Food Safety and Inspection Service

Submitted by

Dr. Quita Bowman Blackwell

National Humane Handling Enforcement Coordinator

2019
TABLE OF CONTENTS

EXECUTIVE SUMMARY ................................................................................................................................. 3

INTRODUCTION ............................................................................................................................................ 5

BACKGROUND .............................................................................................................................................. 6

DVMS ENHANCED OUTREACH VISIT (DEOV) APPROACH AND TIMELINE .................................................. 8

OUTREACH VISIT PROCESS........................................................................................................................... 8

Pre-Visit Data Review...................................................................................................................... 8

Outreach Visit.................................................................................................................................. 9

Post-Visit Actions ............................................................................................................................ 9

Outreach Analysis by the Agency ................................................................................................... 9

ENHANCED OUTREACH PLAN SCHEDULE MILESTONES ............................................................................ 11

COMMUNICATION PLAN............................................................................................................................ 12

COLLABORATION AND PARTNERSHIP WITH INDUSTRY ........................................................................... 13

RESOURCES................................................................................................................................................. 14

NEXT STEPS................................................................................................................................................. 14

POINT OF CONTACT.................................................................................................................................... 15

ACKNOWLEDGMENTS ................................................................................................................................ 16

APPENDIX 1: DVMS Procedures for DEOV....... ......................................................................................... 17

APPENDIX 2: Evaluation Feedback Questions for DEOV........................................................................... 21

APPENDIX 3: Humane Handling/Good Commercial Practice (GCP) Resources........................................ 23

APPENDIX 4: Talking Points for DVMS Use During Enhanced Outreach .................................................. 28

APPENDIX 5: Sample Humane Handling/GCP Non-compliance Records (NRs) to Share with

Establishments........................................................................................................................................... 32

APPENDIX 6: Pilot Outreach Program........................................................................................................ 39

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Executive Summary

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This document is the Food Safety and Inspection Service’s (FSIS) Enhanced 

Outreach plan to support small and very small establishments with humane 

handling and good commercial practice (GCP) issues. Small and very 

small establishments are the largest block of all slaughter establishments

receiving federal inspection and therefore required to meet the Humane 

Methods of Slaughter Act (HMSA) and GCP regulation. This voluntary outreach 

program will support them with their humane handling or GCP program. The 

agency will provide one-on-one support to small and very small 

establishments with subject matter experts (SMEs), the District Veterinary 

Medical Specialists (DVMSs), who will conduct these enhanced visits. 

The DVMS Enhanced Outreach Visit (DEOV) includes several components to 

provide the best outcome for small and very small establishments (both meat 

and poultry) in support of bolstering their humane handling or GCP program. 

The Agency developed a methodology for the DEOV to include preparation for 

the enhanced visit, the one-on-one visit, and post-visit activities. A list of 

humane handling and poultry resources is provided for DVMSs to share with 

slaughter establishments. Talking points are provided for the DVMSs visit. The 

information provides sample topics and questions for before and during the 

outreach visit. Also shared in this document is the Pilot Outreach Program 

(POP); which discusses how the Outreach Workgroup tested and refined the 

plan. Along with the visits, the plan discusses potential ways of working with 

Industry to support the goal of establishments adopting best practices. This 

outreach approach is in congruence with, although separate from, the standard 

DVMS Humane Handling Verification Visit (HHVV) or the GCP Verification Visit 

(GCPVV) requirements. Although participation by the establishment 

in the DEOV is voluntary, enhanced outreach to these establishments, both 

livestock (covered by the HMSA) and poultry (covered by the Poultry Products 

Inspection Act [PPIA] of 1957), is substantially important to ensure that these 

establishments have the guidance and resources for best practices needed to 

comply with FSIS regulations.
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Introduction

The U. S. Department of Agriculture's (USDA) FSIS has developed an initiative to 

increase small and very small slaughter establishments’ knowledge of humane 

handling and GCP best practices, leading to adoption of such practices for both 

meat and poultry. This document is a manifestation of that effort. Small and 

very small establishments represent approximately ninety (90) percent of the 

more than 6,000 establishments regulated by FSIS. As such, outreach to these 

establishments is critically important to ensure that they have the guidance and 

resources needed to comply with FSIS humane handling regulations and GCPs. 

These visits are for both meat and poultry establishments. This will ultimately 

deliver products that are safe and wholesome. FSIS observed establishments 

that adopt these best practices increase compliance with humane handling 

regulatory requirements. To increase this knowledge, FSIS is proactively 

implementing voluntary enhanced outreach by DVMSs to small and very small 

slaughter establishments. This outreach approach is separate from but 

supports the standard DVMS HHVV/GCPVV requirement. 

The DEOV objective is to support and expand small and very small slaughter 

establishments’ knowledge of humane handling and GCP best practices 

through one-on-one visits and other outreach events. This will lead to progress 

in increasing adoption of best practices, more consistent and effective 

application of best practices, and more compliance with regulatory 

requirements for both humane handling of livestock and GCP of poultry.

DEOV Program Development Activities 

• Design and implement a new educational strategy targeting small and very

small establishments focused on preventing humane handling/GCP noncompliance that result in FSIS enforcement actions.

• Assist small and very small establishments to better their understanding of

achieving humane handling/GCP compliance.

• Develop a structure for DVMS use as a guide for conducting the DEOV.

• Develop and update existing materials/resources and products to support

the humane handling/GCP compliance needs of small and very small

slaughter establishments. This will include a list of resources such as

industry associations and extension offices.
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Background 

This initiative directly supports the FSIS Strategic Plan for Fiscal Years (FY)

2017–2021 through Goal 2: Modernize Inspection Systems, Policies, and the 

Use of Scientific Approaches, Outcome 2.1. Improve Food Safety and Humane 

Handling Practices Through Adoption of Innovative Approaches. These are

measured through Objective 2.1.1. Modernize Scientific Techniques and 

Inspection Procedures and Objective 2.1.2. Increase Adoption of Humane

Handling Best Practices. Each year, the measures are outlined in the Agency’s

Annual Plan. The goal is for slaughter establishments to increase adoption of 

humane handling best practices. The focus is on livestock slaughter using 

humane methods, with a specific focus on restraint and/or stunning of 

livestock to improve establishment compliance with regulatory requirements. 

Poultry GCPs are also a priority in focusing on best practices. The goal being 

to reach out to FSIS-regulated slaughter establishments, specifically small and 

very small establishments, with support. The primary objective for this 

initiative is to improve compliance through enhanced outreach to Industry, 

particularly small and very small slaughter establishments. This should reduce 

the risk of humane handling non-compliance at slaughter establishments. 

Small and very small establishments are most of FSIS-regulated slaughter 

facilities. Out of the approximately 1,150 slaughter establishments, 266 (186 

meat and 80 poultry) are small establishments and 653 (597 meat and 56 

poultry) are very small establishments, totaling 919 in the small and very 

small categories. Based on the data, humane handling non-compliances occur 

more in small and very small establishments as they make up the majority of 

eligible establishments. To address this issue, FSIS constructed this outreach 

plan as an enhanced education and outreach strategy designed to target 

small and very small establishments. This is shared in the FSIS 2019 Annual 

Plan. This is to ensure more consistent application of humane handling and 

GCP best practices and compliance with regulatory requirements. 

The primary method to achieve these objectives is with enhanced outreach 

by the Agency’s DVMSs. This DVMS action plan was designed to support these 

efforts via one-on-one outreach meetings with a DVMS and an establishment. 

