to the first scald tank, the 1 live bird I had 

observed and removed from kill line 2 at 1219 

before it entered the first scald tank during the 

GCP check that day was deemed to be an isolated 

incident and not a loss of plant killing process 

control. Thus, I will issue a Poultry Good 

Commercial Practice MOI in lieu of a GCP NR 

concerning this incident as per guidance in FSIS 

Directive 6110.1 dated 7/3/2018.  I then met with 

Plant Manager Hunter Wray at approximately 

1420.  I made sure he had been made aware of 

the above incident.  He stated he had.  After this 

meeting, we met again in the SPHV office at about 

1505.  At this time, he stated they were 

investigating the root cause of the incident and 

would let IPP know the results of the 

investigation. 

in the rehang 

area from 1240-1245.  During this meeting I 

described my observations concerning this 

incident as outlined above. I then told 

that due to the results of observation of the 
- I 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 57 

EstNbr 

M7100+P7 

100+V7100 

EstName 

Tyson Foods, Inc. 

MOINbr 

ZHB53060 

13510G 

Date 

10JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

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

January 09, 2020, 0835 hours, In attendance: (b) (6)

(b) (6)

At approximately 0835 hours, while performing a 

Poultry Good Commercial Practice task, (b) (6)

.

(b) (6)

 and I walked outside from back dock. 

Upon my verification I noticed a live bird, having a 

coating of denaturant, sitting among carcasses in 

the establishment’s dead-on-arrival (DOA) bin. We 

determined this is mistreatment because the DOA 

bin is reserved for birds arriving to the 

establishment already deceased. I was instructed 

by my Supervisor to remove the live bird from the 

bin and hold until management was notified 

(b) (6)

and I immediately notified 

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

as he was shown 

and given the bird to put back into production. 

We also discussed this incident in the 

establishment’s weekly meeting. If we had not 

observed the bird, it could have perished 

inhumanely in the offal. FSIS Directive 

6110.1 – Verification of Poultry Good Commercial 

Practices The regulations 9 CFR 381.65(b) 

requires that poultry be slaughtered in 

accordance with GCP. Poultry are to be 

slaughtered in a manner that ensures that 

breathing has stopped before scalding, so that the 

birds do not drown, and that slaughter results in 

thorough bleeding of the poultry carcass. 

Compliance with these requirements helps ensure 

that poultry are treated humanely. In general, 

poultry should be handled in a manner that 

prevents needless injury and suffering in order to 

produce a commercially marketable product. 

Respectfully, 

(b) (6)

of OFO 

07100P Tyson Foods of Nashville, AR 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 58 

EstNbr EstName MOINbr 

M737+P73 House of Raeford - Wallace Div DHA50080 

7 84314G 

Date 

14AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

0553 – While performing a Good Commercial 

Practice Task on Line 2, I observed a live bird that 

had no cut on its neck and was alert, eyes open 

and controlled movement of its head with 

rhythmic breathing enter the scalder.  The 

establishment has backup employees on both 

lines prior to the scalders to prevent any live birds 

from entering the scalder.  The backup employee 

that was located just before the scalder on line 2 

did not stop the line or remove the bird from the 

line to prevent the bird from enter the scalder 

alive.  I stopped the line once I observed that the 

backup employee did not take any action and had 

the backup employee remove the bird which by 

now had its head under the water of the scalder 

and was flapping its wings.  When the backup 

person pulled the bird out of the scalder, she cut 

the birds neck and proceeded to put it back into 

the scalder.  I had her remove it from the line 

instead of putting it back into the scalder. Had 

the bird not been removed, it would have died 

from means other than slaughter. 

were notified of the 

(b) (6)

(b) (6)

Good Commercial Practice MOI. 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 59 

EstNbr EstName MOINbr 

M737+P73 House of Raeford - Wallace Div DHA16051 

7 02923G 

Date 

23OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 0530 while performing a Good 

Commercial Practice Task on Line 1, I observed a 

live bird that had no cut on its neck and was alert, 

eyes open and controlled movement of its head 

with rhythmic breathing heading for the scalder. 

The establishment has backup employees on both 

lines prior to the scalders to prevent any live birds 

from entering the scalder.  The backup employee 

that was located just before the scalder on Line 1 

failed to take action to prevent the live bird from 

enter the scalder alive.  When I observed the bird 

about to enter the scalder, I moved toward the 

line to stop it.  The backup employee saw me 

moving toward the stop button and saying stop 

and she stopped the line at that time.  At this time 

the backup person and I began looking for the 

bird and the backup employee removed the live 

bird from the line which was in the scalder when 

it was located.  When the backup person pulled 

the bird out of the scalder, it had no cut on its 

neck and was alert, eyes open and controlled 

movement of its head with rhythmic breathing. 

Had the bird not been removed, it would have 

died from means other than slaughter 

were notified of the Good 

(b) (6)

(b) (6)

Commercial Practice MOI. 
-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 60 

EstNbr EstName MOINbr 

M737+P73 House of Raeford - Wallace Div DHA42060 

7 12231G 

Date 

31JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 0634 while performing Good 

Commercial Practices on Line 1, I observed a live 

bird uncut with open eyes, breathing, righting his 

head on its way into the scalder.  The 

establishment has a backup employee prior to 

this point and a second one just before the scalder 

to prevent any live birds from entering.  The 

backup employee was crouched against the wall 

dozing when I started my task, he rose and 

approached the scalder but missed the 

opportunity to take action and prevent the live 

bird from entering the scalder alive.  When I 

observed the bird about to enter the scalder I 

pointed and called to the man and said that there 

was an uncut bird.  He said he didn’t understand 

what I was saying and the bird went into the 

scalder. He said, “My fault I didn’t hear you”.  At 

0630 while performing my Leukosis check I 

notified a Lead that the 2nd back up killer on Line 

1 was crouched against the wall dozing, she called 

(b) (6) . 

When I finished my check and went back to the 

Line 1 scalder was when I saw the live bird come 

down and tried to get the associate’s attention. 

Once 

(b) (6)

arrived to the area she observed 1 

or 2 live birds coming down the line over the 

course of a couple of minutes and alerted the 

backup killer to stop the line as he did not notice 

on his own. Birds should be slaughtered in a 

manner that results in thorough bleeding of the 

carcass in accordance with FSIS Directive 6110.1. 
-

■ 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 61 

EstNbr EstName MOINbr 

M737+P73 House of Raeford - Wallace Div DHA12090 

7 20103G 

Date 

03FEB2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

During the performance of an SSOP task at 

approximately 0834 I observed 

(b) (6)

remove a cadaver from Line 1. She showed it to 

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

me and I passed it on to , 

notifying her that it was a 

cadaver not a DOA. conveyed to me 

she had pulled off 3 birds this morning prior to my 

starting at this assignment. I observed at the 

rehang tables and observed the associate 

struggling to keep up with removing cadavers. 

There were several cadavers in her barrel on Line 

1 indicating a trend. When I went through the kill 

room I did not find that the back up killers missed 

any birds that would cause them to enter the 

scalder alive. The establishment started running 

bpm on this line today, I notified 

took 

regulatory control and reduced the line speed to

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

 bpm. 

(b) (6)

stated that she would 

address the back up killers. Birds should be 

slaughtered in a manner that results in thorough 

bleeding of the carcass in accordance with FSIS 

Directive 6110.1. The last GCP MOI was received 

on 1/31/2020. 
-

470 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 62 

EstNbr 

M7470+P7 

EstName 

Mountaire Farms Inc. - NC Division 

MOINbr 

YRA460604 

5029G 

Date 

29APR2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

April 26, 2019, at approximately 0715 hours, on 

my way, while performing ante-mortem 

inspection in the receiving area, I observed a live 

bird in the dead-on-arrival (DOA) container. The 

bird was underneath several other birds, but I 

could see the breast area of the bird rising and 

falling with each breath. I verbally notified the 

plant’s 

of my findings and she notified the 

The DOA

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

(b) (6)

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

container was retained by . The 

bird was removed from container by 

As the bird was 

being removed from the container, its wings 

began to flap. At that time, the bird was positively 

identified as a live bird. 

