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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 212 

EstNbr EstName MOINbr 

P510 House Of Raeford Farms RHB13131 

00621G 

Date 

21OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Subject: Poultry Good Commercial 

Practices / Documentation of a live bird about to 

enter the scalder. On 10/21/19 at 

approximately 0537 hours I was conducting part 

of the Good Commercial Practice verification task 

in the evisceration department. I was observing 

birds going by on the line from the bleed out 

tunnel before they entered the scalder. One of 

the birds going by was blinking, had his head 

partially elevated, and was looking around. I 

pointed out my concern to 

(b) (6)

the

(b) (6)

 The line was stopped 

before the bird entered the scalder.  The bird was 

removed from the line.  It was blinking, looking 

around, and had rhythmic breathing. It had a 

visible bruise on the ventral neck area, but the 

neck did not have a cut on it. I discussed the 

concern with the plant not following GCP 

regulation.  Per 9 CFR 381.65 (b) 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. The bird 

was returned to the line after the hangers. 

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

stationed a second back up killer after the 

neck cutter blade. He had maintenance 

department adjust the blade.  He also found an 

issue with one of the automatic blade guides 

which was misaligned. 

(b) (6)

put a break in 

the line and had the maintenance department 

resolve the issue. The line was restarted.  I 

monitored the line and did not see any live birds 

enter the scalder.  A similar occurrence was 

documented on 10/07/19. See MOI/ 

RHB0411103107G. A copy of this MOI will be 

forwarded to the District Veterinary Specialist,

 and to the 

If you have any questions you can 

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

contact me or the 

(b) (6) . 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 213 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

Respectfully, 

(b) (6)

, Dayshift 

P510 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 214 

EstNbr EstName MOINbr 

P510 House Of Raeford Farms RHB18091 

12018G 

Date 

18NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Subject: Poultry Good Commercial Practices 

Task/ Documentation of a live bird which was 

about to enter the scalder. On 11/18/2019 at 

approximately 0536 hours while conducting part 

of the Good Commercial Practice verification task 

in the evisceration department I was observing 

the dead birds going by on the line before they 

entered the scalder. I noticed a bird that had his 

head elevated and was blinking.  The line was 

stopped by 

(b) (6) , 

and the bird was removed before it could enter 

the scalder.  The bird was breathing and looking 

around. Upon exam, there was not a visible cut on 

the bird’s neck. I discussed with 

(b) (6)

that per 

regulation 381.65 (b) in CFR 9 poultry must be 

slaughtered in accordance with good commercial 

practices in a manner that will result in thorough 

bleeding of the carcasses and ensure that 

breathing has stopped prior to scalding. The bird 

was taken back to the live hang area to be put 

back on the line. 

(b) (6)

reported he would 

discuss the issue with the backup cutter.  He also 

reported he would be monitoring the line and the 

backup cutter during the remainder of the shift. 

The issue was also discussed with 

He discovered 

an issue with the bird stunner, contacted the 

maintenance department and had the issue 

resolved. I continued to monitor the line as part of 

the GCP task and saw no further issues with live 

birds about to enter the scalder.  The most recent 

occurrence of this issue was on 10/21/2019. A 

copy of this MOI will be forwarded to the 

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

and to 

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

questions you can contact me or the

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

the If you have any 

Respectfully, , 

Dayshift P510 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 215 

EstNbr EstName MOINbr 

P510 House Of Raeford Farms RHB37100 

12631G 

Date 

31JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On 01/30/2020 at 11:38am I was conducting a 

portion of the Good Commercial Practice 

verification task in the evisceration department.  I 

was observing the birds going by on the 

evisceration line after exiting the blood tunnel 

near the first scalder.  I noticed a bird that had its 

head elevated and was looking around.  The line 

was stopped by 

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

and the bird was removed from it’s shackle. 

When I examined the bird it was breathing, 

looking around, and blinking. It did not have a cut 

on it’s neck. The bird was taken back to the live 

receiving conveyor belt. I discussed with the 

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

that per 

regulation 381.65 (b) in CFR 9 poultry must be 

slaughtered in accordance with good commercial 

practices in a manner that will result in thorough 

bleeding of the carcasses and ensure that 

breathing has stopped prior to scalding. He 

reported the automatic neck cutter appeared to 

be working adequately.  However, the 

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

had switched the 

backup cutter to a newer employee. 

discussed the issue with the backup cutter and 

with 

(b) (6)

. Their plan moving forward was to 

monitor the activity of the new back up cutter 

more closely through the remainder of the shift. I 

continued monitoring the birds on the line before 

they entered the scalder and saw no further 

issues. The last occurrence of a similar issue was 

documented on 11/18/2019. A copy of this MOI 

will be forwarded to the 

and to the circuit

(b) (6)

 If you have any questions 

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

you can contact me or the 

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

. 

Respectfully, , Dayshift 

P510 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 216 

EstNbr 

P51179+V5 

1179 

EstName 

Sanderson Farms, Inc. 

MOINbr 

RQE40170 

72503G 

Date 

03JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Open 

MOI Agenda 

Poultry Mistreatment Meeting at Est. P-51179, 

Sanderson Farms - Palestine in July 3, 2019 at 

approximately 1410 hours. In attendance: 

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

and John 

Stedman, Plant Manager At approximately 0515 

hours, on 25th of June 2019, while performing 

Poultry Good Commercial Practices task, 

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

observed that the 

unloading belt is faster than the live hang belt 

which results to live young chickens pile up on top 

of other live young chickens during the transfer 

process.  Piling up is worse at the corner where 

live young chickens are crammed by the diverter 

resulting at times to third pile of birds which 

obviously results to grave discomfort for the first 

and second pile of young chickens.  The next day, 

June 26, 2019,  I discussed my aforementioned 

concerns in the Weekly Establishment Meeting. 

Plant Manager Stedman said he will look into the 

issue.  Few days past by and the live young 

chickens in the live hang belts continue to pile on 

top of another. Again, I talked with Plant 

Manager Stedman about the aforementioned 

mistreatment of poultry concerns last July 2, 2019 

on which he said piling up of live young chickens 

on live hang belt is normal in all plants. 

(b) (6)

repeated his concerns on 

live young chickens piling on top of each other at 

the live hang belts.  Plant Manager Stedman said 

he believes there is nothing wrong with young 

chickens piling on top of each other and there is 

no mistreatment of poultry.  He further said that 

he would consult 

(b) (6)

of DVMS.  And, he 

said, he would appeal the MOI that will be 

written. I recommended to Plant Manager 

Stedman to review the Federal Register Notice 

Vol. 70, No. 187, published September 2005 

(Docket No. 04-037N). I also notified 

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

that this 

Memorandum of Interview (MOI) will be written 

(b) (6)
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 217 

EstNbr EstName MOINbr 

P517 Mar-Jac Poultry-MS QOO39020 

45526G 

Date 

26APR2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

which will be forwarded to the District Office and 

the District Veterinary Medical Specialist (DVMS) 

in case additional follow up is recommended. 

Respectfully, 

(b) (6)

, Night Shift 

Relief IIC of Est. P51179, Sanderson Farms at 

Palestine.

(b) (6)

 Mar-Jac 

Poultry, MS 1301 James Street Hattiesburg, MS 

39401 

(b) (6)

At approximately 2202 hours 

on April 25, 2019, the following less than Poultry 

Good Commercial Practices (GCP) incident was 

observed at P517, Mar-Jac Poultry, Hattiesburg, 

MS. The employees had gone to break without 

removing DOA birds from the DOA conveyor, nor 

the pile on the floor adjacent to the South live 

hang conveyor. 

(b) (6)

observed chest 

movement and paw movement in the pile on the 

conveyor. It took approximately five minutes after 

notification for establishment personnel to begin 

attempting resolution of the situation. During 

resolution two birds were observed trapped 

among DOAs. Comingling live birds and DOAs 

can lead to suffocation and death. Poultry 

slaughter establishments must take every 

precaution to ensure poultry under their control 

on the official premises are treated in a humane 

manner, subjected to minimal excitement, 

discomfort, and injury, or death by means other 

than slaughter. 

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

met with 

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

at approximately 2110 hours on the live 

hang dock to discuss the less than GCP incident. 

Rob Jones was advised a GCP Memorandum of 

Interview would be issued to management 

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

pending review by . 