The enhanced outreach meetings will provide the DVMS an opportunity to 

highlight prevention of multiple stun events that result in FSIS enforcement 

actions. This is distinct from the regulatory HHVV/GCPVV that DVMSs will 

continue to perform. The HHVV/GCPVV purpose is to assess the 

establishment’s humane handling/good commercial practice system as 

required by regulation, policy, and to meet the HMSA for livestock. The 

purpose of the voluntary DEOV is to provide support, understanding and 

clarification

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of humane handling and GCP requirements specific to the small and very small 

establishment being visited. Prioritization of the DEOV should be data-driven 

and informed by Humane Handling Non-Compliance Records (HHNR), Humane 

Handling Memorandum of Interview (HHMOI), or other information that might 

indicate a critical need. For poultry establishments, this would include GCP 

NRs, GCP MOIs, weekly meeting MOIs and other pertinent information. For 

example, Districts may review information from prior years and prioritize 

those establishments that historically have a higher frequency of compliance 

issues. Districts should reach out to small and very small establishments and 

offer this assistance based on this prioritization.

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DVMS Enhanced Outreach Approach and Timeline

This document provides a framework to guide DVMSs in their enhanced 

outreach visits and activities for small and very small slaughter 

establishments. The structure for the DEOV is comparable to the current 

regulatory DVMS HHVV/GCPVV. However, the goals and two-way nature of 

the communications has a new and different objective. Regular DVMS 

HHVVs/GCPVVs are conducted to assess the slaughter establishment’s status 

with their humane handling or good commercial practice system or program. 

The DEOV is voluntary (non-regulated) and focus on four to five items for 

livestock, depending on the establishment’s status at the time of the visit. 

Those items include:

• Livestock:

o Communications with establishment management;

o Proper stunning and restraint of animals;

o Sufficient humane handling facilities;

o Humane handling enforcement actions; and

o Robust Systematic Approach (RSA) to humane handling and

slaughter of livestock.

• Poultry:

o Pertinent GCP topics, concerns, and resources.

Each District should follow the DEOV process below to conduct, track 

and monitor humane handling and GCP outreach activities. 

Outreach Visit Process

The outreach activities and resources used may vary depending on the 

individual establishment’s pre-visit data review and/or requests from 

establishment management. Overall, the one-on-one visits will include a 

walk-through of the humane handling or poultry facilities and follow the 

approach outlined below and the more detailed DVMS Procedures for 

DEOV in Appendix 1 (page 17).

Pre-visit Data Review

• Review the establishment’s humane handling/GCP compliance history over an

appropriate time (e.g., 12 to 18 months) but at least to the previous DVMS

HHVV (as outlined in FSIS Directive 6910.1);

• Contact establishment management to discuss their humane handling/GCP

needs or items they want to discuss during the outreach visit. If the

establishment agrees to the outreach visit, set up the outreach visit date; and

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• Contact the Frontline Supervisor (FLS) and Inspection Program

Personnel (IPP) and check with them about any establishment-specific

concerns.

Outreach Visit 

• Introduce and explain a DEOV and the difference between this visit

(non-regulatory) and a HHVV or GCPVV (regulatory). Follow Appendix 1

(page 17) and use the talking points in Appendix 4 (page 28);

• Discuss the overview outlined above as an enhanced outreach visit by a

DVMS:

o Proper stunning and restraint of animals;

o Sufficient humane handling facilities;

o Humane handling enforcement actions; and

o Robust systematic approach (RSA) to humane handling

and slaughter of livestock.

o Pertinent GCP topics, concerns, and resources.

• Complete a walk-through of the humane handling/poultry facilities;

• Use non-compliance examples (Appendix 5 on page 32); and

• Review topics requested during pre-visit contact or other items as they

arise during the visit.

Post-Outreach Visit Actions

• Complete Outreach Report in the Public Health Information System

(PHIS) including FSIS Forms 6000-31 for livestock and FSIS Form 6000-32

for poultry.

• Provide evaluation feedback of DEOV from both the establishment

management official and the DVMS in the survey on the DVMS

SharePoint site (Appendix 2 on page 21).

Outreach Analysis by the Agency

The Agency will review the data associated with this outreach effort a

outlined below. The assessment will befor an appropriate timeframe to be 

established after assessing the number of establishments that 

accept the voluntary DEOV.

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• Review the initial implementation and participation.

• Assess DEOV data as part of the Annual and Strategic Plan reporting.

• Review feedback on compliance rates at establishments that received visits

over an appropriate timeframe.
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Enhanced Outreach Plan Schedule Milestones 

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Milestone Target Date Completion Date

Establish DVMS Small/Very Small Plant

Outreach Workgroup March 2019 March 2019

Establish regular workgroup meetings March 2019 March 2019

Review 2018 Small/Very Small survey 

data and assign research for additional 

data to support development of 

Outreach Plan

April 2019 March 2019

Start drafting Outreach Plan outline May 2019 April 2019

Develop draft plan for POP

June 2019 May 2019

Identify potential establishments for 

the POP June 2019 June 2019

Select DVMSs to implement Districtspecific POP June 2019 June 2019

DVMS team members execute 

District-specific POP

July - August 2019 July - August 2019

Develop summary and analysis of FY19 

POP August 2019

Analysis - August 2019

Summary - September 2019

Develop humane handling outreach 

Communications Plan for DVMSs

August 2019 August 2019

Revise Outreach Plan based on POP 

analysis September 2019 September 2019

Finalize Humane Handling Outreach 

Plan and Communications Plan September 2019 September 2019

Submit to Executive OFO Management 

for clearance September 2019 September 2019

Revise per OFO and obtain other 

clearances as needed October 2019 October 2019

Develop an Implementation Plan for 

approved DEOV

October - November

2019

DVMS Meeting - Begin Scheduling 

DEOV Nationwide

December 2019

Meeting planned for December 2019 / 

begin initial scheduling of DEOV after 

meeting

Full roll-out of DEOV

January 2020

November 2019

January 2020
The Communications Plan, to be developed by the Office of Public Affairs and 

Consumer Education (OPACE), for the DEOV for humane handling and GCP to 

small and very small establishments includes general talking points to be used 

with the media, industry, animal welfare advocate organizations, and the 

public. As part of the DEOV, talking points are available to guide DVMSs with 

their communication with the establishment, including general topics to 

cover before and while meeting with the establishment and sample language

that can be used as a guide (Appendix 4 on page 28).

Other products to be managed by OPACE include:

 Stakeholder advisory;

 Press release;

 Articles in internal news channels – The Beacon and Wednesday Newsline;

 Articles for external distribution – Constituent Update and USDA Radio; and

 Presentation slides for FSIS officials.

Timing of communications will be outlined in the Implementation Plan 

developed after approval of this plan.

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Communication Pla Communication Plan
FSIS outreach efforts intended for small and very small establishments’ 

humane handling/GCP program should include industry outreach as an 

important component. This includes working directly with industry 

organizations that represent owners and operators of small and very small 

establishments to share this new enhanced outreach support, discuss 

humane handling/GCP regulatory compliance, review available resources, 

and respond to inquiries. The FSIS DEOV objectives can also be met through 

working with partners and stakeholders internal and external to the Agency 

to develop outreach materials, inform policy, and actively participate in 

existing outreach efforts. This can include one or more of the following 

approaches:

• DEOV – one-on-one discussions in coordination with establishment

owners and operators to meet in the establishment or other agreed-upon

location;

• Regional/Circuit Meetings – meetings with owners and operators in a

given circuit or region;

• DVMS Participation in Grant of Inspection Application Review –providing

an opportunity for DVMSs to meet with establishment owners and

operators and establish themselves as a resource for assistance and a

conduit for additional humane handling/GCP information; and

• Workshops and Conferences – participate in workshops or conferences

that reach and benefit small and very small establishments to share the

voluntary DEOV opportunity and information.