(b) (6)

arrived in the 

receiving area and took corrective action by 

having the remaining birds in the DOA container 

dumped out onto the pavement. I did not observe 

any other living birds in the container. Had this 

bird remained in the condition it was found; it 

would have been smothered to death and 

therefore died by means other than by slaughter. I 

notified 

of the plants failure to comply with 9 CFR 

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

381.65 (b) and I would be issuing a Memorandum 

of Interview (MOI) for failure to follow good 

commercial practices. The PPIA and Agency 

regulations require that live poultry be handled in 

a manner that is consistent with good commercial 

practices and live poultry should not die of causes 

other than by slaughter. The Federal Register on 

Treatment of Live Poultry before Slaughter gives 

recommendations on how to prevent these 

occurrences. A copy of this MOI has been 

forwarded to the District Veterinary Medical 

Specialist (DVMS) in the event further action is 

recommended. I certify that this MOI includes all 
-

470 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 63 

EstNbr 

M7470+P7 

EstName 

Mountaire Farms Inc. - NC Division 

MOINbr 

YRA350908 

0407G 

Date 

07AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

pertinent matters discussed concerning this 

incident and is true to the best of my knowledge. 

of the situation and that the 

bird in question must be removed from the area 

to prevent it being run over

(b) (6)

 radioed for 

help in my presence to have the bird removed. I 

also notified him that I would be issuing a MOI 

due to the plants failure to adhere to good 

commercial practices. At approximately 0920 

hours I visually inspected bay 13 and verified that 

the bird had been removed. Had the bird not 

been removed it would have likely been run over 

and died by means other than by slaughter. 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 for causes other than by slaughter. The 

Federal Register on Treatment of Live Poultry 

before Slaughter gives recommendations on how 

to prevent these occurrences. A copy of this MOI 

has been forwarded to the District Veterinary 

Medical Specialist (DVMS) in the event further 

action is recommended. I certify that this MOI 

includes all pertinent matters discussed 

concerning this incident and is true to the best of 

my knowledge. 

On Wednesday, August 7, 2019, at approximately 

0904 hours, while performing ante mortem 

inspection at the live bird holding shed, I noticed a 

solitary chicken located on the floor of bay 13. 

The bird was sitting up and was alert but did not 

attempt to move when I approached it. It was in 

an area where it could likely be run over if not 

promptly removed. There were no supervisors in 

the immediate area, so I proceeded to the Live 

Hang area and at approximately 0905 hours 

notified

(b) (6)
49 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 64 

EstNbr 

M751+P10 

EstName 

Pitman Farms Inc. (Moroni Turkey Processing) 

MOINbr 

MMK1115 

090604G 

Date 

04SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

of my 

observations regarding injuries to the live birds 

and concerns regarding humane methods of 

handling and slaughtering that are not consistent 

with good commercial practices. 

On Wednesday September 4, 2019 during 

ante-mortem inspection at approximately 0600 

hours, I, 

(b) (6)

, observed injuries to 

the birds.  I observed one tom on trailer number 

98 with a severe open fracture at the right elbow. 

I observed the joint and bone to be completely 

exposed.  The tom was still alive but appeared to 

have lost blood and developed an 8 cm 

hematoma in that wing.  I observed the tom was 

breathing shallowly and appeared to be in shock. 

Trailer number 98 cannot be loaded using the 

auto-loader but must be loaded manually. Trailer 

number 98 is one of the last trailers scheduled to 

be processed today (approximately nine hours 

from the time of my observations).  I also 

observed one dead hen with a bloody wing on 

trailer number 99 and one hen with a foot 

trapped under a cage door on trailer number 82. 

I informed 

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 65 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

M751+P10 Pitman Farms Inc. (Moroni Turkey Processing) MMK1615 04SEP2019 04C05 Poultry Good Finalized 

49 094604G Commercial 

Practices 

On August 29, 2019 at approximately 1000 hours 

were directly observing 

(b) (6)

conditions of live birds in cages on trailers.  There 

were two trailers staged at the live receiving 

unloading dock with cages that were overcrowded 

(there were so many birds in the cages that there 

was not enough space within the cage for the 

birds to lie down without lying on top of each 

other), approximately 90% of the birds (toms) on 

the trailers were displaying signs of heat stress by 

open mouth breathing/panting and the trailers 

did not have any fans, misters or any source of 

ventilation for the birds as required per the 

establishments written Standard Operating 

Procedures (SOP).  In the trailer holding shed area 

there were two trailers that were completely out 

of the shed without any shade, fans, misters or 

ventilation source.  There was a third trailer that 

had half of it directly exposed and facing the sun, 

without shade, fans, or misters.  Several other 

trailers in the holding shed only had one side 

exposed to fans or misters.  All the trailers were 

overcrowded with approximately 90% of the birds 

showing signs of heat stress, panting/open mouth 

breathing.  At that time of these observations it 

was approximately 90 degrees outside with the 

sun shining fully and no clouds in the sky. There 

were multiple trailers that contained birds with 

injured, hemorrhagic wings, some that were 

trapped in cages.  Multiple trailers had birds with 

legs trapped in cage bars that were injured and 

could not be retracted. On August 30, 2019 at 

approximately 0550 hours I, 

(b) (6) , 

observed the seven (7) trailers of live toms held 

over from August 29, 2019.  The establishment 

put the trailers in the trailer shed overnight and 

left the fans and misters running.  It was 
-

(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 66 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

approximately 55 degrees when I performed good 

commercial practice observations. The toms on 

the outer edges of the trailers with the misters 

were dripping wet and shivering.  I observed one 

dead tom on trailer number 79 with a bloody 

wing.  I observed an increased amount of diarrhea 

from the toms. Four trailers of hens had already 

arrived on the morning of August 30th, 2019.  The 

hens appeared overcrowded (as the birds were 

stacked in multiple layers on top of each other 

without enough space to lie down in a single 

layer) on trailer numbers 91 and 11. Two of the 

hen trailers (91 and 11) were parked at the end of 

the trailer shed where there are no fans or 

regarding the live birds at the weekly meeting 

held at 9 am on August 30th, 2019. 

misters, these two trailers are scheduled to be 

processed last today. I informed and 

Jaime Rodriguez of my observations and concerns 
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49 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 67 

EstNbr 

M751+P10 

EstName 

Pitman Farms Inc. (Moroni Turkey Processing) 

MOINbr 

MMK3916 

095511G 

Date 

11SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Tuesday, September 10th, 2019, during 

ante-mortem inspection at approximately 0545 

hours, I, 

(b) (6)

, observed 

multiple injured and dead birds.  On trailer 99, I 

observed one tom with a bloody injured wing.  On 

trailer 59, I observed one tom whose wing had 

been trapped underneath a closed cage door.  The 

wing was bent at an odd angle at the carpus joint 

where the cage door had been closed on it.  I 

observed a second tom in this trailer with a 

bloody wing.  In trailer 80 I observed one dead 

hen.  In trailer 79, I observed a hen trapped in a 

closed cage door.  The cage door had been closed 

on her neck so that her neck was caught between 

the side of the cage and the side of the cage door. 

There was regurgitation on her beak and in her 

mouth.  She was gasping for breath, her 

respiration was rattly, and her eyes were closed. 

There was fresh bruising on her neck where the 

cage door was closed on it.  One wing was bloody 

on the edge where the hen had beat it against the 

cage door while trying to pull back.  I was able to 

free the hen and she was still alive at the time, but 

due to her poor condition and rattling respiration 

I doubt she will survive until slaughter.  On trailer 

81, I observed one hen with a full thickness 

ulceration of the skin over the breast covering an 

area approximately 7 x 5 cm.  The serosal layer of 

the crop was exposed.  On trailer 11, I observed 

one dead tom and one tom that was stuck on his 

side and unable to right himself.  His wings had 

fresh bruising from struggling.  At approximately 

0735 hours, I informed 

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

of my observations 

regarding injuries to the live birds and concerns 

regarding humane methods of handling and 

slaughtering that are not consistent with good 

commercial practices. 