Respectfully, 
-

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-

_______________________________________ 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 218 

EstNbr EstName MOINbr 

P517 Mar-Jac Poultry-MS QOO40050 

52328G 

Date 

28MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda

(b) (6)

 Mar-Jac 

Poultry, MS 1301 James Street Hattiesburg, MS 

39401 

(b) (6)

At approximately 2050 hours 

on May 27, 2019, the following less than Good 

Commercial Practices (GCP) incident was observed 

at Mar-Jac Poultry in Hattiesburg, MS. One (1) 

alert live young chicken with no cut to its neck, 

it's head raised, and vocalizing from an 

approximate 500 bird random subgroup sample 

entered the scald tank on the north picking line 

which feeds evisceration line #1. 

(b) (6) , 

(b) (6)

, was verbally notified of the 

incident at approximately 2055 hours. A second 

verification check of an approximate 500 bird 

random subgroup sample on the north picking 

line did not have any live bird(s) entering the scald 

tank. This incident was determined to be an 

isolated event and not a loss of process control or 

systemic event. Allowing bird(s) to enter the 

scald tank while still breathing is a less than GCP 

and causes needless suffering and death and 

results in adulterated product. Poultry slaughter 

establishments must take every precaution to 

ensure poultry under their control on the official 

premises are treated in a humane manner, 

subjected to minimal excitement, discomfort, and 

injury, or death by means other than slaughter. 

(b) (6)

was advised a GCP Memorandum of 

Interview would be issued to management 

pending review by 

(b) (6) . 

Respectfully, . 

(b) (6)
 

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_______________________________________ 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 219 

EstNbr EstName MOINbr 

P517 Mar-Jac Poultry-MS QOO39050 

73502G 

Date 

02JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda

(b) (6)

 Mar-Jac 

Poultry, MS 1301 James Street Hattiesburg, MS 

39401 

(b) (6)

, At approximately 2057 hours 

on July 1, 2019, the following less than Good 

Commercial Practices (GCP) incident was observed 

at Mar-Jac Poultry in Hattiesburg, MS. One (1) 

alert, live, young chicken with no cut to its neck, 

it's head raised, breathing, and blinking from an 

approximate 500 bird random subgroup sample 

entered the scald tank on the north picking line 

which feeds evisceration line #1. 

, were 

verbally notified of the incident at approximately 

2059 and 2105 hours respectively. A second 

verification check of an approximate 500 bird 

random subgroup sample on the north picking 

line at approximately 2130 hours did not have 

any live bird(s) entering the scald tank. This 

incident was determined to be an isolated event 

and not a loss of process control or systemic 

event. Allowing bird(s) to enter the scald tank 

while still breathing is a less than GCP and causes 

needless suffering and death and results in 

adulterated product. Poultry slaughter 

establishments must take every precaution to 

ensure poultry under their control on the official 

premises are treated in a humane manner, 

subjected to minimal excitement, discomfort, and 

injury, or death by means other than slaughter. 

(b) (6)

(b) (6)

(b) (6)

was advised a GCP Memorandum of 

Interview would be issued to management 

pending review by 

Respectfully, . 

(b) (6)

(b) (6)
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 220 

EstNbr EstName MOINbr 

P517 Mar-Jac Poultry-MS QOO56040 

73317G 

Date 

17JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda

(b) (6)

 Mar-Jac 

Poultry, MS 1301 James Street Hattiesburg, MS 

39401 

(b) (6)

, At approximately 2045 hours 

on July 16, 2019, the following less than Good 

Commercial Practices (GCP) incident was observed 

at Mar-Jac Poultry in Hattiesburg, MS. 

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

observed two (2) live birds 

(bright, alert, and responsive) in a pile at the end 

of the line 1 conveyer belt in live hang where they 

were comingled with at least 8 DOA birds. One of 

the live birds was partially covered/surrounded by 

the DOAs. 

(b) (6)

was verbally notified and shown the incident at 

approximately 2045 hours. Comingling live birds 

with DOAs can cause suffocation and death by 

means other than slaughter resulting in 

adulterated product. The establishment must 

ensure that birds under their control on the 

official premises are treated in a manner that will 

minimize discomfort, injury, and/or death by 

means other than slaughter. 

(b) (6)

was 

advised a GCP Memorandum of Interview would 

be issued to management pending review by 

Respectfully, . 

(b) (6) (b) (6) (b) (6)
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 221 

EstNbr EstName MOINbr 

P517 Mar-Jac Poultry-MS QOO23031 

02923G 

Date 

23OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda

(b) (6)

 Mar-Jac 

Poultry, MS 1301 James Street Hattiesburg, MS 

39401 

(b) (6)

At approximately 0035 hours 

on October 23, 2019, the following less than 

Good Commercial Practices (GCP) incident was 

observed at Mar-Jac Poultry in Hattiesburg, MS. 

On three sequential cage dumps, 

observed the cage of birds emptied 

(b) (6)

(b) (6)

on top of birds that were already on the conveyor 

belt for the South picking line. This resulted 

in multiple incidents of a pile of live birds at least 

two birds deep on the conveyor belt with many 

birds completely covered. 

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

was verbally notified of the incident at 

approximately 0100 hours. Burying live birds 

under other birds can cause injury and/or 

suffocation and death by means other than 

slaughter resulting in adulterated product. The 

establishment must ensure that birds under their 

control on the official premises are treated in a 

manner that will minimize discomfort, injury, 

and/or death by means other than slaughter. 

(b) (6)

was advised a GCP Memorandum of 

Interview would be issued to management 

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

(b) (6)

pending review by . 

Respectfully, , 
-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 222 

EstNbr EstName MOINbr 

P517 Mar-Jac Poultry-MS QOO04001 

12421G 

Date 

21NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda

(b) (6)

 Mar-Jac 

Poultry, MS 1301 James Street Hattiesburg, MS 

39401 

(b) (6)

At approximately 2048 hours 

on November 20, 2019, the following less than 

Good Commercial Practices (GCP) incident was 

observed at Mar-Jac Poultry in Hattiesburg, MS. 

One (1) alert, live, young chicken with no cut to its 

neck, it's head raised, breathing, and vocalizing 

from an approximate 500 bird random subgroup 

sample entered the scald tank on the north 

picking line which feeds evisceration line #1. 

as verbally notified of the incident at 

(b) (6)

approximately 2050 hours. A second verification 

check of an approximate 500 bird random 

subgroup sample on the north picking line at 

approximately 2055 hours did not have any live 

bird(s) entering the scald tank. This incident was 

determined to be an isolated event and not a loss 

of process control or systemic event. Allowing 

bird(s) to enter the scald tank while still breathing 

is a less than GCP and causes needless suffering 

and death and results in adulterated product. 

Poultry slaughter establishments must take every 

precaution to ensure poultry under their control 

on the official premises are treated in a humane 

manner, subjected to minimal excitement, 

discomfort, and injury, or death by means other 

than slaughter. 

(b) (6)

was advised a GCP 

Memorandum of Interview would be issued to 

management pending review by 

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

. Respectfully, . 

(b) (6)
  

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 223 

EstNbr EstName MOINbr 

P519 Wayne Farms LLC KMH23011 

02504G 

Date 

04OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda

(b) (6)

 Wayne 

Farms 525 Wayne Drive Laurel, MS 39440 

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

At approximately 2150 

hours on October 03, 2019, the following less 

than Good Commercial Practices (GCP) incident 

was observed at Wayne Farms in Laurel, MS. 

(b) (6)

observed two (2) live birds (one 

bright, alert, and responsive; one dull but 

responsive) in a pile at the end of the conveyer 

belt in live hang where they were comingled with 

at least 30 DOA birds. One of the live birds was 

partially covered/surrounded by the DOAs. 

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

, was 

verbally notified and shown the incident at 

approximately 2150 hours. Comingling 

live birds with DOAs can cause suffocation and 

death by means other than slaughter resulting in 

adulterated product. The establishment must 

ensure that birds under their control on the 

official premises are treated in a manner that will 

minimize discomfort, injury, and/or death by 

means other than slaughter. 

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

was advised a GCP Memorandum of 

Interview would be issued to management 

pending review by 

Respectfully, 

39440 cc: 

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

(b) (6)
 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 224 

EstNbr EstName MOINbr 

P522 Sanderson Farms, Inc. (Processing Div) IKB580504 

4326G 

Date 

26APR2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On April 26, 2019 at approximately 0456 hours 

while conducting a Good Commercial Practice 

check in the Picking Room of establishment 

P-522, I observed sufficient evidence to support 

that the stunner located on the inside picking line 

was inoperable and as such approximately 54 

conscious birds drowned when the picking line 

was stopped

 was informed of the forthcoming 

GCP MOI documenting this incident. 