Ultimately, DVMSs should establish themselves as a resource for assistance 

and additional information.

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Collaboration Collaboration and Partnershi Partnershipwith

Industry Industry toSupport
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Resources

FSIS has several resources available to support enhanced outreach to small 

and very small establishments on humane handling and GCPs. As outreach 

efforts continue, DVMSs are encouraged to provide feedback on guidance and 

resources developed by FSIS and to identify useful support developed through 

partners. These are a few examples: 

• Industry Support and Resources (see updated link from FSIS homepage);

• Small Plant Help Desk;

• Niche Meat Processor Assistance Network (search for humane handling);

• Cooperative Extension System

See Appendix 3 (page 23) for a more comprehensive list of resources.

Additionally, the National Humane Handling Enforcement Coordinator (HHEC) 

will facilitate coordination with the Office of Employee Experience and 

Development (OEED), OPACE and the Office of Policy and Program 

Development (OPPD) to develop additional resources and support as needed 

and assist in coordination with other outreach efforts across the Agency and 

with Industry. 

Next Steps

After the Agency completes preparations for the small and very small 

establishment DEOV program, including readying the DVMSs for additional 

duties, the Office of Field Operations (OFO) will fully implement the program 

in calendar year (CY) 2020. OFO will continue to identify resources and review 

the program to make adjustments as needed. Updates will be provided to the 

DVMSs by email and/or through the DVMS SharePoint site. OFO will work with 

OPACE, OEED, OPPD and others as appropriate to identify training and 

resources for DVMSs on crucial conversations, messaging, policy changes, and 

related topics that may be beneficial. 

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Point of Contact

If you have questions or need support from other program areas to implement 

these outreach activities, contact the National HHEC:

Dr. Quita Bowman Blackwell

National Humane Handling Enforcement Coordinator

Office of Field Operations

Food Safety and Inspection Service

United States Department of Agriculture

(202) 205-0081

quita.bowmanblackwell@usda.gov

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Acknowledgments

Much appreciation goes to the Small and Very Small DVMS Outreach 

Workgroup that designed and tested this important project.

Dr. Quita Bowman Blackwell – Lead 

Dr. Travis Auxier

Dr. Claire Hotvet

Dr. Renee Larson 

Ms. Laura Reiser

Dr. Kurt Schulz 

Dr. Arial Thompson

Thanks also to other DVMSs who significantly contributed to this project.

Dr. Adil Abdalla 

Dr. Kermit Harvey

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APPENDIX 1: 

DVMS Procedures for DEOV

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DVMS Procedures for DEOV

The outreach activities and resources used may vary depending on the 

individual establishment’s pre-visit data review and/or requests from

establishment management. This is a voluntary program, therefore the DEOV 

should be prioritized and targeted to the small and very small establishments 

that have humane handling/GCP issues as outlined in the Background section 

(page 7) of this document. Overall, the one-on-one visits should follow the 

approach outlined below. 

Initial Contact for DEOV

• Introduction and explanation of the DEOV as opposed to the HHVV/

GCPVV.

• Voluntary and non-regulatory.

• If the offer for a DEOV is declined, note that where appropriate on the

evaluation/feedback survey through the DVMS SharePoint site

(Appendix 2 on page 21).

• If the outreach visit offer is accepted continue with Pre-visit Data Review

Section (page8).

Pre-visit Data Review

• Review establishment information since the previous DVMS HHVV/

GCPVV documented in PHIS. The DVMS will review PHIS and local files

to identify trends through Humane Handling Enforcement Actions

(HHEA), HHNRs, HHMOIs, GCP NRs, GCP MOIs, weekly meeting MOIs,

Letter of Concern (LOC), etc.

• Contact establishment management to set up a mutually agreed upon

time and location for the outreach visit.

o DVMS is to ask the establishment if they have any specific

topic requests and if they have a format preference

(electronic documents, paper copies, PowerPoint

presentations, etc.).

• Contact the FLS and IPP to check for any establishment-specific

concerns.

Outreach Visit

• Brief review of introduction and explanation of the DEOV as opposed to

the HHVV/GCPVV and that this DEOV is voluntary and non-regulatory.

• Explanation of how “adequate” restraint, or lack thereof, has been

identified and associated with trends in HHNRs and HHEAs.

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• Explanation of how the regulated industry’s stunning decisional

methodology (especially in small and very small establishments) has been

associated with trends in HHNRs and HHEAs.

• Review/Explanation of how OFO considers the issuance of HHMOIs, weekly

meeting MOIs, HHNRs, and HHEAs as providing communication and part of

Due Process as required by regulation 9 CFR Part 500.

o Explanation of the various aspects of HHEAs (Notice of

Intended Enforcement [NOIE] versus Notice of Suspension

[NOS] and Notice of Reinstatement of Suspension [NROS],

etc.).

o Steps/Progression of events from time of notification of an

incident, mitigation of enforcement action, verification period,

and closeout procedures, including expected timeframes.

o Explanation of the Agency’s position on establishments with

repetitive HHEAs for same/similar causes (referral to the

Enforcement and Litigation Division [ELD]).

o Review sample HHNRs (Appendix 5 on page 32).

• Complete a walk-through of the humane handling/poultry facilities.

• Review additional topics if requested by establishment either during initial

contact or during course of discussions.

• RSA discussion/review in light of covered topics.

• Close out of DEOV:

o Short summary of items discussed; and

o Review evaluation questions with manager/establishment

personnel visit was conducted with.

Post-Outreach Visit Actions

• Complete Report in PHIS:

o Complete data entry in PHIS for &^/^&orm 6000-31 for livestock

and/or &^/^&orm 6000-32 for poultry;

o Under Reason for Visit (Box 12) Check "Special Correlation/

Other" and type "Outreach" in the Other Reason text box;

o List personnel present during discussion in Box 15

(Narrative - Correlation);

o Document topics discussed in Box 15 (Narrative - Findings); and

o Document resources shared in Box 15 (Narrative - Findings).

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Follow-up Action Items

• Provide additional or follow-up information and resources as needed

based on site visit discussion.

NOTE: The DVMS has flexibility to assign/change a planned HHVV/GCPVV

to a DEOV when conducting assessment visits to small and very small 

establishments, if the occasion arises. For example, if a HHVV/GCPVV is 

scheduled and for some reason no animals are present for slaughter, at the 

consent of establishment management, the DVMS could conduct a DEOV. 

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• Enter evaluation feedback of DEOV from both the establishment

management official and the DVMS in the survey on the DVMS SharePoint

site (Appendix 2 on page 21).
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APPENDIX 2: 

Evaluation Feedback Questions for DEOV

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Evaluation Feedback Questions for DEOV

• All portions of this evaluation are to be filled out by the DVMS through the

DVMS SharePoint site.

• If the DEOV has been declined by the establishment, please mark “visit

declined” and include any reasons given for the declination. in the

appropriate section of the DVMS SharePoint site (Appendix 2 on page 21).