(b) (6)

said that he would 

forward the MOI about these issues to the live 

haul crew. 
49 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 68 

EstNbr 

M751+P10 

EstName 

Pitman Farms Inc. (Moroni Turkey Processing) 

MOINbr 

MMK1114 

095313G 

Date 

13SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Friday, September 13th, 2019, during 

ante-mortem inspection at approximately 0600 

hours, I, 

(b) (6)

, observed 

two birds with body parts trapped in the cages 

they were placed in for transport to the slaughter 

plant. On trailer 94, I observed a dead tom turkey 

whose head was trapped between the bottom of 

the cage above his and a metal support beam 

used to support the cage bottom.  The weight of 

the turkeys in the cage above had likely resulted 

in suffocation.  On trailer 11, I observed a tom 

whose wing was trapped at the base of the 

primary feathers between the bottom of the cage 

above his and metal support beam used to 

support the cage bottom. I am concerned that 

when the live hang crew remove this tom from 

the cage his wing will be broken due to the way it 

is trapped.  At approximately 0710 hours, I 

discussed my observations with Jaime Rodriguez, 

Plant Manager, regarding injuries to the live birds 

and concerns regarding humane methods of 

handling and slaughtering that are not consistent 

with good commercial practices.  Jaime Rodriguez 

said that the establishment has been working on 

issues such as cage doors closed on birds with the 

live haul crew. 
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49 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 69 

EstNbr 

M751+P10 

EstName 

Pitman Farms Inc. (Moroni Turkey Processing) 

MOINbr 

MMK1314 

115101G 

Date 

01NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Memorandum of Interview to Discuss Birds Held 

Over for Slaughter Norbest Turkey / Est# P01049 

Meeting Time: Friday, November 1, 2019 at 1245 

Attendees: 

USDA 

Establishment 

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

This meeting was necessitated by observations 

made while performing a Good Commercial 

Practices task each day for the week of October 

28, 2019. The establishment protocol concerning 

live birds held over is documented in both their 

Animal Welfare Program and also SOP #307 Live 

Bird Holdover.  The written procedure pertains to 

an unscheduled live bird holdover and “is in 

conjunction with applicable best industry 

practices, notably National Turkey Federation 

(NTF) Animal Care Best management Practices, 

2012.”  Monday Holdover (approx. 1,000 birds) 

A partial trailer load of hens (truck #80) was held 

over from Monday afternoon to Tuesday 

morning.  According to 

(b) (6)

the holdover 

was attributed to both to mechanical issues (stuck 

shackle issue and head conveyor) as well as line 

speed reductions due to feed.  As was discussed 

previously in other MOI to document birds held 

over, it is not a good practice nor is it in the 

establishment’s interest to leave birds in public 

view outside the plant at night.  This 

memorandum serves to document what was 

discussed and also provide the Denver district 

office with information concerning the operations 

being conducted at this establishment.  A copy of 

this memorandum of interview was provided to 

establishment management, and the signed 

original will be placed in the USDA files 

(b) (6) (b) (6)
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49 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 70 

EstNbr 

M751+P10 

EstName 

Pitman Farms Inc. (Moroni Turkey Processing) 

MOINbr 

MMK2713 

114208G 

Date 

08NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Memorandum of Interview to Discuss Broken 

Wings Pitman Farms / Est# P01049 Meeting 

Time: Friday, November 8, 2019 at 0845 

Attendees: 

USDA 

Establishment 

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

Mr, Jaime Rodriguez, Plant 

Manager This meeting was necessitated by 

observations made while performing a Good 

Commercial Practices task on Friday, November 8, 

2019.  After performing antemortem inspection 

on flocks delivered this morning for slaughter,(b) (6 (b) (6)

 reported she had observed 

several bloody birds but one, in particular, on 

trailer 74 which appeared to have its “wing 

completely pulled out socket joint bone 

completely exposed.”  At approx. 0540, I visited 

the hanging bay and found the particular bird she 

had observed in trailer 74.  After it was hung on 

shackles I could confirm the wing was broken and 

the humerus was exposed for most of its length. 

I then performed a check of 100 carcasses passing 

between the pickers and the rehang table and 

counted 15 which had broken wings with 

evidence of acute injury.  Even though it is a more 

difficult location to assess wings, I also performed 

a 100 bird check as they passed the bleeder and 

counted 10 with broken wings.  On the 

production floor, I observed a trimmer cutting off 

broken wings at the trim station and discarding 

them into an inedible barrel. 

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

was present and noted he was 

performing an audit of the wings and reported he 

had found 11 carcasses with broken wings in his 

audit of 100 carcasses.  At 0845, I met with 

Jaime Rodriguez, Plant Manager, to share these 

findings with him.  We discussed the importance 

of the good commercial practices and their 

inclusion in the company’s animal welfare 

program as well as the obvious economic impact 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 71 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

on the company that the wings represented.  The 

observations made today indicate the problem is 

occurring prior to the birds arriving at the plant 

and probably at the time they are loaded into the 

coops.  The handling of the birds during unloading 

at the plant was observed to be proper and was 

not the cause of the broken wings.  Jaime will 

verify the trim counts from production and notify 

his auditor who has oversight of the contracted 

catch crews working at the farms.  All birds and 

. This memorandum 

serves to document what was discussed and also 

commercial practices being employed at this 

establishment as stipulated in FSIS Directive 

6100.3, Ante-Mortem and Post-Mortem Poultry 

Inspection.  A copy of this Memorandum of 

Interview was provided to establishment 

placed in the USDA files. 

trucks for today’s production originated from one 

producer, 

provide

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

and the Denver district management 

team with information concerning the good 

management, and the signed original will be 
-

325 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 72 

EstNbr 

M9977+P1 

EstName 

Tyson Foods Inc. 

MOINbr 

YBL140504 

1423G 

Date 

23APR2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On 23 April 2019 at P1325, Tyson Foods Inc., at 

approximately 0445 hrs while performing a 

routine Poultry Good Commercial Practices (GCP) 

verification task at the dumper, I observed the 

following event. A team member was operating 

the dumper to dump cages of live chickens. He 

was moving the cage back, then lifting the cage to 

dump again. He did this repeatedly leaving a gap 

between the cage and dumper each time before 

dumping again. I observed a chicken that was still 

twitching fall onto the belt. I observed the chicken 

as it stopped moving and died. It had blood 

dripping from an area on the neck onto the belt.

 came 

into the dumping area and I immediately pointed 

the chicken out to him and explained that the 

team member dumping the cage had moved the 

cage back away and then dump again, repeatedly. 

He spoke with the team member and I said that I 

wanted to get the carcass when it went into the 

live hang area. We observed the carcass and it had 

a bleeding cut on the neck and also cervical 

dislocation in the neck. I immediately found 

(b) (6)

and notified him of the event at 

approximately 0451 hrs. The establishment said 

they would have a meeting with all of the team 

members in the live-hang area at the end of lunch. 

I reminded 

(b) (6)

(b) (6) (b) (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.  I recommended that they review 

Federal Register Notice Vol. 70, No. 187, 

published September 2005 [Docket No. 04–037N] 

for FSIS recommendations concerning treatment 

of live poultry before slaughter.  I notified the 

establishment that this MOI will be forwarded to 

the District Office and the District Veterinary 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 73 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

Medical Specialist (DVMS) in case additional 

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

M9977+P1 Tyson Foods Inc. YBL140707 03JUL2019 04C05 Poultry Good 

325 0203G Commercial 

Practices 

Finalized On 7/3/2019 at approximately 0711 hours I was 

performing a routine poultry Good Commercial 

Practice (GCP) verification task in the live hang 

room of establishment P1325, Tyson Foods, Inc.  I 

observed one live, weak young chicken in the 

establishment’s designated Dead on Arrival (DOA) 

cart that contained approximately eight DOA 

chickens.  I immediately showed the nearest 

establishment employee and 

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

my findings.  The 

establishment employee removed the live bird 

from the cart and euthanized it by cervical 

dislocation.  Agency regulations require live 

poultry to be handled in a manner that is 

consistent with good commercial practices (GCPs) 

and that they not die from causes other than 

slaughter.  Live chickens in the DOA cart can die 

from suffocation, which is then considered 

adulterated product. Respectfully, (b) (6) (b) (6)
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325 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 74 

EstNbr 

M9977+P1 

EstName 

Tyson Foods Inc. 

MOINbr 

YBL370707 

0519G 

Date 

19JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On 7/19/2019 at approximately 0714 hours at 

the evisceration department rehang area of 

establishment P1325, Tyson Foods, Inc, I observed 

a cadaver on the kill line.  The cadaver was a deep 

red color throughout the carcass and its neck was 

completely uncut with the head still attached and 

engorged with blood.  The back-up kill person 

failed to manually cut the neck to permit the 

required bleed out.  The cadaver was transferred 

to the evisceration line and I observed an 

establishment employee re-hanger throw it into a 

red inedible barrel.  I immediately showed 

the cadaver and then observed a 

(b) (6)

(b) (6)

second cadaver with the same physical 

appearance on the evisceration line.  As I 

continued to observe the rehang area for the next 

1-2 minutes I observed approximately four more 

cadavers enter the department and immediately 

notified 

of the additional birds. 