Respectively, 

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

(b) (6)

P522 Sanderson Farms, Inc. (Processing Div) IKB500605 20MAY2019 04C05 Poultry Good 

2320G Commercial 

Practices 

Finalized On May 20, 2019 at approximately 0518 hours 

while conducting a Good Commercial Practice 

check in the Picking Room of establishment 

P-522, I observed sufficient evidence to support 

that the stunner located on the inside picking line 

was inoperable and as such approximately 28 

conscious birds drowned when the picking line 

was stopped.  Additionally, I observed 8 live birds 

enter the scalders on the inside picking line. There 

was no blood or cut on the neck of the birds.  The 

birds were alert, blinking their eyes and looking 

around as they hung on the Picking Line. 

nd Brandon 

(b) (6)

(b) (6)

Macloud, Plant Manager, were notified of the 

pending MOI. Respectively, 

(b) (6)

(b) (6)
 

 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 225 

EstNbr EstName MOINbr 

P522 Sanderson Farms, Inc. (Processing Div) IKB541610 

1529G 

Date 

29OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

October 29, 2019 

Farms, Inc., Collins MS 

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

1111 

N. Fir Avenue Collins, MS 39428 

At approximately 0932 hours while 

performing the PHIS Poultry Good Commercial 

Practices verification task, the following less than 

Good Commercial Practice (GCP) was observed. 

One (1) live chicken with raised head, rhythmic 

breathing, pupillary reflexes, and no visible cut to 

the neck entered the scalder on the outside 

picking line which feeds evisceration lines 3 and 

4. 

was notified of the incident at approximately 

0942 hours.  A second verification of the outside 

picking line was conducted at approximately 1036 

hours after the scheduled lunch break.  No birds 

entered the scalder during this observation.  This 

was determined to be an isolated event and not a 

loss of process control. Birds must not be 

breathing at the point they enter the scalder to 

avoid unnecessary suffering and death by means 

other than slaughter.  Every effort must be made 

by the establishment to prevent injury, 

unnecessary suffering, and death by means other 

than slaughter for birds which have come onto 

the official premises and are under their control. 

(b) (6)

A meeting was held in the Quality Control 

Manager’s office at approximately 1045 hours to 

discuss the preceding incident. 

stated the incident was under 

investigation and a cause had yet to be 

determined. 

(b) (6)

stated once a cause had 

been determined, corrective actions would be 

implemented. 

(b) (6)

was advised a GCP 

Memorandum of Information would be issued 

after review by 

District Office. Respectfully submitted, 

were present. 

(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 226 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

Office of Field Operations DO-90, Jackson Food 

Safety and Inspection Service, USDA 713 S. Pear 

Orchard Rd. Ridgeland, MS 39157 cc: 

(b) (6) (b) (6) (b) (6) (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 227 

EstNbr EstName MOINbr 

P522 Sanderson Farms, Inc. (Processing Div) IKB071211 

4606G 

Date 

06NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

November 6, 2019 

(b) (6)

Sanderson 

Farms, Inc., Collins MS Division Manager 1111 

N. Fir Avenue Collins, MS 39428 

(b) (6) , 

At approximately 1133 hours while 

performing the PHIS Poultry Good Commercial 

Practices verification task, the following less than 

Good Commercial Practice (GCP) was observed. 

One (1) live chicken with raised head, rhythmic 

breathing, pupillary reflexes, and no visible cut to 

the neck entered the scalder on the outside 

picking line which feeds evisceration 

(b) (4)

and (b) (4)

A second verification of the outside picking line 

was conducted at approximately 1135 hours.  No 

birds entered the scalder during this observation. 

This was determined to be an isolated event and 

not a loss of process control. 

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

was notified of the 

incident at approximately 1142 hours 

Birds must not be breathing at the point they 

enter the scalder to avoid unnecessary suffering 

and death by means other than slaughter.  Every 

effort must be made by the establishment to 

prevent injury, unnecessary suffering, and death 

by means other than slaughter for birds which 

have come onto the official premises and are 

under their control. A meeting was held 

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

(b) (6)

(b) (6)

with at approximately 1245 hours to 

discuss the preceding incident.  , 

were present.  stated the incident was 

under investigation and a cause had yet to be 

determined. 

(b) (6)

stated once a cause had 

been determined, corrective actions would be 

implemented. 

(b) (6)

was advised a GCP 

Memorandum of Information would be issued 

after review by 

District Office. Respectfully submitted, 

(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 228 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda

 DO-90, Jackson Food 

Safety and Inspection Service, USDA 713 S. Pear 

Orchard Rd. Ridgeland, MS 39157 cc: 
■ 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 229 

EstNbr EstName MOINbr 

P529+V529 Pilgrim's Pride Corporation ODE35100 

61226G 

Date 

26JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 0310 on Tuesday June 18, 2019, 

I was notified by 

(b) (6)

that an 

on-line USDA food inspector had condemned two 

cadavers within a five-minute period. I evaluated 

the two carcasses hanging behind the inspector's 

stand, they appeared bright red to purplish with 

no evidence of a cut on their neck. I notified 

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

of our findings. He 

implemented his corrective actions which 

consisted of raising both the stunner and the 

automatic neck cutter to compensate for the bird 

size variation. He also mentioned that if more 

cadavers are encountered the back-up cutter 

would be substituted. As I walked to the 

inspector's stand at around 0330, I noticed two 

more cadavers hanging behind one of the 

inspector's stands and two more cadavers 

recorded on the lot tally sheet of a different 

inspector; all on line two. I went out to the live 

hang area to evaluate the stunning and cutting 

machinery, both of which appeared to be working 

properly. Then I stood by at the end of the blood 

tunnel to evaluate the birds bleed out and noticed 

an uncut bird. Upon further evaluation the neck 

was extended downward, and no blood stain or 

cut was noticed on the neck region. 

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

, was immediately 

notified of the uncut bird at around 0345 and he 

said that the back-up cutter will be replaced. I 

then went to the transfer table to wait  for the 

cadaver and condemned the carcass at that 

point.  At around 0420, while giving breaks to

(b) (6)

 approached 

me to indicate that there were three more 

cadavers identified by three inspectors on line 

one. After finishing giving breaks, I went and 

looked at the cadavers inside the condemned 

barrels and they looked bright red with no 

evidence of a cut on their neck. Then I went to Kill 

and Pick to notified

(b) (6)

 of the 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 230 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

cadavers found on line one. In addition, 

mentioned that the week before (Wednesday 

June 12, 2019) management was informed of one 

inspector finding three cadavers in less than 10 

minutes right before lunch. That day there were 

12 cadavers in total for the night shift. The next 

day (Thursday June 13, 2019) there were 20 

cadavers in total for the night shift.  This topic 

was discussed at the weekly establishment 

meeting Thursday June 13, 2019 at 0545. The 

establishment's corrective action was to re-train 

the back-up cutter and talk about humane 

handling and animal welfare. 
-

...... 

-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 231 

EstNbr EstName MOINbr 

P529+V529 Pilgrim's Pride Corporation ODE58121 

23723G 

Date 

23DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Wednesday 12-11-2019 at 0600, I 

(b) (6)

was informed by 

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

that a 

mod of 360 birds was left on a truck from 

dayshift. The birds were left on a trailer at the 

holding shed for approximately 6-8 hours in 

temperatures below 10 degrees Fahrenheit. 

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

was notified about 

the mod. The mod was returned to the plant and 

ran immediately, resulting in 39 DOA's of the 360 

birds ran. While gathering more information 

Thursday 12-12-2019, I determined the DOA's 

were not included on the daily summary report 

provided by the establishment; however, it was 

noted these were included on the original lot. 

That afternoon I contacted Processing

(b) (6)

 and we talked 

about what happened. I was told it was due to 

new personnel not following the procedure of 

verifying the farm weight less the plant weight 

(was outside of -250 to 890 pounds) after the 

truck weights were entered into Mtech (gross and 

tare). After our discussion of the incident, I 

informed 

(b) (6)

that I would be 

documenting our discussion in a GCP MOI. The 

establishment must employ humane methods of 

handling and slaughtering consistent with Good 

Commercial Practices in a way that minimizes 

injury to poultry. 
- ■ 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 232 

EstNbr EstName MOINbr 

P533 Poultry Holdings, LLC AKB00210 

43525G 

Date 

25APR2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 2020 hours while performing a 

walkthrough of the live receiving area my 

, and I observed a live bird in the DOA 

auger which at this point was still off and not 

running. The bird was upside down with its head 

in the auger and struggling to breath when we 

saw it. We informed 

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

immediately and he removed the bird 

which started vocalizing and flapping its wings as 

soon as it was removed from being lodged head 

first into the auger. Also, one of the bird's wings 

had been badly broken and mutilated and overall 

the bird appeared to be in intense pain. I saw 

them place the bird back over in the live hang 

area to be properly slaughtered. After speaking 

with

(b) (6)

 he immediately started 

instructing the plant employees on the 

importance of making sure that the birds are 

definitely deceased before they are placed in the 

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

DOA auger. After speaking with 

(b) (6) , 

, I was informed that he 

would speaking with about the 

situation to resolve the issue further and verify 

that this will not occur again in the future. In the 

past USDA was told that if a bird appeared that it 

might still be alive that it would be properly and 

humanely euthanized by a trained supervisor or 

department lead employee before being placed in 

the DOA auger. 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 233 

EstNbr EstName MOINbr 

P533 Poultry Holdings, LLC AKB00070 

95424G 

Date 

24SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On 9/24/19 at approximately 0530 hours I, 

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

was performing a Poultry Good 

Commercial Practices task in the Live Hang Area. I 

was observing the kill blade when I noticed a large 

number or birds had broken and bloody wings. I 

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

immediately notified and 

of my findings. 