Questions to ask of the Establishment Owner/Designee:

On a scale of 1 – 4, where 1 is very little and 4 is very much:

1. How beneficial did you find this DEOV? (SCALE)

2. How useful did you find the resources? (SCALE)

3. Would you recommend this type of outreach in the future? (SCALE)

4. Do you feel that you learned new information from this visit? (SCALE)

5. Were there any topics that you would like to see covered in the

future?(COMMENT FIELD)

6. What is your preferred format for resources (e.g., electronic, CD, or

paper)? (SELECT MULTIPLE OPTIONS)

Questions for the DVMS post-visit:

1. Did this establishment seem to react favorably to this outreach? (Y/N)

2. Were the resources listed useful during the visit? (Y/N)

3. Were any areas identified for improvement during this visit (i.e., was there

a positive change as a result)? (Y/N)

4. Do you have any suggestions for changes to this outreach in the future?

(COMMENT FIELD)

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APPENDIX 3: 

Humane Handling / GCP 

Resources

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• Humane Methods of Slaughter Act §1902 (https://www.govinfo.gov/content/pkg/

USCODE-2014-title7/pdf/USCODE-2014-title7-chap48.pdf);

• 9 CFR 313 (https://www.govinfo.gov/content/pkg/CFR-2000-title9-vol2/pdf/

CFR-2000-title9-vol2-part313.pdf);

• FSIS Directive 6900.2 Rev.2 8/15/11 Humane Handling and Slaughter of Livestock

(https://www.fsis.usda.gov/wps/wcm/

connect/2375f4d5-0e24-4213-902d-d94ee4ed9394/6900.2.pdf?

MOD=AJPERES);

• FSIS Humane Handling Resources webpage

(https://www.fsis.usda.gov/wps/portal/fsis/topics/regulatory-compliance/

humane-handling);

• HIKE Scenarios (https://www.fsis.usda.gov/wps/portal/fsis/topics/inspection/

workforce-training/hike/hike-scenarios);

• Situation-Based Humane Handling Modules 1 and 2 (2011) (https://

www.fsis.usda.gov/wps/portal/fsis/topics/inspection/workforce-training/regionalon-site-training/Humane+Handling+of+Livestock);

• 2013 FSIS Compliance Guide of a SA to the HH of Livestock (https://

www.fsis.usda.gov/wps/wcm/connect/

da6cb63d-5818-4999-84f1-72e6dabb9501/Comp-Guide-Systematic-ApproachHumane-Handling-Livestock.pdf?MOD=AJPERES);

• 2017 PHV Refresher Training: Consciousness and Stunning (https://

www.fsis.usda.gov/wps/wcm/connect/bd0306ae-68ce-4337-

ad3e-61da08eabbaa/PHV-Refresher-Training-ConsciousnessStunning.pdf?MOD=AJPERES);

• Federal Register Notice/Vol. 69, No. 174, September 9, 2004 – Merits of a

Systematic Approach (https://www.fsis.usda.gov/wps/wcm/

connect/3057b87f-1b34-49ea-8e8d-73414b576e5e/04-013N.pdf?MOD=AJPERE S);

• USDA FSIS Humane Handling of Livestock and Poultry: An Education Guidebook

Based on FSIS Polices (Revised June 2015) (https://

www.fsis.usda.gov/wps/wcm/connect/96407439-2142-40c7-8e16-c24949f637ce/

humane_handling_booklet.pdf?MOD=AJPERES);

These resources are available to DVMSs to share with slaughter establishments.

FSIS Humane Handling Resources

Humane Handling and GCP Resources

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• Humane Handling of Livestock and Good Commercial Practices in Poultry PHV

Training (04-18-2017) (https://www.fsis.usda.gov/wps/wcm/connect/175cda99-

ece9-48de-9f75-95499ac3cee7/PHVt-Humane_Handling.pdf?MOD=AJPERES);

• AskFSIS Humane Handling Answered Questions (https://

askfsis.custhelp.com/app/answers/list/st/5/kw/Humane%20Handling/page/1);

• FSIS Humane Handling Blog (https://www.usda.gov/media/blog/archive/tag/

humane-handling);

• Small Plant Help Desk (https://www.fsis.usda.gov/wps/portal/fsis/topics/regulatorycompliance/svsp/sphelpdesk);

o Email: InfoSource@usda.gov or call 1-877-FSIS-HELP (1-877-374-7435).

FSIS Poultry Resources 

• FSIS PHIS Directive 6100.3 4/11/11 Ante-Mortem and Post-Mortem Poultry Inspection

(https://www.fsis.usda.gov/wps/wcm/

connect/724ad094-823a-4e06-83f4-47ecbbefad53/PHIS_6100.3.pdf?MOD=AJPERES);

• FSIS Directive 6110.1 7/3/18 Verification of Poultry Good Commercial Practices

(https://www.fsis.usda.gov/wps/wcm/connect/39d791f2-6bc2-4bb4-

bdfc-72504da30f76/6110.1.pdf?MOD=AJPERES);

• Federal Register Notice/Vol. 70, No. 187, September 28, 2005 - Treatment of Live

Poultry Before Slaughter (https://www.govinfo.gov/content/pkg/FR-2005-09-28/

pdf/05-19378.pdf);

• DOAs in a Poultry Slaughter Establishment Ask FSIS Question (https://

askfsis.custhelp.com/app/answers/detail/a_id/1166/kw/doa);

• Humane Handling Ombudsman: Dr. Kurt Schulz

o If you have a humane handling related comment, concern, or wish to file a

complaint, Dr. Schulz’s contact information is below:

Email: kurt.schulz@osec.usda.gov

USDA/FSIS Attn: Dr. Kurt Schulz

Edward Zorinsky Federal Building

1616 Capitol Avenue, Suite 260

Omaha, NE 68102

Resources for Industry

• North American Meat Institute Foundation (http://www.animalhandling.org/);

o Recommended Animal Handling Guidelines & Audit Guide: A Systematic

Approach to Animal Welfare; June 2017 Rev. 1 (http://certifiedhumane.org/

wp-content/uploads/animal-handling-guidelines-June152017.pdf);

• Temple Grandin – Website Resources (https://www.grandin.com/);

• Humane Slaughter Association (UK Resource) (https://www.hsa.org.uk);
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 6

•

•

National Chicken Council (https://www.nationalchickencouncil.org/);

National Turkey Federation (https://www.eatturkey.org/standards/).

Captive Bolt

•

•

Captive-Bolt Stunning of Livestock, Humane Slaughter Association (2013) (http://

www.hsa.org.uk/introduction/introduction); and

Bildstein, Chuck. Captive Bolt Guns & Electrical Stunners. Bunzl Processor Division

Koch Supplies (2019) (https://www.meatinstitute.org/index.php?ht=a/

GetDocumentAction/i/160441).

Firearms

•

•

Humane Killing of Livestock Using Firearms. Humane Slaughter (2014)(https://

www.hsa.org.uk/downloads/publications/humane-killing-using-firearmsupdated-with-2016-logo.pdf); and Woods, Jennifer. Firearm Stunning Beef and

Sheep. VPM – Animal Welfare; NAMI Animal Care and Handling Conference. (Oct.

2016) (https://

www.meatinstitute.org/index.php?ht=a/GetDocumentAction/i/127674).

Electrical

•

•

Electrical Stunning of Red Meat Animals. Humane Slaughter Association (2016)

(https://www.hsa.org.uk/downloads/publications/

electricalstunningdownload.pdf); and

Vogel, K. D., Bradtram, G., Claus, J. R., Grandin, T., Turpin, S., Weykler, R. E., and

Voogd, E. (2011). Head-only followed by cardiac arrest electrical stunning is an

effective alternative to head-only electrical stunning in pigs. Journal of Animal

Science. 89 (1412-1418) (https://www.ncbi.nlm.nih.gov/pubmed/21183712).