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

All cadavers had the same deep red color 

throughout the carcasses with the engorged 

heads attached and uncut necks. 

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

later informed me that they spoke 

with the back-up kill person, who had been 

identifying mechanical problems while 

simultaneously performing his kill duties. This 

caused him to accidentally miss the chickens that 

made it past the mechanical blade uncut.  They 

also informed me that they reminded the 

employee to focus on his back-up kill 

responsibilities. At approximately 1155 hours at 

the same location I observed another deep red 

cadaver with no bleeding cut in the inedible barrel 

and immediately showed 

(b) (6)

. 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 that 
■ 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 75 

EstNbr 

M9977+P1 

325 

EstName 

Tyson Foods Inc. 

MOINbr 

YBL050709 

5319G 

Date 

19SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

breathing has stopped before scalding, so that the 

birds do not drown, and that slaughter results in 

thorough bleeding of the poultry carcass. 

Respectfully, 

(b) (6)

On 9/19/2019 at approximately 0624 hours I was 

performing a routine poultry Good Commercial 

Practice (GCP) verification task in the live hang 

room of establishment P1325, Tyson Foods, Inc.  I 

observed one live, weak young chicken in the 

establishment’s designated Dead-On-Arrival (DOA) 

cart that contained approximately twenty DOA 

chickens.  I immediately showed

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

 who removed the live bird 

while I verified that no more live chickens were in 

the cart.  He then informed me that, since the bird 

was alive, he hung it on the slaughter line. I also 

discussed the situation with 

I reminded him that agency 

(b) (6)

(b) (6)

regulations require live poultry to be handled in a 

manner that is consistent with good commercial 

practices (GCPs) and that they not die from causes 

other than slaughter.  Live chickens in the DOA 

cart can die from suffocation, which is then 

considered adulterated product.  Furthermore, we 

discussed that moribund chickens should be 

promptly euthanized due to their weakened state 

and condemned.  informed me that 

employees and 

(b) (6)

about the importance of 

not placing live chickens into the DOA cart and 

not hanging moribund chickens on the slaughter 

line. Respectfully, 

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

Establishment response attached. 

he would speak with the establishment 

(b) (6)
1111 I 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 76 

EstNbr EstName MOINbr 

P1209 Whitewater Processing Co. FFG050805 

3901G 

Date 

01MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 0855 hours while observing birds entering the 

scald tank as part of a routine GCP task, (b) (6)

.

(b) (6)

 observed the following. One old Breeder 

turkey (Hen) was observed to be breathing and 

raising it's head on the production line just before 

the scald tank. 

(b) (6)

stopped the line no 

plant personnel responded when the bird had 

expired 

(b) (6)

restarted the line 

went immediately to the office and discussed the 

finding with 

(b) (6)

.. I explained that this issue 

continues to occur. The last one occurred four 

weeks ago (04/04/2019). I again explained that 

public perception of this could lead to problems 

for the plant and further corrective actions need 

to be implemented. He stated he would discuss 

this with management and they would take 

immediate corrective measures which included 

reviewing findings with plant personnel. I again 

stressed that it is not a condition that the birds 

are not cut but that only one carotid is cut and 

the birds are regaining consciousness prior to 

bleeding out. 

(b) (6)
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 77 

EstNbr EstName MOINbr 

P1209 Whitewater Processing Co. FFG420807 

3724G 

Date 

24JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 0830 hours while observing birds entering the 

scald tank as part of a routine GCP task, 

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

observed the following. Two (2) old 

Breeder turkeys (Hen) were observed to be 

breathing and raising there heads on the 

production line just before the scald tank. 

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

stopped the line. Plant personnel 

responded  removed the birds from the line and 

rehung them prior to the stunner. 

then restarted the line

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

 went 

immediately to the office and discussed the 

finding with 

(b) (6)

. This is a violation of 9 CFR 

318.65(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.. I 

explained that this issue continues to occur. The 

last one occurred twelve (12) weeks ago 

(05/01/2019). This shows am improvement but 

we still need to strive for zero 

occurrences. Further corrective actions need to be 

implemented. He stated he would discuss this 

with management and they would take 

immediate corrective measures which included 

reviewing findings with plant personnel. I again 

stressed that it is not a condition that the birds 

are not cut but that only one carotid is cut and 

the birds are regaining consciousness prior to 

bleeding out. 
I I I I I I I I ·1 

. 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 78 

EstNbr EstName MOINbr 

P1209 Whitewater Processing Co. FFG210808 

1830G 

Date 

30AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 0910 hours while observing birds entering the 

scald tank as part of a routine GCP task, 

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

observed the following. One (1)  old 

Breeder turkey (Hen) were observed to be 

breathing and raising it's head on the production 

line just before the scald tank. 

(b) (6)

stopped 

the line. Plant personnel responded  removed the 

bird from the line and rehung it prior to the 

stunner. 

(b) (6)

then restarted the line. 

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

went immediately to the office and 

discussed the finding with 

(b) (6)

. This is a 

violation of 9 CFR 318.65(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.. I 

explained that this issue continues to occur. The 

last one occurred five (5) weeks ago 

(07/24/2019). This shows am improvement but 

we still need to strive for zero occurrences. 

Further corrective actions need to be 

implemented. He stated he would discuss this 

with management and they would take 

immediate corrective measures which included 

reviewing findings with plant personnel. I again 

stressed that it is not a condition that the birds 

are not cut but that only one carotid is cut and 

the birds are regaining consciousness prior to 

bleeding out. 
I I I I I I I I l 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 79 

EstNbr EstName MOINbr 

P1209 Whitewater Processing Co. FFG360809 

0818G 

Date 

18SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 0910 hours while observing birds entering the 

scald tank as part of a routine GCP task, 

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

observed the following. One (1) old 

Breeder turkey (Hen) were observed to be 

breathing and raising it's head on the production 

line just before the scald tank. 

(b) (6)

stopped 

the line. By the time plant personnel 

responded the bird had expired. 

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

the office and discussed the finding with

(b) (6)

 then 

restarted the line. went immediately to 

(b) (6)

This is a violation of 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.. I explained that this issue continues to 

occur. The last one occurred nineteen (19) days 

ago (08/30/2019). This shows am improvement 

but we still need to strive for zero occurrences. 

Further corrective actions need to be 

implemented. He stated he would discuss this 

with management and they would take 

immediate corrective measures which included 

reviewing findings with plant personnel. I again 

stressed that it is not a condition that the birds 

are not cut but that only one carotid is cut and 

the birds are regaining consciousness prior to 

bleeding out. 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 80 

EstNbr EstName MOINbr 

P1209 Whitewater Processing Co. FFG070810 

3124G 

Date 

24OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 0900 hours while observing birds entering the 

scald tank as part of a routine GCP task, 

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

observed the following. One (1) old 

Breeder turkey (Hen) was observed to be 

breathing and raising it's head on the production 

line just before the scald tank

(b) (6)

 stopped 

the line. Plant personnel then removed the bird 

from the line and rehung it prior to the stunner. 

(b) (6)

then restarted the line. 

(b) (6)

went 

immediately to the office and discussed the 

finding with 

(b) (6)

. This is a violation of 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.. I 

explained that this issue continues to occur. The 

last one occurred Thirty-five (35) days ago 

(09/18/2019). This shows an improvement but we 

still need to strive for zero occurrences. Further 

corrective actions need to be implemented. He 

stated he would discuss this with management 

and they would take immediate corrective 

measures which included reviewing findings with 

plant personnel. I again stressed that it is not a 

condition that the birds are not cut but are not 

adequately cut, meaning  that only one carotid is 

cut and the birds are regaining consciousness 

prior to bleeding out. 
        

        

       

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 81 

EstNbr EstName MOINbr 

P1235 Wayne Farms LLC GKN51120 

54828G 

Date 

28MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On May 28, 2019, at 1020, while performing a 

routine good commercial practice verification, I 

observed one live bird enter the scald vat.  I was 

standing in the picking room at the west entrance 

of scald vat number one.  Just as a bird was 

entering the scald vat, I observed that a second 

smaller bird was hung behind it on the same 

shackle.  The bird that was hung behind had open, 

blinking eyes and was lifting its head.  I notified

(b) (6)

 who was in 

the immediate area. The line was stopped and an 

attempt at retrieval was made.  When the bird 

exited the scald vats, I confirmed that the throat 

had not been cut and therefore this bird had died 

otherwise than by slaughter

(b) (6)

 removed 

the bird from the line and condemned it.  I 

immediately performed an additional one 

thousand bird check and did not observe any 

improperly slaughtered carcasses.  I then 

proceeded to the kill room and verified that the 

stunner and kill machine were functioning as 

expected. 