We then proceeded to watch the line and 

observed several more birds with broken wings. 

(b) (6)

acknowledged that it 

was an excessive amount and stated he would 

investigate it. I then informed 

of my findings. This incident is not in keeping 

with Good Commercial Practices, especially those 

practices related to the humane handling of live 

poultry. This MOI serves as a written notice that 

future oversight of this nature may result in the 

taking of additional administrative actions. Please 

submit documentation of corrective and 

preventative measures relating to this incident. 

(b) (6)
• 

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■ 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 234 

EstNbr EstName MOINbr 

P533 Poultry Holdings, LLC AKB03070 

13307G 

Date 

07JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On January 7, 2020 at approximately 0650 hours 

I, 

(b) (6)

, was performing a Poultry 

Good Commercial Practices task in the New York 

Room. As I was walking through the New York 

room I observed a bright red chicken carcass 

going down the line towards the rehang table. I 

immediately pointed the carcass out to the 

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

, he removed the 

carcass from the line and I confirmed that it was a 

cadaver.  I continued to observe the line and 

identified two additional carcasses within the next 

10 minutes that had a bright red appearance. In 

both instances I pointed them out to the 

Supervisor and confirmed that they were 

cadavers. I then went to the end of the blood 

trough, prior to the scolder. 

was standing with me when I identified a carcass 

that was flapping its’ wings, 

(b) (6)

immediately 

removed the chicken carcass from the line and 

ensured that it was bled out completely prior to 

hanging it back on the line. At this time I was 

informed by 

(b) (6)

that the kill blade 

was adjusted. I continued to observe carcasses 

hanging on the line just prior to the re-hangers, at 

approximately 0709 hours I observed two 

carcasses within 30 seconds of each other that 

were bright red. I pointed them both out the 

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

he removed them from the 

line and confirmed they were both cadavers. I 

informed 

(b) (6)

of my additional 

findings and he informed me again that the blade 

was adjusted, I also observed him standing at the 

blood trough ensuring the carcasses were 

bleeding out completely prior to entering the 

scolder. I continued to observe the line for an 

additional 20 minutes and did not observe any 

additional carcasses with the appearance of a 

cadaver. Please note, during the time of my 

observations there was one back up neck cutter 

after the kill blade. The regulations (9 CFR 
-

- -

-

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 235 

EstNbr EstName MOINbr 

P550 Simmons Prepared Foods, Inc. XWN00040 

82220G 

Date 

20AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

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 breathing has stopped before 

scalding, so that the birds do not drown, and that 

slaughter results in thorough bleeding of the 

poultry carcass. This MOI serves as a written 

notice that future oversight of this nature may 

result in the taking of additional administrative 

actions. Please submit documentation of 

corrective and preventative measures relating to 

this incident. Respectfully, 

(b) (6)

At approximately 23:58 hours, on August 18th, 

2019, while performing Good Commercial 

Practices in live hang I observed a discrepancy in 

their procedure of humane handling.  I observed 

no less than 30 birds on the floor due to the 

amount of birds coming in on the belt and being 

suffocated.  I had a conversation with 

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

about the DOA’s and pile up of birds 

on the belt. I also told 

(b) (6)

that his floor 

person was picking up the DOA's when I entered 

live hang. 

(b) (6)

told me that line 2 in Evis 

had been down for 30 minutes prior to me 

coming to live hang and that they had slowed 

down kill line 1. 

(b) (6)

said they probably 

should have slowed down the picking line first 

and the belt that the birds come on into the live 

hang area.  He also stated that the establishment 

takes humane handling seriously, and this 

situation would not happen again.  I thanked him 

for the information, and that ended our 

conversation. 
1111 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 236 

EstNbr EstName MOINbr 

P584 Pilgrim's Pride Corporation QLM21121 

11904G 

Date 

04NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Open 

MOI Agenda 

While performing an Animal Welfare/Good 

Commercial Practices observation and verification 

in the picking room on November 4, 2019 at 

approximately 1031 hours, 

and 

became aware of a concern. A live, conscious bird 

was observed on the outside line progressing 

through the blood trough section of the kill line. 

No evidence of the kill blade or back-up kill step 

was observed on the bird  This segment of the kill 

line is after both the kill blade and back-up kill 

steps. It was removed from the line by FSIS and 

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

brought to . 

who was present between the two 

kill blades at the time of the observation. 

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

took the bird from FSIS and had 

maintenance assess and adjust the kill blade. No 

further findings of live, conscious birds were 

observed prior to exit of the picking room. 

Measures to prevent the needless suffering, 

discomfort or death of poultry must be met 

throughout the entire slaughter process. The 

establishment failed to do so in this incident. In 

this incidence, poultry were not slaughtered in a 

manner that resulted in thorough bleeding of the 

poultry carcass and did not prevent the needless 

suffering and discomfort of poultry to ensure 

breathing has stopped before scalding. The 

establishment is reminded of the requirement to 

meet with 9 CFR 381.65(b) which states in 

part: " 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. " FSIS respectfully requests the 

establishment assess any opportunities or gaps 

that may have lead to this observation to ensure 

the poultry are handled and process in 

accordance with Good Commercial Practices. 

Documented by 

(b) (6)
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-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 237 

EstNbr EstName MOINbr 

P584 Pilgrim's Pride Corporation QLM00231 

15306G 

Date 

06NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Open 

MOI Agenda 

At approximately 0333 hours, 6th of November 

2019, I, Relief 

(b) (6)

observed the 

following while performing GCP verification task: 

one young chicken went past the head puller in 

Line 1 with intact neck and head, its head in 

righting position, eyes open, aware of its 

surroundings and entered the scalder few feet 

away.  I told 

(b) (6)

who was 

nearby about my observation.  I also told

 that the head puller is clogged, 

allowing many heads passed through it unpulled. 

promptly cleared the head puller 

of the clog and a maintenance man came and 

adjusted the head puller.  No more unpulled head 

passed through it thereafter. Few minutes 

earlier, at approximately 0330 hours, I saw 5 

whole young chickens with cherry red neck and 

carcass with head and neck intact at a 

condemned barrel by Line 1 hot rehang table.  I 

notified 

(b) (6)

of my 

observation. That prompted me to check the live 

hang line and  found the aforementioned one 

young chicken enter the scalder breathing. I 

reminded 

(b) (6)

that 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 also recommended to 

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

to review Federal Register Vol 70, No. 187, 

published September 2005 (Docket No. 

04-137N).  I also informed 

(b) (6)

that 

the MOI will be forwarded to the District Office 

and the DVMS in case additional follow-up is 

recommended. 
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■ 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 238 

EstNbr EstName MOINbr 

P6164A Foster Farms OIJ202108 

3226G 

Date 

26AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 1930 hrs on August 23, 2019, I, 

(b) (6)

, while performing a 

routine Good Commercial Practices (GCP) task, I 

observed an event not consistent with good 

commercial practices of poultry. The module 

dump operator dumped a module of birds into 

the receiving belt, then moved the empty module 

away from the dump chutes.  This revealed a 

single live bird tripping and flapping upon the top 

chute louvre in apparent injury from being 

pinched between the heavy steel module and the 

steel louvre.  I expected the operator—in 

accordance with standard procedure—to briefly 

stop the dump operation, walk out on the 

platform, and remove the bird to place it with the 

rest of the birds on the belt; however, the 

operator left the bird struggling while he began to 

move another module into place.  As the bird 

would likely be re-pinched again between the two 

heavy metal parts, I took the regulatory control 

action of directing the operator to briefly cease 

operation until the bird could be removed; 

however, the operator stopped operating the 

equipment after moving the next module fully 

into place, thereby re-trapping the bird.  So that 

the bird would not be further traumatized by 

being re-mashed between the sliding/pressing 

steel parts when the module was tilted, I directed 

the operator to wait until I could get a supervisor 

to remove the module and humanely release the 

trapped bird. I found the lead employee who 

radioed the nearest supervisor, 

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

however, as I was returning to the 

module dump, I observed another employee at 

the control station, dumping the module. I 

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

explained the event to . 

appeared and

 re-explained.  As the trapped bird had 

already been re-dumped (and presumably 

re-traumatized) and freed onto the belt, and 

(b) (6)
-

(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 239 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

assumed responsibility to restore 

GCPs, I released the equipment back into 

operation and slaughter processes resumed 

without further event. The establishment is 

reminded that the Poultry Products Inspection Act 

(PPIA), 21 U.S.C. 453(g)(5), as well as the Agency’s 

regulations (9 CFR 381.90), provide that carcasses 

of poultry having died from causes other than 

slaughter are considered adulterated and 

condemned. Further, regulations (9 CFR 

381.65(b)) require that poultry be slaughtered in 

accordance with good commercial practices. 