Controlled Atmosphere

•

•

Martoft, L., Lomholt, L., Koltoff, C., Rodriguez, B. E., Jensen, E. W.,

Jorgensen, P. F., Pedersen, H. D., & Forslid, A. (2002). Effects of CO2

anaesthesia on central nervous system activity in swine. Laboratory Animals

36 (116-126)(https://www.ncbi.nlm.nih.gov/pubmed/11943075); and

Carbon Dioxide Stunning and Killing of Pigs. Humane Slaughter Association

(May 2007) (https://www.hsa.org.uk/downloads/technical-notes/TN19-carbondioxide-pigs-HSA.pdf).
• Welfare Guidelines. National Turkey Federation. AMI Animal Care and Handling

Conference. (October 2014) (https://www.meatinstitute.org/index.php?ht=a/

GetDocumentAction/i/104491);

• National Chicken Council Animal Welfare Guidelines and Audit Checklist For Broilers.

NCC. (February 2017) (https://www.nationalchickencouncil.org/wp-content/

uploads/2018/07/NCC-Animal-WelfareGuidelines_Broilers_July2018.pdf);

• Grandin, T. Poultry Slaughter Plant and Farm Audit: (July 2009) (https://

www.grandin.com/poultry.audit.html);

• Slaughter Guidelines for Poultry. A Greener World. (https://agreenerworld.org/

certifications/animal-welfare-approved/standards/slaughter-guidelines-for-poultry/);

• Thaxton, Yvonne Vizzler and Christensen, Karen D. Poultry Stunning. University of

Arkansas System (https://www.meatinstitute.org/index.php?ht=a/

GetDocumentAction/i/116619); and

• Bourassa, Dianna V. Controlled Atmosphere Stunning for Poultry Processing. Auburn

University. NAMI Animal Care and Handling Conference. (Oct. 2019)(https://

www.meatinstitute.org/index.php?ht=a/GetDocumentAction/

i/160399).

27 FOR INTERNAL USE ONLY 

Poultry Resources

• Grandin, T. (1996). Factors that impede animal movement at slaughter plants.

Journal American Veterinary Medical Association. 209 (757-797)(https://

www.grandin.com/references/abstract-14.html);

• Trouble shooting Captive-Bolt Equipment, Humane Slaughter Association (2013)

(https://www.hsa.org.uk/introduction/troubleshooting-captive-bolt-equipment);

and

• Voogd, Erika L. Improving Electrical Stunning with B&D Stunner. Voogd

Consulting, Inc. (2011) (http://www.voogdconsulting.com/images/

Improving_Electrical_Stunning_with_B_D_Stunner_2013_AC.pdf).

Troubleshooting

• Grandin, T. (2014). Kosher Box Operation, Design, and Cutting Technique will

Affect the Time Required for Cattle to Lose Consciousness. Department of

Animal Science at Colorado State University (http://grandin.com/ritual/

kosher.box.variables.time.lose.sensibility.html); and

• Grandin, T. (2012). Maintaining acceptable animal welfare during Kosher or Halal

slaughter. Department of Animal Science at Colorado State University(http://

grandin.com/ritual/maintain.welfare.during.slaughter.html).

Kosher and Halal Slaughter
FOR INTERNAL USE ONLY 

APPENDIX 4: 

Talking Points for DVMS Use During 

Enhanced Outreach 

28 
FOR INTERNAL USE ONLY 

Talking Points for DVMS Use During DEOV

These are talking prompts to help the DVMS negotiate through communications 

with establishment management. These are intended as a guide to be tailored by 

the DVMS as appropriate to meet the concerns of the establishment.

Initial Description of the Program [phone]

 New kind of DVMS visit about humane handling of livestock or GCPs for

poultry for small and very small slaughter establishments.

 DEOV is in conjunction with, not a replacement of, the HHVVs/GCPVV, which

will continue. The DEOV is voluntary.

 Opportunity for you to ask questions, receive information about humane

handling/GCP issues that you are concerned about.

 Overall purpose is to help small and very small slaughter establishments

improve compliance in humane handling of livestock and GCPs of poultry.

 This is the initial phase of implementation, FSIS will look at feedback to make

future outreach visits more useful to establishments.

Pre-Visit [phone]

 Calling to schedule a DEOV. This is voluntary visit, not a HHVV/GCPVV.

 Overall purpose is to help small and very small slaughter establishments

improve compliance in humane handling of livestock and GCPs of poultry.

 Opportunity for you to ask questions, receive information about humane

handling/GCP issues that you are concerned about.

 Differences between a DEOV and a HHVV/GCPVV:

o This is not and doesn't replace the HHVV/GCPVV.

o The DEOV is to provide assistance and information, not focus on

non-compliances that could be observed during the visit.

o The DEOV is voluntary.

o Differences between a DEOV and a HHVV/GCPVV.

 Visits may be scheduled:

o At your request to address humane handling/GCP questions you

have;

o When you want to get information about best practices regarding

a specific issue; or

o When the Agency reaches out to your establishment to support

your Humane Handling/GCP program based on current Humane

Handing/GCP issues.

 

29
FOR INTERNAL USE ONLY 

 Schedule a time:

o To have the appropriate person available to discuss humane

handling/GCP issues; and

o That doesn’t need to be on a scheduled day of slaughter.

 Are there any questions or concerns at this time?

 Please send questions prior to the DEOV so the DVMS can be readywith 

appropriateresources. Can touch base again prior to the visit if there are no

questions now.

 What is the preferred format for resources/information the DVMS will

bring to the DEOV (e.g., hard copy, email)?

Starting DEOV [on-site]

 Introduce yourself if you don’t already know the person.

 Thanks for meeting today.

 Just to make sure we are all on the same page; this is an informational

outreach visit, not a regulatory HHVV/GCPVV.

 I have some goals for our visit:

o Answer the questions you sent and have about your

establishment’s compliance.

o Discuss common questions and issues that many small and

very small establishments have. These include facilities,

stunning effectiveness, and RSA programs.

o Provide resources that may be useful to you.

o Discuss any other questions or issues that weren't already

covered.

Outreach Discussion (Appendix 1 on page 17)

• Let’s start with questions:

o Discuss the topics the establishment gave in advance.

• Discuss previous issues/history of establishment compliance:

o Discuss the humane handling/GCP violations or concerns

associated with this establishment.

• Discuss humane handling/GCP trends:

o Discuss the trends found in the pre-visit data review.

 30
FOR INTERNAL USE ONLY 

General Issues

 Make sure to touch on all the components listed:

o Proper stunning and restraint of animals;

o Sufficient humane handling/poultry facilities;

o Humane handling enforcement actions; and

o RSA - if they have an RSA you don’t need to review that

component unless there are questions.

o Pertinent GCP topics, concerns, and resources.

 Discuss common questions and issues with similar establishments.

 Complete a walk-through of the facilities related to humane handling/

GCPs.

 Provide information and resources that might be helpful for the

establishment.

 Discuss comments/observations based on today’s visit (Appendix 3 on

page 23).

Close-Out of Visit

 Summarize major themes discussed in the visit.

 Any other questions or topics?

 Evaluation review/get feedback from the establishment on the visit per

Appendix 2 (page 21).

 Contact the DVMS if there are any further questions/comments.

 Provide card/DVMS contact information.

31
FOR INTERNAL USE ONLY 

APPENDIX 5: 

Sample Humane Handling/GCP

Non-compliance Records (NR)

to Share with Establishment

32 
Sample HHNRs

HATS Category I – Adequate Measures for Inclement Weather 

At approximately 0645 hours while performing HATS Category IV - Handling During 

Ante-mortem Inspection, I observed the following non-compliance with HATS 

Categories I – Adequate Measures for Inclement Weather and III – Water and Feed 

Availability: Three goats were present in pen 1 and four steers were present in pen 

3. Both pens had red plastic water buckets placed in the corners of the pens and as I

reviewed the contents I noted that the water was frozen. I notified Mr. Smith,

Slaughter Supervisor of the non-compliance with regulation 9 CFR 313.2(e) with

regards to access to water in holding pens. Mr. Smith proceeded to dump the

contents of the buckets out and I noted an approximately eight-centimeter layer of

ice build-up on the top of each water bucket. Mr. Smith immediately refilled the

buckets and stated he would refill them as needed during the day’s production. I

periodically verified that the establishment was compliant through the day. I

verbally notified Mr. Smith of the forthcoming non-compliance record.