(b) (6)

stated that he had multiple 

new, inexperienced live hangers in the area and 

for immediate corrective actions, he instructed an 

experienced live hanger to work with each person. 

At approximately 1100, I notified 

of this incident and 

forthcoming MOI documentation. 

was also notified 

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

by phone while I was in . 

Respectfully, 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 82 

EstNbr EstName MOINbr 

P1235 Wayne Farms LLC GKN54080 

64827G 

Date 

27JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On June 26, 2019, at 1108, I, 

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

observed less than good 

commercial practices in the picking room.  During 

the performance of a routine Good Commercial 

Practice check (GCP), I observed one live bird 

whose throat had not been cut about to enter 

scalder number one.  Additionally, the bird 

exhibited labored respiration and open eyes. I 

was standing at the west (entrance) end of scalder 

number one where the establishment has 

installed a stop button for occurrences such as 

this. Per establishment’s written permission, I 

immediately stopped the picking line to prevent 

the bird from entering the scald vat and 

drowning. 

arrived quickly and removed the 

bird from the line prior to restarting the picking 

line. This bird had passed all the establishment’s 

intervention steps and the entrance into 

the scalder was imminent when the line stopped. 

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

Hence, it is reasonable to conclude that without 

intervention and the utilization of the emergency 

stop button, the bird would have entered the 

scalder alive. I immediately performed an 

additional 1,000 bird check and did not observe 

any improperly slaughtered carcasses.  I then 

proceeded to the kill room to verify the function 

of the stunner and kill machine.  During my 

observation period I noted that the backup killer 

had to slit the neck on more than 20 birds in less 

than 3 minutes and approximately 50 percent of 

these birds were not properly stunned.  I 

instructed the backup killer to blow his horn for 

maintenance assistance. After removal of the live 

bird and examination of the kill process, the 

establishment determined that due to bird size 

variations the stunner and the kill blade needed to 

be raised.  After adjusting the equipment, 

verification checks performed by the QA humane 

handling technician were found to be acceptable 
                             

                                                                                

                                                

                                                                                     

                                                   

                                                                                     

                  

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 83 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

documentation would be forthcoming. A copy 

of this Memorandum of Interview will be 

forwarded to appropriate personnel in the 

and within the parameters of their poultry welfare 

and handling program

(b) (6)

 was notified that GCP MOI 

(b) (6)

Jackson District Office. Respectfully, 

(b) (6)

(b) (6)

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

                                                                                

                                                

                                                                                     

                     

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 84 

EstNbr EstName MOINbr 

P1235 Wayne Farms LLC GKN52140 

73618G 

Date 

18JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On July 18, 2019, at approximately 1355, I, 

(b) (6)

, observed less 

than good commercial practices in the picking 

room.  During the performance of a routine Good 

Commercial Practice check (GCP), I observed one 

live bird whose throat had not been cut about to 

enter scalder number one. This bird had open and 

blinking eyes and was lifting its head attempting 

to right itself.  I was standing at the west 

(entrance) end of scalder number one where the 

establishment has installed a stop button for 

occurrences such as this. Per establishment’s 

written permission, I immediately stopped the 

picking line to prevent the bird from entering the 

scald vat and drowning. 

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

arrived quickly and 

removed the bird from the line prior to restarting 

the picking line. This bird had passed all the 

establishment’s intervention steps and the 

entrance into the scalder was imminent when the 

line stopped.  Hence, it is reasonable to conclude 

that without intervention and the utilization of 

the emergency stop button, the bird would have 

entered the scalder alive. I immediately 

performed an additional 500 bird check and did 

not observe any improperly slaughtered carcasses. 

was notified that GCP MOI 

(b) (6)

documentation would be forthcoming. A copy 

of this Memorandum of Interview will be 

forwarded to appropriate personnel in the 

Jackson District Office. Respectfully, 

(b) (6)

(b) (6)

(b) (6)

. 

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

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 85 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

P1241 Tyson Foods, Inc. MGJ44160 19APR2019 04C05 Poultry Good Finalized 

42719G Commercial 

Practices 

Establishment 1241-P, Tyson Foods, Inc. April 19, 

2019, 9:00 pm.  In attendance: 

At approximately 3:25 pm while 

(b) (6)

(b) (6)

performing a Poultry Good Commercial Practices 

task at a point just before where the chickens 

enter the scalding tank, I observed a live chicken 

enter the scalding tank while still breathing.  The 

chicken had no visible knife cut on its neck and 

was exhibiting voluntary movement of the head 

and neck as it entered the scalding tank.  I 

immediately proceeded to the point on the kill 

line directly after the last picking machine and 

waited for the chicken carcass in question to pass 

by me.  When the carcass appeared, I removed it 

from the kill line and examined it.  The carcass 

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

the neck.  I immediately showed the chicken 

carcass to 

, and informed him of the impending 

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

MOI.  At approximately 3:45 pm, I resumed the 

performance of my Poultry Good Commercial 

Practices task at the same point of the process as 

described above.  After observing the process for 

approximately 2 minutes, I again observed a live 

chicken enter the scalding tank while still 

breathing.  This chicken also had no visible knife 

cut on its neck and was exhibiting voluntary 

movement of the head and neck as it entered the 

scalding tank.  I immediately proceeded to the 

point on the kill line directly after the last picking 

machine and waited for the chicken carcass in 

question to pass by me.  When the carcass 

appeared, I removed it from the kill line and 

examined it.  The carcass was small, red in color, 

and had no knife cut on the neck.  I immediately 

showed the chicken carcass to 

(b) (6)

and 

informed him that this incident would also be 
-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 86 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

added to the MOI.  After finding this 2nd incident 

of a live chicken entering the scalding tank, I then 

observed the process at a point near the 

employee who was working as the back up killer. 

I noted that several of the chickens coming down 

the line were very small, were missing the water 

bath in the stunner, were not being properly 

stunned, and were therefore not being cut by the 

kill machine.  As a result, the employee working 

as the back up killer was having trouble keeping 

discuss my findings and the corrective actions that 

stated that the Live Hang 

supervisor immediately assumed the role of back 

up killer for the remainder of the shift, members 

of the maintenance team looked at the stunner 

and made some adjustments to it, all 

establishment employees who work in the back 

up killer position were reminded to stop the kill 

line whenever they are unable to keep up with the 

process, and the grow out team members were 

informed to work with the growers to ensure a 

more uniform bird size for incoming flocks. 

1241-P Corydon, IN 

up with the process. At approximately 9:00 pm, I 

met with and the other members of 

establishment management listed above to 

(b) (6)

were taken by establishment management. 

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

Est. 
-

- -

1111 -

-

1111 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 87 

EstNbr EstName MOINbr 

P1243 Perdue Foods, LLC. XLB591008 

1623G 

Date 

23AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

While out in the live receiving area performing the 

Good Commercial Practices task, at approximately 

11:39 a.m. on 08-23-2019, 

(b) (6)

and I 

were walking through the receiving area and I 

observed a live breathing chicken coming down 

the DOA conveyor belt. The chicken then slid 

down the slide and onto the ground in the area at 

the end of the belt for collection. I then observed 

an employee pick up this live breathing bird and 

place it into the DOA bin. Immediately after being 

placed in the DOA bin, I observed another 

employee sprinkle denaturant on this alive and 

breathing bird. 

(b) (6)

then told him to stop 

placing birds in the bin and went to get 

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

the live hang supervisor, to inform him of 

the live bird in the DOA bin. While 

was gone to get 

(b) (6)

I observed the same 

employee remove the live bird from the bin and 

place it on the ground. 

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

came back out to the area and he 

confirmed that the chicken was alive and 

breathing and at that time he had the bird 

immediately humanely euthanized via cervical 

dislocation. Otherwise if this chicken would have 

remained in the DOA bin, other birds could have 

been placed on top of this bird, thereby 

smothering this bird allowing it to die otherwise 

than by slaughter. 
- -

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 88 

EstNbr EstName MOINbr 

P1243 Perdue Foods, LLC. XLB370811 

4808G 

Date 

08NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On  Friday 11/08/2019 while performing the GCP 

task at approximately 0905 hours, I observed a 

couple of the live hang employees slamming the 

birds into the shackles very aggressively during 

my observation. This is a humane handling issue. 