Compliance with these regulations helps ensure 

that poultry are treated humanely. 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 240 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

P6164A Foster Farms OIJ582009 06SEP2019 04C05 Poultry Good Finalized 

2506G Commercial 

Practices 

Est. P6164A, Foster Farms September 6, 2019, 

1245 hours In attendance: 

On 

(b) (6)

(b) (6)

September 6, 2019 at approximately 1035 hours 

at Est. P6164A Foster Farms, I, 

(b) (6)

, was 

performing inspections of the scalding tank area 

as part of a routine Good Commercial Practices 

(GCP) verification task when I observed signs of 

live young chickens mistreated before slaughter. I 

observed 1 large non-eviscerated carcass (#1) 

being transported by the chain between picker #2 

and #3 with brightly pink to red-tinged skin, intact 

neck, and attached purple-colored head. I asked 

, 

standing beside me to have the plant employee at 

(b) (6)

the pre-sorting station remove the carcass for me 

to examine it more closely. As the carcass 

approached the station, another similarly looking 

carcass (#2) emerged from picker #3. Upon 

further examination with . 

standing closely, I observed both necks intact 

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

aside from each having an approximately 1 mm 

diameter skin puncture lateral to the first cervical 

bone, damaged skulls, and blood engorged head 

and neck. The skull of carcass #1 was nearly 

entirely crushed with extensive crepitus and 

deformation. Reflecting the skin of carcass #1 

revealed normal tissue consistent with thorough 

bleed out (i.e. no signs of congested blood). 

Carcass #2 had an approximately 8 mm x 2 mm 

depression in the posterior skull. Reflecting the 

skin of carcass #2 revealed congested blood in the 

wings and the pectoral muscle, predominately 

cranially, which supports insufficient bleed out. Its 

death by means other than slaughter classifies the 
-

-

(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 241 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

carcass as a cadaver and adulterated product 

requiring condemnation. I communicated this to 

and applied U.S. Retain 

tag # B45141985 to both carcasses explaining my 

intent to maintain control of the product until 

necessary plant management and I finish 

reviewing the evidence and I verify condemnation. 

At approximately 1047 hours, as I proceeded to 

the live hang room to observe conditions, another 

similarly appearing carcass (#3) with intact 

engorged purple head and neck and red-tinged 

skin appeared at the pre-sorter station and was 

being removed from the line by the plant 

employee. In the live hang room, numerous birds 

were observed missing the automatic knife 

machine below their heads. The backup cutter 

was observed adequately cutting the necks of all 

the birds I observed missed by the machine. I did 

not observe any live birds entering the scalder.

 and I discussed the 

plant’s corrective measures. 

said the cutting machines would be raised, 

(b) (6)

(b) (6)

additional backup cutter added to help with the 

overwhelming number of birds missing the 

autoblade, and 500-bird GCP monitoring checks 

will be performed. Immediately afterward, I went 

back to the pre-sorting station for carcass #3. The 

carcass was not there. explained their 

determined it was another cadaver, and properly 

disposed of it. I proceeded to the QC office to 

team had taken the bird for assessment, 

(b) (6)

discuss the cadaver findings and eviscerate the 2 

retained carcasses with , 

present. The viscera of carcass #1 supported the 

(b) (6)

(b) (6)

carcass bled out sufficiently despite receiving a 

miscut. Carcass #2 had clearly congested viscera 

which coincides with the earlier determination of 
-, 

-

• 

- ■ 

-

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 242 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

corrective measures. In response to my inquiry 

about the results of the 500-bird GCP check, 

said 9 of 500 birds were miscut, 

which supports their decision to add another 

backup cutter until the problem is fixed. I relayed 

the importance of making sure the machinery, 

automatic knife, and/or backup cutting plant 

employees are functioning in a manner that 

enable them to meet the requirement to 

slaughter poultry in accordance with good 

commercial practices that result in thorough 

bleeding which causes breathing to stop before 

scalding. I provided notice of my forthcoming 

documentation, either in the form of 

memorandum of interview (MOI) or 

noncompliance report (NR), pending discussion 

with the District Veterinary Medical Specialist 

(DVMS). At approximately 1123 hours after the 

group discussion, I verified condemnation of the 

carcasses. I also returned to the live hang and 

scalding areas to verify adequacy of slaughter 

operations. No birds, aside from very small birds 

that were caught by the backup cutter, were seen 

missing the autoblade. A plant employee stood 

immediately after the neck puller to ensure no 

heads remain attached to birds and nothing 

enters the scalder breathing. I received guidance 

from the DVMS to document a MOI. At 

approximately 1245 hours, I explained to 

that the MOI documents discussion 

between IPP and establishment management 

about the poultry mistreatment event. No 

adulterated product was observed at the CI 

stand. After more checks, I continued to see the 

additional backup cutter at the neck puller 

clearing out tissue caught in the device, and I did 

it being a cadaver necessitating condemnation. 

agreed to condemn both carcasses. 

We continued to discuss the investigation and 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 243 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

Respectfully, 

not observe any more cadaver-related issues. 

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 244 

EstNbr EstName MOINbr 

P6164A Foster Farms OIJ042011 

1625G 

Date 

25NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On November 25, 2019, at approximately 1750 

hours, I, 

(b) (6)

, while 

providing swing shift coverage for P6164A, while 

on a routine Good Commercial Practices (GCP) 

inspection, observed an event not consistent with 

GCPs. The establishment slaughter system has of 

a three step approach for bleeding of the 

carcasses to ensure breathing has stopped prior to 

scalding: 1) a mechanical throat-slitting device, 2) 

an employee providing back-up throat slitting, 

and 3) a mechanical head pulling device.  Between 

hurdles #2 and #3, I observed passing on the 

evisceration line the body of a large bird that had 

been beheaded and hanging by one leg.  Beside it 

hung a smaller bird that was alive and fully alert.  I 

waited to allow the system to complete; however, 

after the live bird passed the third step still alive 

and alert—prior to entering the first of 

several boiling scalding tanks—I took the 

regulatory control action (RCA) of briefly stopping 

the line, as attempting to remove the live bird 

from its steel shackle with the line still in 

motion would have endangered personal safety. 

Two employees appeared.  I explained the issue 

and asked for a supervisor.  One employee 

departed to get the supervisor; while, the other 

employee gestured to behead the bird.  I asked 

the employee to wait for the supervisor.  After 

approximately twenty seconds of line stoppage 

when no supervisor had yet appeared, I informed 

the employee that if he wanted to remove the live 

bird from the line then the line could be 

restarted.  The employee removed the bird and I 

restarted the line.  The employee handed the live 

bird to me to resume his duty position as back-up 

slitter. I carried the live bird into the live hang 

area where I met 

who had just arrived, and I explained 

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

the event.  ordered an additional 

(b) (6)

employee to the back-up line slitter position and 
-

(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 245 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

stated that the employee would remain on that 

duty until the cause and a solution to the problem 

could be determined.  assured that the 

live bird was slaughtered in accordance with 

GCPs. The Agency’s regulation (9 CFR 381.65(b)) 

requires that poultry 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 . Compliance with these 

regulations helps ensure that poultry are treated 

humanely. 
-

-

-

-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 246 

EstNbr EstName MOINbr 

P6164A Foster Farms OIJ292011 

0230G 

Date 

30NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On November 26, 2019 at approximately 2245 

hours I, 

(b) (6)

while performing a 

routine Good Commercial Practice Inspection 

task, was in the live hanging room observing 

establishment personnel hang the live chickens 

with the lights on, when I saw water being 

sprayed into the chute on the conveyor belt. It 

was the end of slaughter, and there were still live 

chickens on the conveyor belt coming into the 

room. I went outside and observed the cage dump 

operator using a high-pressure water hose to 

spray the live chickens with water.  It appeared 

the establishment employee was using the water 

as a movement facilitator to encourage the live 

chickens to move along the conveyor belt into the 

live hang room. I asked the employee why he was 

directly spraying the chickens with water and the 

establishment employee said that’s what he was 

told to do. I went and spoke to 

, regarding my 

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

observation. I asked 

(b) (6)

if the 

establishment had any written procedures 

regarding the way the establishment handles the 

chickens while offloading from the trucks onto the 

conveyor belts. Nothing in the establishment’s 

written procedures made mention of using a 

person or hose to motivate or facilitate the 

movement of the chickens. 