HATS Category II – Truck Unloading 

At approximately 1430 hours while performing HATS Category II – Truck Unloading, I 

observed the following non-compliance: While watching truck unloading from the 

outside unloading area, I observed a livestock hauler driving one dairy cow off a 

livestock trailer. The cow slipped as she was walking from the trailer to the 

unloading ramp and her right front foot slipped into an approximately fifteencentimeter gap between the trailer and the ramp. The cow was not able to remove 

her foot from the gap and vocalized. The hauler continued to try and drive the 

animal forward. I verbally requested that he discontinue trying to move the animal 

and informed him that the cow was stuck. I then notified Ms. Smith, Slaughter 

Supervisor, of the situation and she immediately assisted the cow in removing its 

front foot. After the foot was removed, I noted a five-centimeter bleeding wound 

on the right front foot, but the animal was fully ambulatory. As there were two

other dairy cows on the trailer, I verbally notified Ms. Smith that no further 

unloading could occur until the gap hazard was corrected. Ms. Smith had the 

livestock hauler realign his truck and once no hazards were present, I allowed the 

other two dairy cows to be unloaded. The unloading of the other two animals went 

without incident. I verbally informed Ms. Smith of the forthcoming non-compliance 

record with regulations 9 CFR 313.1(b) (provide good footing) and 9 CFR 313.2(a) 

(driving with a minimum of excitement and discomfort). 

FOR INTERNAL USE ONLY 33 
HATS Category III – Water and Feed Availability (1 NR for Lack of Feed and 1 NR for 

Lack of Water) 

At approximately 1140 hours while performing HATS Category III – Water and Feed 

Availability, I observed the following non-compliance: I noticed that pen 2, 

containing twenty head of market swine, had no visible feed in the pen. I observed 

truck unloading of this lot at approximately 0730 hours yesterday 

(2019-04-10). I asked Mr. Smith, Slaughter Supervisor, if the establishment had 

provided feed to the swine prior to my arrival today and he stated they had not. I 

verbally notified Ms. Smith, Establishment Owner of the forthcoming noncompliance record and that the animals had not been provided feed as required by 

regulation 9 CFR 313.2(e) as they had not been provided feed after being held for 

twenty-four hours. Ms. Smith immediately provided adequate feed to the twenty

head of swine. 

At approximately 0830 hours while performing HATS Category III – Water and Feed 

Availability, I observed the following non-compliance: I checked pens 2 and 3 and 

noted there were approximately six head of heifers without access to water. There 

were three black rubber round water bins present in the pens, but they did not 

contain any water. I verbally notified Mr. Smith, Slaughter Supervisor, that there 

was no water in pens 2 and 3 as required by regulation 9 CFR 313.2(e) and that I 

would be documenting my findings in a non-compliance record. Mr. Smith 

immediately filled the three rubber buckets with water. 

HATS Category IV – Handling During Ante-mortem Inspection 

At approximately 1000 hours while performing HATS Category IV – Handling During 

Ante-mortem Inspection, I observed the following non-compliance: I observed a 

dairy cow with a five-centimeter wound on her right rear flank that appeared fresh 

and was actively bleeding. Once all 5 head of dairy cows were removed from pen 5, 

I requested to review the pen. On the north side wall, I observed a rusted gate post 

with adhered hair and fresh blood. The edges of the rusted post were sharp when 

touched. The sharp edge was approximately two-meters off the ground, was 

approximately three-centimeter in length and matched the height of the wound on 

the dairy cow. I verbally notified Ms. Smith, Establishment Owner, of the noncompliance with regulation 9 CFR 313.1(a) with regards to poor pen maintenance 

that led to animal injury. Ms. Smith stated they would not be able to repair the pen 

immediately, so I placed U.S. Reject tag number B40682148 on the pen. I verbally 

notified Ms. Smith of the forthcoming non-compliance and the regulatory control 

action taken. 

FOR INTERNAL USE ONLY 34 
FOR INTERNAL USE ONLY 

HATS Category V – Handling of Suspect and Disabled 

At approximately 1445 hours while performing HATS Category IV – Handling During 

Ante-mortem Inspection I observed the following non-compliance with HATS Category 

V – Handling of Suspect and Disabled Animals: At approximately 1000 hours, Dr. Jones, 

Inspector-In-Charge had identified a U.S. Suspect 

(M-1234567) beef cow with back-tag number 41DL 2468. The establishment had 

separated the cow from other animals in pen 6 which was not a covered pen as 

required by regulation 9 CFR 313.1(c) and 313.2(d)(1). It was sunny, hot, (108 degrees 

Fahrenheit according to the establishment’s outside thermometer) and humid. The cow 

was laying laterally on her right side, breathing irregularly, and her tongue was hanging 

out of her mouth. Dr. Jones was notified of the findings and requested that the 

establishment take the animal’s temperature, which was 105 degrees Fahrenheit. Dr. 

Jones notified Mr. Smith, Barn Supervisor, of the findings and Mr. Smith elected to 

euthanize the animal. I observed the animal humanely euthanized and prior to removal 

from the pen, slashed and denatured. I had the establishment place U.S. Condemn tag 

number Z-7654321 in the animal’s ear prior to removal and remove the U.S. Suspect 

tag. I verbally notified Mr. Smith of the forthcoming non-compliance record. 

HATS Category VI – Electric Prod/Alternative Object Use 

At approximately 1030 hours while performing HATS Category VI – Electric Prod/

Alternative Object Use, I observed the following non-compliance: As I entered the pen 

area, I observed an establishment employee near the restrainer driving a sow with a 

hand-held battery powered electric prod. The sow was balking at the entrance to the 

restrainer and the employee shouted at the animal to move. When the animal would 

not move, the employee placed the electric prod on the rear of the animal and pushed 

the button four times in quick succession. The animal vocalized but did not move 

forward. The employee placed the electric prod on the rear of the animal again and 

pushed the button four times in quick succession. The animal again vocalized but did 

not move forward. The employee then used profane language and yelled at the animal 

to move forward and appeared to be in the process of using the electric prod again 

when I requested that he discontinue the use of the prod. I placed U.S. Reject tag 

number B19283746 on the restrainer and requested Ms. Smith, Slaughter Supervisor, 

come to the restrainer. I verbally notified Ms. Smith of my observations of noncompliance with regulation 9 CFR 313.2(b) and the excessive use of the electric prod on 

the sow. Ms. Smith had the employee driving hogs removed from the area. Ms. Smith 

identified and removed a white wash towel that had been draped over the front of the 

restrainer and requested that she try to move the sow forward into the restrainer. 

35
FOR INTERNAL USE ONLY

After further verbal preventative measures were given, I removed by the regulatory 

control action and the sow was moved forward and humanely stunned without 

further incident. I verbally informed Ms. Smith of the forthcoming non-compliance 

record. 