I stood and observed the employees for 

approximately 5 to 7 minutes to verify my 

observation. During the time of my observation 

neither of the employees noticed that I was 

standing right at the bottom of the steps looking 

at what was going on. I notified 

of my observation and he told me that 

he would notify 

of my observation for him to address the 

employees. 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 89 

EstNbr EstName MOINbr 

P1243 Perdue Foods, LLC. XLB280912 

2427G 

Date 

27DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On 12/27/2019 at approximately 0750 hours, 

while performing the Good Commercial Practice 

Verification Task I observed a live bird in the DOA 

bin. It was on top of the pile and had no 

denaturant applied during the time of my 

observations. I observed the bird was continuing 

to breath, blinking its eyes and moving head. I 

came closer to the DOA bin to ensure that the 

bird inside of the DOA bin was still alive and it 

was. During the time of these observations, 

there were no supervisors in the area. I then asked 

the team member to call his supervisor. 

came, and I 

informed him and showed him my observations. 

He picked the bird up and saw that it was 

breathing, moving its head, blinking and kicking. 

He agreed that it was alive. At this time, he had 

the bird humanely euthanized via cervical 

dislocation. Perdue Foods LLC. establishment 

#1243 P- has established a protocol that any birds 

should be confirmed dead prior to entry the dead 

container. If a bird is questionable, it should be 

hung as a suspect prior to making a 

determination.  I prepared this report on 

12/27/2019 and I certify that this report has 

recorded in it a summary of all pertinent matters 

discussed. 

(b) (6) (b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 90 

EstNbr EstName MOINbr 

P1243 Perdue Foods, LLC. XLB201202 

2520G 

Date 

20FEB2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Open 

MOI Agenda 

On 02/20/2020 at approximately 1142 hours, 

while performing the Good Commercial Practice 

Verification Task I observed a live bird in the DOA 

bin. It was on top of the pile and had no 

denaturant applied during the time of my 

observations. I observed the bird was continuing 

to breath, blinking its eyes and moving head. I 

came closer to the DOA bin to ensure that the 

bird inside of the DOA bin was still alive and it 

was.  During the time of these observations, 

there were no supervisors in the area. I then asked 

the lead person to call his supervisor and showed 

him my observations. 

came, and I informed him my 

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

observations. 

(b) (6)

asked the team 

member if the bird was alive and he said ‘Yes” it 

was alive. The rehang lead person picked the bird 

up and saw that it was breathing, moving its head, 

blinking and kicking. He agreed that it was alive. 

At this time, he had placed the bird back on the 

rehang table to rehang it back to the line. 

Perdue Foods LLC. establishment #1243 P- has 

established a protocol that any birds should be 

confirmed dead prior to entry the dead container. 

If a bird is questionable, it should be hung as a 

suspect prior to making a determination. I 

prepared this report on 02/20/2020 and I certify 

that this report has recorded in it a summary of all 

pertinent matters discussed. This MOI is 

associated with MOI # XLB1304021812G dated 

02/12/2020. 
1111 

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 91 

EstNbr EstName MOINbr 

P1250 Fieldale Farms Corporation OAA56190 

83712G 

Date 

12AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On 8/12/19 at 18:35 while performing Good 

Commercial Practices, I 

(b) (6) ,

(b) (6)

 observed two large piles of dead birds in 

the live hang room.  One pile was concentrated 

between the belt and the wall where hangers for 

Line #2 stand to hang birds. This area is 

approximately 2 feet between the belt and the 

wall.  This pile contained approximately 150-200 

birds and was piled 4-5 birds tall.  The other pile 

was at the end of the conveyer belt.  This pile also 

contained approximately 150-200 birds and was 

piled 3-4 birds tall.  There was no pile around Line 

#1.  I informed 

that they must stop hanging on Line 

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

radioed for

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

#2. 

Employees from Line #2 

began to dispose of the dead birds.  During this 

process, I observed 6 live birds pulled from the 

pile at the end of the conveyer belt. Several live 

birds were under the first layer of dead birds and 

one bird in particular was on the very bottom of 

the pile of dead birds, creating the potential for 

suffocation and death.  Both piles were removed 

from the live hang room and I released Line #2 to 

rehang at 18:49. After I released Line #2, I spoke 

with

(b) (6)

 I explained that commingling live bird 

with dead birds creates potential for them to be 

suffocated, and therefore die by means other than 

slaughter.  He said that they would have a 

dumpster brought it at the start of 2nd shift every 

day so as not to overwhelm rendering with the 

dead birds.  I left the area at 19:02. This MOI will 

be forwarded to the District Office and the District 

Veterinary Medical Specialist (DVMS) in case 

additional follow-up is recommended. 

Respectfully, 

(b) (6) (b) (6)
1111 

- -

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 92 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

P1272 Pilgrim's Pride Corporation CCA31190 08JUL2019 04C05 Poultry Good Finalized 

74808G Commercial 

Practices 

Est. P-01272, Pilgrim’s Pride, July 2, 2019, 1543 

On July 2, 2019, 

(b) (6)

(b) (6)

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

hours. In attendance ,

 observed inhumane handling of 

live birds in the live receiving area. The 

temperature at the time of inspection was 97 

degrees Fahrenheit. While performing my Good 

Commercial Practice (GCP) verification I observed 

twelve (12) birds in a cage sitting on the floor 

beside the cage dump for line one. One bird was 

deceased, and the rest were in distress. The live 

hang lead person was immediately notified and 

took control of the situation. Upon further 

investigation I observed that the misters and fans 

for the left truck holding area on line one was not 

operational. The birds on the truck were lethargic 

and open mouth breathing due to heat stress. The 

establishment was told that the birds will not be 

allowed to sit in those condition and maintenance 

was called to the area. The establishment elected 

to sprinkle the birds with cool water from a hose 

until they could fix the problem. At 1546 hours, I 

continued to line two to complete my inspection 

and observed the cage dump operator for line two 

throwing a live bird. I observed the cage bump 

operator pick up a bird from the floor and 

attempted to throw the bird over a wire fence 

barrier and onto the cage dump belt. When the 

operator threw the bird it left her hands, went 

approximately two to three feet above her head, 

hit the wire barrier and fell back onto a concrete 

floor. The operator then proceeded to pick the 

same bird up again and threw it once more over 

the barrier and unto the cage dump belt. 

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

was walking with me the 

entire duration of my inspection and immediately 

contacted the 

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

and spoke with the cage dump operator 

about her actions. I informed 

(b) (6)

and 
■ 

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 93 

EstNbr EstName MOINbr 

P1272 Pilgrim's Pride Corporation CCA02150 

91404G 

Date 

04SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

(b) (6)

of the forthcoming MOI. I reminded

(b) (6)

 that the PPIA and 

Agency regulations require that live poultry be 

handled in a manner that is consistent with good 

commercial practices. I also 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. Respectfully, 

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

Pilgrim’s Pride. 

Est. P-01272, Pilgrim’s Pride, September 3, 2019, 

On September 3, 2019

(b) (6)

(b) (6)

(b) (6)

1743 hours. In attendance: ,

 observed inhumane handling of 

live birds in the live receiving area. The 

temperature at the time of inspection was 90 

degrees. While performing my Good Commercial 

Practice (GCP) verification I observed that none of 

the misters for the truck holding areas on both 

lines were on. The birds on the trucks (4 in total) 

were lethargic and open mouth breathing due to 

heat stress 

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

was notified of my observations and of 

the forthcoming MOI. 

(b) (6)

turned on the 

misters at the time of notification. I reminded 

(b) (6)

that the PPIA and Agency regulations 

require that live poultry be handled in a manner 

that is consistent with good commercial practices. 

I also notified him, that this MOI will be 

forwarded to the District Office and the District 

Veterinary Medical Specialist (DVMS) in case 

additional follow-up is recommended. 