(b) (6)

told me 

the establishment used to use the water hose to 

move the chickens before. Then the establishment 

stopped. 

(b) (6)

stated the establishment 

is going back to that practice because it’s safer 

than having an employee walking on the belt to 

move the birds along. 

(b) (6)

told me the 

pressure is supposed to be turned down, and the 

employee then sprays behind the chickens to 

make the water ricochet off the conveyor belt 

toward the chickens, but not to spray the 

chickens directly. 

(b) (6)

told me that he 

will send an email to the establishment 
-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 247 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

management about my question. 

Spraying

(b) (6)

said he would let me know the result. 

live birds with a high-pressure water hose for the 

purposes of hastening the live birds movement is 

not consistent with Good Commercial Practice. 
-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 248 

EstNbr EstName MOINbr 

P6164A Foster Farms OIJ481712 

1830G 

Date 

30DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On December 28, 2019, at approximately 1145 

hours, I, 

(b) (6)

while 

performing a routine Good Commercial Practices 

(GCP) inspection, observed an event not 

consistent with GCPs. The establishment 

slaughter system has of a three-step approach for 

bleeding of the carcasses to ensure breathing has 

stopped prior to scalding: 1) a mechanical 

throatslitting device, 2) an employee providing 

back-up throat slitting, and 3) a mechanical head 

pulling device.  Between steps #2 and #3, I 

observed passing on the evisceration line a small 

bird that was alive and fully alert. I waited to 

allow the system to complete; however, after the 

live bird passed the third step still alive and 

alert—prior to entering the first of several boiling 

scalding tanks—I briefly stopped the line, found 

an establishment employee who removed the 

bird, then restarted the line.  The line-stoppage 

was not a regulatory control action (RCA) as the 

establishment management had—in the interests 

of GCPs and humane treatment—pre-authorized 

USDA IPP (as documented in a recent meeting 

MOI) to stop the line if necessary to prevent a live 

bird from entering the scalder. 

assured me that 

the live bird had been rehung and slaughtered in 

accordance with GCPs. 

(b) (6)

took the 

immediate further actions of replacing the 

back-up slitter and posting an additional 

employee to monitor the birds after the third 

step, before going into the scalding tanks. USDA 

reaffirms federal regulation (9 CFR 381.65(b)) 

requiring that poultry 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.  This event does not 

constitute noncompliance. 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 249 

EstNbr EstName MOINbr 

P622 Tyson Foods NLB25200 

62403G 

Date 

03JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Mr. Ira Phillips, Plant Manager Establishment 

P622 Tyson Foods, Inc. Monroe, NC 28110 Mr. 

Phillips, On 6/3/2019, at approximately 1737 

hours, while performing a Good Commercial 

Practices task in the Kill Room, I noted a bird pass 

by the back-up killer uncut.  At the time of my 

observations, the bird had normal rhythmic 

breathing, eyes open and blinking with the head 

elevated.  No team member in the area had 

noticed that this bird passed uncut, so I had the 

line stopped and called a team member to 

remove the bird from the line.  On further 

observation of the bird, I confirmed that there was 

no evidence of a cut on the neck to allow it to 

bleed out completely before entering the scalder. 

The bird was placed back on the line to go 

through the proper slaughter process. 

shown my findings. 

confirmed that a new back up killer was being 

trained and that they would ensure that the 

experienced back up killer was paying close 

attention to prevent recurrence.  Following this 

conversation, I repeated my Good Commercial 

Practices task and verified that the number of 

stunned birds and manually killed birds was 

appropriate.  PPIA and Agency regulations 

require that live poultry be handled in a manner 

that is consistent with good commercial practices 

(GCP), and that they do not die from causes other 

than slaughter.  It is the establishment’s 

responsibility to ensure that birds are slaughtered 

in accordance with 9 CFR 381.65(b). If you have 

any questions or concerns regarding this MOI, 

please feel free to contact myself or 

was 

(b) (6)

(b) (6)

(b) (6)

. Respectfully, 

Tyson Foods, 

Inc., Monroe 

(b) (6) (b) (6) (b) (6)
■ 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 250 

EstNbr EstName MOINbr 

P622 Tyson Foods NLB33130 

62505G 

Date 

05JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Mr. Ira Phillips, Plant Manager Establishment 

P622 Tyson Foods, Inc. Monroe, NC 28110 Mr. 

Phillips, On 06/04/2019, at approximately 

01645 hours, while walking into the plant I noted 

that both evisceration and picking lines were not 

running.  As I proceeded through the Picking 

Room towards the Live Hang Room, I noted there 

were no birds on either picking line prior to the 

scalders.  In the Live Hang Room, I observed that 

both Live Hanging Belts, which conveys live birds 

from the Dumper to the Hanging Station, were full 

of birds. Each belt contained large numbers of 

birds such that there was little room for individual 

movement and the high density of birds was 

observed to extend back to the Dumping Station 

for both lines.  At the time of my observations, I 

observed that birds on each belt had open mouth 

breathing and there were no team members in 

the area.  At the Dumping Station, there were 3 

cages in queue for each line on the platform.  I 

returned to the Upper Evisceration area and 

(b) (6)

, confirmed that both lines had been 

(b) (6)

stopped for 28 minutes.  I informed him of my 

observations in Live Hang, as well as the failure to 

follow the plant’s written Action Plan in the event 

a picking line is shut down for an extended period 

of time.  The Action Plan outlines the steps to be 

taken in the event of an extended shut down (i.e. 

longer than 10 minutes); including the removal of 

live birds from the Live Hanging Belt in the event 

that the density of birds is high and the return of 

cages on the Dump Platform to the trailer for 

shut-down extending beyond 30 minutes in warm 

weather to improve ventilation. 

immediately directed that the live birds be 

removed from the Live Hanging Belt and return of 

the queued cages to the trailers over his radio. 

When I returned to the Live Hang Area, I observed 

large numbers of dead birds on the floor behind 

(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 251 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

both hanging lines and two racks of dead birds 

being pushed out to the dumpster.  These dead 

birds were being removed from the Live Hanging 

Belt as the live birds were being returned to 

I informed them of my observations and the 

failure of team members to follow the plant’s 

written Action Plan.  In all there were 245 

carcasses that had been removed by the time Live 

Hang was returned to process control at 1750 

hours.  It is likely that the large number of dead 

birds on the Live Hanging Belt was due to 

smothering.  Operations resumed once process 

control was returned in the area and Mr. Phillips 

as a result.  Mr. Phillips stated that he would 

address the situation to prevent this from 

occurring in the future.  It is important that the 

plant’s preventative measures be proactive and 

effective in ensuring that birds entering the 

establishment do not die from causes other than 

slaughter.  PPIA and Agency regulations require 

that live poultry be handled in a manner that is 

consistent with good commercial practices (GCP), 

and that they do not die from causes other than 

slaughter.  It is the establishment’s responsibility 

to ensure that birds are slaughtered in accordance 

with 9 CFR 381.65(b). A copy of this MOI will be 

forwarded to the District Veterinary Medical 

Specialist (DVMS) in the event that an additional 

follow-up is recommended. If you have any 

questions or concerns regarding this MOI, please 

Monroe 

cages.  At 1740 hours, Mr. Ira Phillips, Plant 

Manager, and 

came to the Live Hang Area and 

and were made aware of my findings 

and was notified that a GCP MOI would be written 

feel free to contact myself or ,

 Respectfully, 

Tyson Foods, Inc., 
-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 252 

EstNbr EstName MOINbr 

P622 Tyson Foods NLB15160 

63310G 

Date 

10JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Mr. Ira Phillips, Plant Manager Establishment 

P622 Tyson Foods, Inc. Monroe, NC 28110 Mr. 