HATS Category VII – Observations for Slips and Falls 

At approximately 0730 hours, while performing HATS Category VII –Observations 

for Slips and Falls, I observed the following non-compliance: An establishment 

employee was driving five steers from pen 2 to the holding pen. Three of the five

steers were observed to slip and then fall after being moved around a right handturn between the pens. All three animals rose and appeared unharmed and 

continued to walk into the holding pen area. After the area was clear and safe to 

observe, I noted an area approximately two-meters in radius of ice and manure 

build-up at the area where the steers fell. I notified Mr. Smith, Slaughter Supervisor, 

of the ice and manure build-up and my observations of the movement of animals 

around the right-hand turn and tagged the alleyway prior to the holding pen with 

U.S. Reject tag number B66468123. Mr. Smith scraped the ice and manure away 

and added salt and hay to the area to improve footing and stated they would 

minimize the use of that area due to the sharp corner. After verbal preventative 

measures were given and the area verified as compliant, I removed the regulatory 

control action. I verbally notified Mr. Smith of the forthcoming non-compliance 

record in regard regulations 9 CFR 313.2(b) and 9 CFR 313.2(d). 

HATS Category VIII – Stunning Effectiveness 

At approximately 0915 hours, while observing HATS Category VIII – Stunning 

Effectiveness, I observed the following non-compliance: A stunning employee 

attempted to stun a lamb with a hand-held captive bolt device. The first attempt 

was ineffective as the lamb remained conscious. The lamb remained standing, was 

tracking the stunning employee with its eyes and moving its head away from the 

employee. The lamb vocalized immediately after the captive bolt contacted the 

head. There was a wound observed on the head of the lamb approximately threecentimeters above the half-way point between the eyes and blood was observed 

coming from its nose. The stunning employee immediately and effectively restunned the lamb with a pre-loaded hand-held captive bolt device resulting in an 

unconscious lamb. I placed U.S. Reject tag number B91827364 on the restrainer 

and verbally discussed my observations with Mr. Smith, Establishment Owner. 

 36
After Mr. Smith provided verbal preventative measures I removed the regulatory control

action. I verbally informed Mr. Smith of the forthcoming non-compliance record and that 

the establishment failed to render the animal immediately unconscious with the first

application of the stunner and failed to meet the regulatory requirements of 9 CFR

313.15(a)(1). 

HATS Category IX – Check for Conscious Animals on the Rail 

At approximately 1235 hours while performing HATS Category IX – Check for Conscious 

Animals on the Rail, I observed the following non-compliance: a shackled butcher hog 

that seemed to be vocalizing and blinking. I moved closer to inspect further. I found the 

animal had rhythmic breathing, eye tracking, and displayed the righting reflex. I 

determined that this animal was still conscious and notified plant personnel and 

management immediately. The animal was stunned again with a captive bolt device and 

rendered unconscious. I placed U.S. Reject tag number B23747923 on the rail. I contacted 

the district office with the information regarding this egregious event as defined in the 

humane handling directive for the DM’s assessment. I verbally notified Mr. Smith, 

Establishment Owner, of the non-compliance with regards to consciousness on the rail 

and the forthcoming non-compliance and with the explanation for the regulatory control 

action taken. I informed him of the DM’s impending assessment of this egregious event.

HATS Category IX non-compliance is due to animal(s) regaining consciousness which are 

egregious and would result in further enforcement action (NOS or a NOIE in lieu of a 

NOS).

Sample GCP Poultry NR

At approximately 1530 hours, while performing a Good Commercial Practices verification 

task, I observed the following non-compliance with regulation 9 CFR Part 381.65(b): At 

1530 hours, the inspector at Inspection Station number 1 identified five cadaver birds 

without a bleed cut on the neck. I presented the cadavers to Mr. Smith, Evisceration 

Supervisor and then preceded to the re-hang area and noted twenty cadavers on the rehang table without a bleed cut on the neck and an additional fifteen cadavers in a U.S. 

Condemn barrel next to the re-hang table that did not have a bleed cut on the neck. I 

preceded to the area just prior to the scalder and noted five additional birds enter the 

scalder still breathing and conscious. These birds did not appear to have a neck cut. I then 

preceded to the kill line and found no back-up cuter present at the station located just past 

the automatic knife. Additionally, stunned birds were passing through the automatic 
FOR INTERNAL USE ONLY 

Follow-up Action Items

• Provide additional or follow-up information and resources as needed

based on site visit discussion.

NOTE: The DVMS has flexibility to assign/change a planned HHVV/GCPVV

to a DEOV when conducting assessment visits to small and very small 

establishments, if the occasion arises. For example, if a HHVV/GCPVV is 

scheduled and for some reason no animals are present for slaughter, at the 

consent of establishment management, the DVMS could conduct a DEOV. 

38

• Enter evaluation feedback of DEOV from both the establishment

management official and the DVMS in the survey on the DVMS SharePoint

site (Appendix 2 on page 21).

knife cut without the neck being cut and some birds were passing above the 

blade not stunned. I requested that Mr. Smith immediately stop the kill line 

and placed U.S. Reject tag number B15759535 to the hanging area. Mr. Smith 

and additional supervisors adjusted the stunner and the automatic knife to 

ensure proper stunning and bleed cuts as well as added additional back-up 

employees after the automatic knife. Any birds prior to the scalder that were 

still conscious, breathing or did not have bleed cuts were cut and bleed out 

and returned to the line. Mr. Smith confirmed an additional forty cadavers 

were condemned per regulation 9 CFR Part 381.90. After corrective actions 

and preventative measures were reviewed, I removed the U.S. Reject tag 

from the hanging area and the line was allowed to restart. 
FOR INTERNAL USE ONLY 

Appendix 6: 

Pilot Outreach Program (POP)

3 9
Pilot Outreach Program (POP)

Background/Participation

The POP visit framework was developed to test the one-on-one outreach 

approach to humane handling in small and very small establishments outlined 

in the FSIS Annual Plan FY 2019 linked to the Strategic Plan FY 2017–2021. 

The purpose was to assess the processes developed for the DEOV. 

• District Office (DO) Participation – 3 Districts and 5 DVMSs were chosen to

participate in the POP to provide a small test group of locations. DVMS

volunteers were based on participation in the development of the

outreach program.

o Raleigh District Office (DO80)

 Dr. Travis Auxier

 Dr. Arial Thompson

o Des Moines District Office (DO25)

 Dr. Renee Larson

 Dr. Claire Hotvet

o Dallas District Office (DO40)

 Dr. Adil Abdalla

• Establishment Selection - 11 establishments participated in the POP.

Selections were made to include both small and very small establishments

to determine if there are any significant differences in outreach

effectiveness.

o DO80 Raleigh

 M5911 A & M Packing

 M5439 Kleemeyer & Merkel, Inc.

 M3940 Fauquier’s Finest

 M8496 Central Meat Packing

o DO25 Des Moines

 M7627 North Dakota State University Meat Laboratory

 M19717 Lynch BBQ Company

 M34283 Custom Meats of Marathon, Inc.

 M1361 VPP Group, LLC

o DO40 Dallas

 M13324 K & C Meat Processing

 M21179 J & J Packing Co., Inc.

 M34660 Tran Meat Corporation

FOR INTERNAL USE ONLY 4 0
POP Visit Procedures

The outreach activities and resources used may vary depending on the individual 

establishment’s pre-visit data review and/or requests from establishment 

management. Overall, the one-on-one visits should follow the approach outlined 

below.

• Pre-visit Data Review

o Review establishment information since the previous DVMS HHVV/

GCPVV documented in PHIS. DVMS will review PHIS and local files to

identify trends through HHEAs, HHNRs, HHMOIs, LOCs, etc.

o Contact establishment management to set-up a mutually agreed upon

time and location for the DEOV.

 DVMS is to ask the establishment if they have any specific topic

requests and if they have a format preference (electronic

documents, paper copies, PowerPoint presentations, etc.).

o Contact FLS and IPP to check for any establishment-specific concerns.