Respectfully, 

(b) (6)

Pilgrim’s 

Pride. 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 94 

EstNbr EstName MOINbr 

P1272 Pilgrim's Pride Corporation CCA17191 

00016G 

Date 

16OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Est. P-01272, Pilgrim’s Pride, October 14, 2019, 

On October 14, 2019, 

(b) (6)

(b) (6)

(b) (6)

1736 hours. In attendance: , 

while performing my Good 

Commercial Practices Task, I observed improper 

implementation of the Good commercial 

Practices. While conducting my tasks I looked into 

the DOA bin for Line 2 in the Live receiving area 

and saw two live birds. Both birds were amongst 

other deceased birds. The supervisor was on the 

line and the lead person was working in the 

picking room. The 

was walking past me into the live hang area when 

I stopped him to retrieve the birds from the DOA 

bin and correctly dispose of them. No other live 

birds were observed in the DOA bin. I informed 

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

of the forthcoming MOI. I reminded

 that the PPIA and Agency regulations 

require that live poultry be handled in a manner 

that is consistent with good commercial practices. 

I also 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. 

Respectfully, 

(b) (6)

Pilgrim’s 

Pride. 
- ■ 

- ■ 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 95 

EstNbr EstName MOINbr 

P1284 Pilgrim's Pride Corporation GDA38010 

52115G 

Date 

15MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Est. 01284-P, Pilgrim’s, May 14, 2019, 2120 

hours. In attendance: 

(b) (6)

(b) (6)

On May 14, 2019, approximately 2115 hours, 

while inspecting the MSC/DOA offal trailer, I 

observed a live chicken. The chicken was on the 

floor of the trailer resting on its breast and 

covered in red dye denaturant. I estimated around 

150 dead chickens were in the trailer, and all 

chickens I could easily observe still had their 

heads attached. I immediately notified 

(b) (6)

. He and 

inspected the offal trailer with me 

stated he had not dumped any DOA’s into the 

trailer since live hanging had started for the shift. I 

observed the denaturant on the carcasses and live 

chicken had stained the chickens but was dry. 

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

retrieved the live chicken which was alert 

and active when picked up. He humanely 

euthanized the animal by rapid decapitation. A 

Poultry Good Commercial Practices MOI was 

documented on 11/19/2015 for finding a live 

chicken in the offal trailer. The preventative 

measure documented by plant management to 

prevent recurrence, was “a documented check 

will be performed at the beginning and end of 

each shift. The check will be to inspect the 

MSC/DOA offal trailer for any live chickens. 

Documentation of this check can be found on the 

Daily Animal Welfare Audit.” I reviewed the Daily 

Animal Welfare Audit form from day shift 

operations on 5/14/19, and an inspection of the 

MCC/DOA offal trailer for live chickens was 

completed at 1520 hours and found to be 

acceptable, no live chickens in the MSC/DOA offal 

trailer at the end of the shift. I reminded 

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

that the regulations require that poultry 

be slaughtered according to Good Commercial 

Practices. This includes employing humane 
- ■ 

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 96 

EstNbr EstName MOINbr 

P1307 Mar-Jac Poultry-AL KIL030205 

2108G 

Date 

08MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

methods of handling that prevents needless injury 

and suffering. No immediate planned actions 

were provided by the establishment at this time, 

however, an investigation would be conducted, 

and a response would be provided by plant 

management. 

(b) (6)

was informed that 

this mistreatment MOI will be forwarded to the 

District Office and the District Veterinary Medical 

Specialist (DVMS) in the event additional 

follow-up is recommended. Respectfully, 

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

01284-P Pilgrim’s 

At approximately 0125 while performing 

Ante-Mortem and an Animal Welfare check at line 

1 live bird cage dump, I observed an 

Establishment employee throw a live chicken 

approximately 3 feet diagonally across from a 

lower set of cages to the top of another set of 

cages.  As the chicken skidded across the top of 

the cage approximately 2 feet, it vocalized and 

flayed its wings.  The employee's actions caused 

the bird undue distress and excitement.  I notified

(b) (6)

 of my observations. A copy of this 

Memorandum of Interview (MOI) will be 

forwarded to the appropriate District Office 

personnel. Respectfully submitted on May 8, 

2019, 

(b) (6)

(b) (6)
-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 97 

EstNbr EstName MOINbr 

P1307 Mar-Jac Poultry-AL KIL551310 

3117G 

Date 

17OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 13:10 on October 17, 2019, I 

observed less than Good Commercial Practices 

(GCP) while performing 

Antemortem/GCP/Mishandling verification at 

Mar-Jac Poultry in Jasper, AL.  I observed a small 

chicken in the DOA dumpster that was still 

breathing.  The chicken was alert and sitting on its 

hocks, while surrounded by DOA's and chicken 

litter.  I immediately notified 

(b) (6)

of this finding.  The 

chicken was retrieved from the dumpster and 

euthanized by cervical dislocation and 

decapitation. cc: 

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

(b) (6)

P1307 Mar-Jac Poultry-AL KIL571502 05FEB2020 04C05 Poultry Good 

0205G Commercial 

Practices 

Open At approximately 14:38 on February 5, 2020, I 

observed less than Good Commercial Practices 

(GCP) while performing 

Antemortem/GCP/Mishandling verification at 

Mar-Jac Poultry in Jasper, AL.  I observed four (4) 

live chickens in the DOA dumpster. The chickens 

were lethargic, but breathing heavily, and were 

surrounded by DOA's and chicken litter.  I 

immediately notified 

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

of this finding.  The chickens were 

retrieved from the dumpster and euthanized by 

cervical dislocation and decapitation. cc: (b) (6)

(b) (6)
        

        

17 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 98 

EstNbr 

P1317+V13 

EstName 

Wayne Farms LLC 

MOINbr 

QUI331809 

2012G 

Date 

12SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Open 

MOI Agenda 

TO: Mr. BRYAN ELROD, Plant Manager Wayne 

Farms LLC. 700 McDonald Ave. Albertville AL, 

35950 FROM: 

Dear Mr. Elrod, At approximately 16:15 hours, on 

September 12, 2019, while performing the Review 

and Observation component of the PHIS task, 

“Poultry Good Commercial Practices,” I observed 

one live birds covered by and comingled with 

dead birds in a pile on the floor at the end of the 

live bird belt. Also one alive bird was lying on the 

top of dead birds and being in eminent danger to 

be crushed and smothered by other birds when 

piling up on the top of each other. At that time I 

instructed a fork lift driver to take care of alive 

birds.  During a meeting, with a plant 

management members, held in USDA/FSIS office 

at approximately 17:15 hours I informed 

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

.

(b) (6)

 that a 

GCP MOI documentation of our meeting and 

discussion of the observed deficiency would be 

forthcoming. As per Federal Register Notice 

Docket No. 04-037N dated September 28,2005, 

'Treatment of Live Poultry before Slaughter," the 

Food Safety Inspection Service (FSIS) strongly 

encourages all establishments engaged in the 

slaughter of poultry to make every effort to treat 

poultry humanely and abide by the Good 

Commercial Practices (GCPs) as described by 

industry guidelines. Corrective and preventive 

measures addressing this incident are appropriate. 

I look forward to your response. Respectfully 

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

(b) (6)

(b) (6)

submitted, Cc: 
   

               

-

17 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 99 

EstNbr 

P1317+V13 

EstName 

Wayne Farms LLC 

MOINbr 

QUI561710 

4007G 

Date 

07OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

TO: Mr. BRYAN ELROD, Plant Manager Wayne 

Farms LLC. 700 McDonald Ave. Albertville AL, 

35950 FROM: 

Dear Mr. Elrod, At approximately 17:25 hours, on 

October 07, 2019, while performing the Review 

and Observation component of the PHIS task, 

“Poultry Good Commercial Practices,” I observed 

one live birds covered by and comingled with 

dead birds in a pile on the floor at the end of the 

live bird belt. Also one alive bird was lying on the 

top of dead birds and being in eminent danger to 

be crushed and smothered by other birds when 

piling up on the top of each other. During a 

meeting, with the 

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

, held in USDA/FSIS office at approximately 

17:35 hours I informed him that a GCP MOI 

documentation of our meeting and discussion of 

the observed deficiency would be forthcoming. 

Corrective and preventive measures addressing 

this incident are appropriate. I look forward to 

your response. Respectfully submitted, (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)

, 
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17 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 100 

EstNbr 

P1317+V13 

EstName 

Wayne Farms LLC 

MOINbr 

QUI201212 

5927G 

Date 

27DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 1140 hours on December 26, 2019 while 

performing the Good Commercial Practices 

verification task, the following was observed at 

the entrance to the scald tank. One young chicken 

was seen entering the scald tank with a uplifted 

head, reflexes, rhythmic breathing, and 

movements with no cut on the neck. I tried  to get 

the back up auto killer person to stop the line but 

could not make him understand what I needed 

him to do. Before I started my task I observed the 

back up person washing out the blood drip pan. I 

immediately notified 

was 

notified soon after. Live bird(s) entering the 

scald system live is a less than Good Commercial 

Practices and results in adulterated product. The 

establishment is responsible for ensuring that 

birds under their control on the official premises 

are treated in a humane manner that will 

minimize excitement, discomfort, injury and/ or 

death by means other than slaughter. 