Phillips, On 6/10/2019, at approximately 1635 

hours, while performing a Good Commercial 

Practices task at the head puller for Line 2, I noted 

a live bird about to enter the scalder.  At the time 

of my observations, the bird had its eyes open and 

blinking with the head elevated above the head 

puller.  No team member was in the area and I 

could not stop the line before the live bird entered 

the scalder.  I waited for the bird to exit the 

scalder on Line 2 and upon exiting the scalder I 

confirmed that there was no evidence of a cut on 

the neck to allow it to bleed out completely 

before entering the scalder.  The bird’s head, neck 

and breast were bright reddish purple in color.  I 

followed the carcass through the rest of the 

Picking Room and caught the head at the head 

puller after the pickers.  At the transfer belt in the 

Evisceration Department, where the birds are 

transferred to the Evisceration Line, I observed a 

team member taking the bird off the line and put 

it into a USDA yellow condemn barrel. I called 

(b) (6)

, to 

the area and showed him my findings in upper 

evisceration. 

(b) (6)

went to the kill room and 

found that the number of manually killed birds 

exceeded the plant’s plan.  He made an 

adjustment on the automatic kill blade and I 

verified that the number of stunned birds and 

manually killed birds was appropriate. PPIA and 

Agency regulations require that live poultry be 

handled in a manner that is consistent with good 

commercial practices (GCP), and that they do not 

die from causes other than slaughter.  It is the 

establishment’s responsibility to ensure that birds 

are slaughtered in accordance with 9 CFR 

381.65(b). If you have any questions or 

concerns regarding this MOI, please feel free to 

contact myself or 

(b) (6)
  

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 253 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda

 Respectfully, 

Tyson Foods, Inc., Monroe 

(b) (6)(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 254 

EstNbr EstName MOINbr 

P646 JCG Foods of Georgia, LLC XAA29170 

92020G 

Date 

20SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 1940 hours, on September 17, 

2019, I, 

went to live hang and observed 

that they were on break, both live hang belts were 

stopped. On Live hang belt 1 all the birds were 

sitting one layer quietly and alive.  However, I 

observed that all of the birds that they had left on 

the belt during break for line 2 were all piled up at 

the end of the live hang belt, they were on top of 

each other at least 3 to 4 high and you could see 

legs sticking out from under the gate at the end of 

the belt as well as live birds smothering and 

struggling to get out from underneath the piled 

up birds.  About this time the supervisor in the 

area came into the room and I asked for the 

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

At this 

time the supervisor started pulling birds from the 

end of the belt and as he did the belt begin to roll 

(without the bar being pushed) and again push 

the birds to the end of the belt, he then took his 

hand and pulled the knee control bar back 

manually to stop the belt which had just started 

rolling on its own.  After getting the belt stopped, 

they again started moving the live birds on top 

and pulling both dead and live birds from under 

the pile of birds.  When they got through there 

were approximately at least 50 dead birds that 

were removed from the area.  There were both 

live and dead birds that were trapped under the 

pile of birds, it is reasonable to conclude that the 

birds had suffocated in the pile at the end of the 

belt since on the other line the birds were single 

layer, quiet and alive.  Had the issue not been 

addressed more of the birds could have 

suffocated.  While we were back in the area 

management called maintenance back to look at 

the knee bar.  They stated to me that they had 

repaired the bar this weekend but it was bent and 

they would take it off and straighten it tonight, 

until then they had lubricated it and tightened the 
-

(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 255 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

bolts, which were loose.  The PPIA and Code of 

Federal Regulations require that live poultry be 

handled in a manner that is consistent with good 

commercial practices.  I notified that 

this issue would be documented in a MOI and 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 256 

EstNbr EstName MOINbr 

P646 JCG Foods of Georgia, LLC XAA26221 

04623G 

Date 

23OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 1809 hours, on October 23, 

2019, I, 

(b) (6)

went to live hang 

to observe operations.  As I made my way through 

I noticed there was a black cart sitting behind line 

2 that the establishment uses to transport dead 

on arrival chickens (DOA) to the drain leading to 

offal.  Upon further inspection I observed 6 to 7 

chickens piled inside of the cart all with their 

heads on.  I used my foot to bump the cart to 

make any alert chickens move, one chicken 

moved its head laboring to breath due to two 

other DOA chickens laying on top of the live 

chicken.  About this time, I notified the supervisor, 

(b) (6)

of my finding and he immediately 

addressed the situation.  The topic of live 

chickens being found in the DOA bin has been 

discussed on numerous occasion by 

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

, and myself both 

individually with management and in USDA 

management meetings.  Had the issue not been 

addressed by USDA with management this bird 

could have been suffocated or dumped down the 

drain alive.  The PPIA and Code of Federal 

Regulations require that live poultry be handled in 

a manner that is consistent with good commercial 

practices.  I notified 

(b) (6)

that this issue 

would be documented in a MOI and 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 257 

EstNbr EstName MOINbr 

P6504 Peco Foods, Inc. CHK21020 

40917G 

Date 

17APR2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

P-6504, Peco Foods Inc., Tuscaloosa AL 16 April 

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

0245 hours Meeting Participants:  ,

 At 

approximately 0245 hours on 16 April 2019 in the 

live hang area of P-6504, I witnessed that there 

were approximately 10 or more birds piled on top 

of each other at the end of the live hang belt. 

Some were partially stuck under the roller at the 

end of the belt by wings and feet.  The lead live 

hang person then used his arms to sweep the 

birds that were piled up at the end of the belt to 

force them back on top of the incoming birds 

from belt away from the roller.  This sweeping 

action resulted in birds being thrown a short 

distance, landing on top of those birds coming 

down the belt and possibly smothering those 

birds underneath them.  Further investigation 

revealed that the bird density on the incoming 

feed belt was very high -- too high in my opinion 

for the hangers to effectively handle the birds as 

observed by the back-up of birds waiting to be 

hung on the kill line leading to the mistreatment 

of the birds at the end of the line as described 

above. 

(b) (6)

was 

informed of the birds piling up and the overload 

on the incoming belt. 

(b) (6)

supervised 

the pile-up at the end of the belt and gave 

direction to the lead hanger to correct the issue. 

A discussion between myself and

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

 ensued to inform the 

establishment that they were not treating birds in 

a manner consistent with good commercial 

practices.  Video surveillance should be available 

to justify my claims. 

(b) (6)

went to check 

the videotape.  I am unaware of any further 

actions that were taken.  Later in the shift I 

checked the hanging procedure in live hang and 

the incoming belt for bird density and was 

satisfied that the birds, at that time, were being 
                                     

-

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 258

Task

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 258 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

P6504 Peco Foods, Inc. CHK21020 17APR2019 04C05 Poultry Good Finalized 

40917G Commercial 

Practices 

handled appropriately, hopefully as a result of P-6504, Peco Foods Inc., Tuscaloosa AL 16 April 

actions taken by plant management

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

0245 hours Meeting Participants:  ,

At 

approximately 0245 hours on 16 April 2019 in the 

live hang area of P-6504, I witnessed that there 

were approximately 10 or more birds piled on top 

of each other at the end of the live hang belt. 

Some were partially stuck under the roller at the 

end of the belt by wings and feet.  The lead live 

hang person then used his arms to sweep the 

birds that were piled up at the end of the belt to 

force them back on top of the incoming birds 

from belt away from the roller.  This sweeping 

action resulted in birds being thrown a short 

distance, landing on top of those birds coming 

down the belt and possibly smothering those 

birds underneath them.  Further investigation 

revealed that the bird density on the incoming 

feed belt was very high -- too high in my opinion 

for the hangers to effectively handle the birds as 

observed by the back-up of birds waiting to be 

hung on the kill line leading to the mistreatment 

of the birds at the end of the line as described 

above. 

(b) (6)

was 

informed of the birds piling up and the overload 

on the incoming belt. 

(b) (6)

supervised 

the pile-up at the end of the belt and gave 

direction to the lead hanger to correct the issue. 

A discussion between myself and 

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

ensued to inform the 

establishment that they were not treating birds in 

a manner consistent with good commercial 

practices.  Video surveillance should be available 

to justify my claims. 

(b) (6)

went to check 

the videotape.  I am unaware of any further 

actions that were taken.  Later in the shift I 

checked the hanging procedure in live hang and 

the incoming belt for bird density and was 

satisfied that the birds, at that time, were being 

handled appropriately, hopefully as a result of 

i l 
                                     

                                    

                                    

                                    

 

                                    

                                     

.. 