• Outreach Visit Component

o Introduction and Explanation of a DEOV as opposed to the HHVV/GCPVV.

o Review/Explanation of relevant information in the FSIS Directive

o Explanation of how “adequate” restraint, or lack thereof, has been

identified and associated with trends in HHNRs and HHEAs.

o Explanation of how the regulated industry’s stunning decisional

methodology (especially in small and very small establishments) has

been associated with trends in HHNRs and HHEAs.

o Complete a walk-through of the facilities related to humane handling.

o Review/Explanation of how OFO considers the issuances of HHMOIs,

weekly meeting MOIs, HHNRs, and HHEAs as providing communication

and part of Due Process as required by regulation 9 CFR Part 500.

 Explanation of the various aspects of HHEAs (NOIE versus NOS and

NROS, etc.).

 Steps/Progression of events from time of notification of an

incident, mitigation of enforcement action, verification

period, and closeout procedures, including expected

timeframes.

 Explanation of the Agency’s position on establishments with

repetitive HHEAs for same/similar causes (referral to ELD).

FOR INTERNAL USE ONLY 41
FOR INTERNAL USE ONLY 

o Additional topics if requested by the establishment either during the initial

contact or during the course of discussions.

o RSA discussion/review in light of covered topics.

o Ask for feedback of visit from establishment.

 Usefulness, material format, etc.

o Post Outreach Visit Actions

o Complete Report in PHIS:

 Complete data entry in PHIS for FSIS Form 6000-31 for livestock

and/or FSIS Form 6000-32 for poultry;

 Under Reason for Visit (Box 12) - Check "Special Correlation/Other"

and type "Outreach" in the Other Reason text box;

 List personnel present during discussion in Box 15

(Narrative - Correlation);

 Document topics discussed in Box 15 (Narrative - Findings); and

 Document resources shared in Box 15 (Narrative - Findings).

o Outreach Analysis

o Provide feedback to the workgroup, both personal experience and from

establishment management.

o Develop summary analysis from the POPs.

o Modify the plan/resources as needed.

o Track DEOV data as part of annual and strategic plan reporting.

POP Analysis

Background: As the Outreach Workgroup worked to develop the DEOV Plan we 

wanted to ensure that our process would be effective and functional. In that vein, we 

did a pilot project to assess the DEOV process developed for this plan. The analysis 

below outlined what worked, what could use improvement, and lessons learned. We 

took those lessons and made changes to the process to advance the methodology.

What Worked Well in Executing the POP Visit?

• Calling in advance helped in the explanation of the visit purpose, set-up date and

time for the visit, and allowed meeting and discussion with the appropriate

management personnel available on the day of the visit.

• Outreach discussion was generally well received. Discussions included humane

handling regulations, other related FSIS policies and most causes of humane

handling non-compliance.

• Resource material was provided including a DVD copy of resource material. Some

pilot establishments were provided paper resources. There were others that had

a RSA program and had no interest in any additional humane handling materials.

4 2
FOR INTERNAL USE ONLY 

• Walking through the establishment during slaughter operations eased the

discussion about the most vulnerable areas, potential humane handling

violations, different preventive measures, and areas for improvement.

• Outreach visits performed as part of the POP experience felt more relaxed for

the DVMSs.

What Did Not Go Well During the POP Visit?

• One establishment was apprehensive on doing an outreach visit. They had no

interest in doing a walk-through of the facility with the DVMS but did provide

time for a discussion on humane handling, which centered on big picture items

and how districts operate differently across the country. This establishment has

a RSA program.

• One establishment owner had minimal interest in the DEOV, stating they

“heard it all before.”

• Some managers stated they did not see the difference between the DEOV and

the routine HHVVs/GCPVVs. Some stated that the same discussion/

conversations are done during the routine HHVV/GCPVV assessment.

• There was a statement that the Agency is wasting too much time and resources

on animal welfare, rather than food safety.

What Were the Lessons Learned?

• Even though the DVMS called and scheduled the visits in advance, they did not

get any requests for information prior to the visit, or any specific questions

generated during the visit. The advanced call is still productive, as most

establishments stated they would talk with their teams prior to the visit and see

if they had any animal welfare topics of concern.

• Very small establishments seemed to be more apprehensive on bringing up

questions or concerns.

• The outreach in the majority of visits was well received, even if the owner/

management did not feel as though we could offer them any useful information.

• Speaking candidly and plainly with owners/management on humane handling in

general did generate some input from the establishments on improvements

specific to their facility.

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• At the small establishment with a RSA in place, management was quite candid

on the importance of good communication with the assigned in-plant team,

but they had concerns on how humane handling tasks are done and

enforcement actions are taken in small versus large establishments.

• There is a general consensus from a noteworthy portion of the establishments

participating in the POP, that the DEOV is more of the same type of

information given during the outreach component of the routine HHVV/

GCPVV.

• Outreach should be targeted to the most vulnerable establishments with

repeated and/or increased number of humane handling violations.

What Impact Does This Have on the DVMS Methodology for executing DEOV 

Goals?

• DEOV should be done per request, for new establishments, and to target

establishments identified by the DO as most vulnerable, with repeated and/or

increased number of humane handling violations or GCP concerns.

• The DEOV should be documented in much the same way that traditional DVMS

HHVVs/GCPVVs are documented, in PHIS, but identified as "Outreach".

o Information reviewed in advance of a DVMS HHVV/GCPVV is the same

information reviewed for the DEOV.

o A walk-through of the facility proved very helpful even when no animals

were present.

o Additional information in the DEOV report would include topics of

discussion (without specific information about the establishment, as this

could be proprietary) and resources provided and/or requested by

owner/management.

• DVMS follow-up should be performed on an as-needed basis:

o Must follow-up with establishments that request additional resources.

o Any other follow-up requests should be done at a higher level (District

Manager [DM] or Headquarters [HQ]).

FOR INTERNAL USE ONLY 4 4
FOR INTERNAL USE ONLY 

• Tracking the DEOV can be accomplished by the DVMS in each individual

District. A District summary at the end of each FY would provide HQ with an

overall sense of how many DEOVs are being performed.

Conclusion/Next Steps

• Overall, the POP visits were helpful and sharing of resource material, even if

not requested, is proactive on the Agency’s part. Even in establishments where

the owner/management stated that this was redundant information, the

communication bridges built were supportive.

• Encourage establishments to participate in Industry and/or Agency meetings

and voice their opinions.

• Strongly suggest considering regional outreach meetings (e.g., district town

hall) or in conjunction with some other event. For example, in the Des Moines

District, the Enforcement Investigations Analysis Officers (EIAOs) work with

universities (Iowa State University, the University of Minnesota, the University

of Wisconsin, and South Dakota State University) on yearly food safety

summits. DVMSs can be proactive in seeking a window of time at these types of

meetings to talk about humane handling/GCP outreach.

• Work with the FLSs on participating in a walk-through for the start-up of a new

slaughter establishments or have the first DVMS visit focus more on outreach

than regulatory verification.

• Reassess the DEOV process to ensure we are making the most impact after the

first year and then as needed.

• Ensure that the DVMS has flexibility to assign/change a planned HHVV/GCPVV

to a DEOV when conducting assessment visits to small and very small

establishments, if the occasion arises. For example, if a HHVV/GCPVV is

scheduled and for some reason no animals are present for slaughter, at the

consent of establishment management, the DVMS could conduct a DEOV.

• The Outreach Workgroup acknowledges that as a voluntary program there may

be low participation. We suggest tracking in the evaluation/feedback survey on

the DVMS SharePoint site that the outreach contact be noted and that the

offer was declined. We can then use that data in the review of this program.

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USDA