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

-

-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 101 

EstNbr 

P13369+V1 

3369 

EstName 

George's Processing, Inc. 

MOINbr 

ZUD41100 

60426G 

Date 

26JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

FSIS Personnel: 

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

Plant 

Personnel: 

Location: FSIS Supervisor’s Office Meeting 

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

conducted by On 6/25/2019 at 1435 

hours, met with 

to discuss the humane handling 

issue observed by as described below. 

On 6/21/19 at approximately 1715 hours while 

performing a Good Commercial Practice 

Verification Task in the dumper area of Live 

Receiving, I observed the feet of what appeared to 

be 2 birds visible behind the gear/sprocket cover 

on the south end of the upper line 3 dumper belt 

of the line. The lower 2 1⁄2 to 3 inches of 3 paws 

were visible in a standing configuration. I was 

unable to determine if the birds were alive at this 

time. I immediately informed 

, who stopped the 

dumping process and removed 3 uninjured live 

birds and 1 macerated dead bird from this area. 

All birds were significantly undersized. The cover 

was in place to prevent live birds from being 

injured or killed in the gears/sprocket of the upper 

belt. 

(b) (6)

called maintenance to evaluate the 

situation. It was determined that, under certain 

conditions, the lower portion left space for the 

very small birds to get trapped inside and possibly 

contact the gears. The cover was removed, the 

area was monitored with the intention of 

redesigning the cover. 

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

and I discussed the observation and he 

confirmed the corrective measures that were to 

be taken. Monday at approximately 0830 hours I 

was told by 

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

that the redesign had taken place and I 

verified the cover was in place and functioning as 

intended. It is your responsibility to design and 

monitor the live bird handling equipment and 

practices in a manner which prevents birds from 

being mishandled or dying by means other than 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 102 

EstNbr EstName MOINbr 

P1353 Pilgrim's Pride Corporation WUM3901 

072623G 

Date 

23JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

slaughter. Your ongoing monitoring of areas 

where issues have historically occurred or are at 

increased risk for such problems is critical in 

properly implementing good commercial 

practices. This MOI includes all information 

discussed during the meeting 

(b) (6)

6/25/2019 

On 7/23/2019 at approximately 0120 hours, I was 

called to the evisceration department by an online 

inspector. The online inspector informed me that 

they had gotten multiple cadavers at their station. 

I immediately went to the stunning/killing area to 

observe conditions. I found that multiple birds 

were missing the initial blade and had to have 

their throats cut by the employee serving as the 

back-up killer. 

were 

informed of this finding. At 0139 hours, I 

followed up by performing a Good Commercial 

Practice check prior to the scald tanks. During this 

check, I observed one young chicken out of a 

subset of 500 to be alive while entering the scald 

tank. The young chicken had a lifted head with 

open and responsive eyes. A second verification 

check of approximately 500 birds was conducted 

prior to the scald tanks and there were no live 

birds observed entering the scald tanks during this 

retest. Due to this, the incident appeared to be 

isolated with no evidence of a system failure. 

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

were notified. I explained my 

observations and informed them that a 

(b) (6)

Memorandum of Interview (MOI) was going to be 

documented and a copy forwarded to the 

appropriate personnel in the Jackson District 

Office. Respectfully submitted, 

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 103 

EstNbr EstName MOINbr 

P1362 Tyson Foods, Inc. LPC292009 

4904G 

Date 

04SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 1826 hours, while performing Good 

Commercial Practices outside the establishment, I 

observed a single live bird in the DOA tank on top 

of numerous dead carcasses. I observed no 

management in the area, but a fork truck driver 

was present, retrieved the bird, and euthanized 

the bird by separating the neck. I informed 

, who then informed 

, of 

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

the observation by FSIS. 

(b) (6)

stated he 

would immediately check into it and have a 

meeting with the live dock employees. This issue 

will be discussed in the weekly meeting on 

September 5, 2019. 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 104 

EstNbr EstName MOINbr 

P1480 Tip Top Poultry, Inc. JBA572009 

1019G 

Date 

19SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

September 12,2019 Attending: 

On 09/12/2019 at approximately 1808 

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

(b) (6)

hours, I observed  approximately 20 

birds roaming free in the yard area, 7 under the 

feather offal trailer,3 birds under shed #6 and 1 

notifie 

said when coming back from checking the

(b) (6)

(b) (6)

loose bird under shed #20. said she 

live birds on the truck she observed a flattened 

bird moving with the viscera exposed from the 

abdominal cavity at the loading dock area where 

the trailers pull in. 

(b) (6)

notified 

(b) (6)

of 

the incident. said when the employee 

removed the bird it was squirming and 

squawking. The bird was removed and 

euthanized. 

(b) (6)

proceeded to the inside of 

the live dock  area and observed approximately 

200 birds piled up in the corner on top of each 

other near the live hang belt 

immediately informed 

On 09/12/2019 at approximately

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

(b) (6)

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

1825 was performing a GCP. 

notified me that there were 

(b) (6)

too many birds loose outside in the live hang area 

room where the birds are removed from the 

crates and are placed  onto the shackles. I 

observed a large pile of birds on the other side of 

the gate in the left- hand corner with 

approximately 200 birds piled (about 5 feet high) 

on top of each other.  I also observed other birds 

approximately 200 birds that were loose and 

moving around. I observed the hangers to 

continue to remove and hang birds from the 

crates onto the shackles. I notified 

(b) (6)

who was on the line hanging 

(b) (6)

birds that I was taking regulatory control because 
I 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 105 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

I did not notice anyone taking control of the 

process and clearly the “process was out of 

control”. I notified him to stop hanging birds and 

remove the birds from the pile in the corner and 

the floor. The employees stopped removing the 

birds from the crates and began to remove the 

birds from the floor and the birds that were in the 

pile in the corner and placing them onto the 

shackles. I observed both live birds and dead 

birds as they were being removed from the pile. 

There were approximately 20 dead birds in the 

pile that had been smothered. The temperature 

that day outside was over 100F ventilation with 

only 2 fans in the room. I observed the birds to 

have a gray appearance from the mixture of 

feather dust and feces on them in the pile. The 

employees began rehanging at approximately 

1839. I took regulatory control of the line speed 

because the process was clearly out of control and 

the corrective action(s) the plant will take to 

prevent this happening again before we get 

started after lunch. I received a documented 

corrective action from 

resumed at approximately 2047 hours. I observed 

the live hang area at approximately 2045 hours to 

performed a monitoring check at approximately 

2230 and had line speed adjusted to bpm and 

rooster line to bpm for the rest of the shift. I 

observed 3 birds loose on the floor and several 

birds hung onto the shackles by 1 leg. I notified

reduced the hen line from bpm and the 

rooster line from bps. I notified 

what happened 

and that I would have to have documentation on 

at 

approximately 2040 hours. Production was 

verify checks and monitoring of the area by QA 

and I 

of this and she discussed this with the 

live hanger employees. I had a meeting with 

on 09/12/2019 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 106 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

2045hours. gave me an Animal 

09/12/2019. It stated the cause of this incident 

was due to the lack of focus on picking up the 

birds from the floor. A team member performing 

this duty had left the cage without notifying the 

lead or management. The preventative measures 

that will be taken to prevent this from reoccurring 

are the following: 1. Disiciplinary action will 

occur for failure to ensure animal welfare 

standards are being maintained. 2.Supervisor and 

all live dock team members will go trought Animal 

Welfare training refresher course to reinforce the 

importance of meeting those expectations. This 

training will occur prior to the start of night shift 

09/13/2014. 3. Utilities /unloaders will rotate to 

the cage and lot when they complete their trucks 

prior to going to their breaks to ensure birds are 

picked up from the floor in timely manner. 3. A 

documented monitoring will be performed every 

30 minutes by plant designee throughout night 

shift from 09/12/2019-09/20/2019 to ensure 

corrective actions are effective. QA will also 

perform 3 verifications daily of this monitoring. 

This Documentation will be turned in to the QA 

ofie at the end of each night to be readily 

available for USDA verification. 

Welfare Corrective Action Letter dated