-

1111 

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 259 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

P6504 Peco Foods, Inc. CHK41220 12MAY2019 04C05 Poultry Good Finalized 

54012G Commercial 

Practices 

P-6504 Peco Foods, Inc. Tuscaloosa, AL 

Meeting Date:  8 May 2019  Meeting Time: 

0400 hours Meeting Participants: 

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

(b) (6)

(b) (6)

(b) (6)

(b) (6)

P6504 Peco Foods, Inc. CHK15040 24MAY2019 04C05 Poultry Good 

52324G Commercial 

Practices 

Finalized 

(3rd shift) On May 2, May 5, and May 8 

2019 on the transfer belt conveying live birds 

from the dumper into live hang 

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

witnessed, at approximately 0200 

hours on each morning, the piling of live birds on 

top of one another.  The handling of live birds in 

this manner is inconsistent with industry 

standards for good commercial practices. 

P-6504 Peco Foods Inc. Tuscaloosa, AL 

Meeting Date:  22 May 2019 Meeting Time: 

2215 hours Meeting Participants: 

On 22 May 2019 

while doing a Good Commercial Practices task at 

P-6504 located just before bird entry into the 

scalder tank at 2210 hours 

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

witnessed a bird with a small cut in the 

neck, head attached, eyes open, and making 

conscious movements with its wings and legs go 

into the scalder tank.  Because this bird was alive 

and the head pullers before entry into the scalder 

tank were not adjusted properly as 

(b) (6)

had 

informed the establishment previously the bird 

missed the head pullers and proceeded into the 

scalding tank before death.  The handling of live 

birds in this manner is inconsistent with industry 

standards for good commercial practices. 
                                    

 

                                    

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 260 

EstNbr EstName 

P6504 Peco Foods, Inc. 

P6504 Peco Foods, Inc. 

MOINbr 

CHK35020 

53630G 

CHK57040 

70615G 

Date 

30MAY2019 

15JUL2019 

Task 

Code 

04C05 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

Finalized 

MOI Agenda 

P-6504 Peco Foods, Inc. Tuscaloosa, AL 

Meeting Date:  30 May 2019  Meeting Time: 

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

0055 hours Meeting Participants:  ,

 On 

30 May 2019 SPHV witnessed 

the piling of live birds on top of one another at 

approximately 0055 hours on the belt conveying 

live birds from the dumper belt into live hang. The 

handling of live birds in this manner is 

inconsistent with industry standards for good 

commercial practices. 

was apprised of the situation at the time it was 

discovered on the back dock of P-6504. 

(b) (6)

P-6504 Peco Foods, Inc. Tuscaloosa, AL 

Meeting Date:  15 July 2019  Meeting 

Time:  0445 hours Meeting Participants: 

(3rd shift) On 14-15 July 20189, 

witnessed the piling of live birds 

on top of one another at 2230 hours and again at 

0430 hours on the belt conveying live birds from 

the dumper belt into live hang. The handling of 

live birds in this manner is inconsistent with 

industry standards for good commercial 

practices. 

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

was 

apprised of the situation at 0445 hours. 

was the most senior supervisor that could be 

located at the time. 

(b) (6) (b) (6) (b) (6) (b) (6)
- ■ 

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 261 

EstNbr EstName MOINbr 

P6505 Norman W. Fries, Inc. BBA24130 

72512G 

Date 

12JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda

(b) (6)

 Norman W. Fries (P6505) 8816 

Highway 301 North Claxton, GA  30417 July 12, 

2019 MEMORANDUM OF INTERVIEW Dear 

On July 11, 2019 at approximately 0846 

hours, while observing conditions outside the 

establishment at the cage dump system #2 (Small 

birds) area; I observed one (1) live bird released 

from the cage as the cage was being dumped. The 

live bird slid underneath the raised cage and was 

alert and looking around while the cage was still 

dumping the other birds on the belt. The 

employee that was operating the cage dump 

system then retrieved a clipboard and began 

documenting on the clipboard. Next, the 

employee dumping cages did not look to make 

sure any loose birds were underneath; but just 

released the cage down and crushed the live bird. 

The bird was killed, and its intestines, organs and 

blood were exposed. I yelled out and signaled to 

get the employee’s attention and informed the 

employee of what had taken place. The employee 

lifted the cage and removed the lifeless bird and 

tossed it to the side of the dumping area. The 

cage dump employee returned and informed me 

that he did not see the bird because he was 

documenting on the clipboard. I informed the 

employee that he needed to check for birds 

before releasing the cages, but I would still be 

documenting the observations. At 0857 hours, 

(b) (6)

was informed of the 

observations. I reminded 

(b) (6)

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 the 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 with a 
-

-

1111 

1111 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 262 

EstNbr EstName MOINbr 

P6505 Norman W. Fries, Inc. BBA21170 

93819G 

Date 

19SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

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. Sincerely, 

(b) (6) , 

(b) (6)

At 2200 on September 18th, 2019, I went into the 

scald/picking room for Line 3 to monitor chickens 

entering the scald tank to ensure none were 

entering while still alive. While in the area, I saw a 

bird without any visible neck cut enter the scald 

tank. I followed the line around and removed the 

bird after the hock cutter. The body was 

red/purple with blood suffused in the neck and 

head. No neck cut of any kind was evident. I 

walked back to the scald tank area to determine if 

this was an isolated incident. Within a couple 

minutes, I saw another bird identical to the first. I 

removed that one as well and brought both 

carcasses to 

(b) (6)

at 2214. I 

told him that it was unacceptable to have live 

birds entering the scald tank. The previous day, 

September 17th, 2019, I had also contacted

 with a similar bird from

 I had also informed him of numerous 

carcasses (approximately eight) with similar 

appearance (red/purple color with blood suffused 

in the head and the neck not cut) in the top visible 

layer of the condemned barrel near a sorter 

positioned as 

(b) (4)

enters evisceration. This 

indicates a possible problem with the 

establishment's system on 

(b) (4)

of ensuring 

chickens are not entering the scald tank alive. Live 

chickens entering the scald tank and dying by 

means other than slaughter is not following PPIA 

and Agency regulations requiring that live poultry 

be handled in a manner consistent with good 

commercial practices. This MOI has been 

forwarded to the FLS and DVMS at the Atlanta 

District Office. 

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

-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 263 

EstNbr EstName MOINbr 

P6510 Peco Foods, Inc WED18211 

11111G 

Date 

11NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

November 11, 2019 Mr. Ronnie Tolbert Peco 

Farms, Inc., Bay Springs Plant Manager 95 

Commerce Dr. Bay Springs, MS 39422 Mr. 

Tolbert, At approximately 1443 hours 

while performing the PHIS Poultry Good 

Commercial Practices verification task, the 

following less than Good Commercial Practice 

(GCP) was observed.  One (1) live chicken, from a 

500 birds random subgroup, with raised head, 

rhythmic breathing, and no visible cut to the neck 

entered the scalder.  At approximately 1450 hours 

were notified.  A second verification of a 500 bird 

(b) (6)

random subgroup sample immediately prior to 

the scalder entrance was conducted at 

approximately 1500 hours.  No birds entered the 

scalder during this observation.  This was 

determined to be an isolated event and not a loss 

of process control. Birds must not be 

breathing at the point they enter the scalder to 

avoid unnecessary suffering and death by means 

other than slaughter.  Every effort must be made 

by the establishment to prevent injury, 

unnecessary suffering, and death by means other 

than slaughter for birds which have come onto 

the official premises and are under their control. 

A meeting was held at approximately 

1545 hours to discuss the preceding incident with 

were 

present.  stated the equipment was 

(b) (6)

(b) (6)

functioning properly and no adjustments were 

made. 

(b) (6)

was advised a GCP 

Memorandum of Information would be issued 

after review by Jackson 

District Office. Respectfully submitted, 

Supervisory Veterinary Medical Office 

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

Office of Field Operations DO-90, Jackson Food 

Safety and Inspection Service, USDA 713 S. Pear 
               

        

        

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 264 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

Orchard Rd. Ridgeland, MS 39157 cc: 

, 

(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 265 

EstNbr EstName MOINbr 

P6510 Peco Foods, Inc WED41201 

12112G 

Date 

12NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

November 12, 2019 Mr. Ronnie Tolbert Peco 

Farms, Inc., Bay Springs Plant Manager 125 

Commerce Dr. Bay Springs, MS 39422 Mr. 

Tolbert, At approximately 2001 hours 

while performing the PHIS Poultry Good 

Commercial Practices verification task, the 

following less than Good Commercial Practice 

(GCP) was observed.  One (1) live chicken, from a 

500 birds random subgroup, with raised head, 

rhythmic breathing, and no visible cut to the neck 

entered the scalder.  At approximately 2008 and 

2010 hours 

and were notified respectively.  A 

(b) (6)

(b) (6)

second verification of the picking line was 

conducted at approximately 2020 hours.  No birds 

entered the scalder during this observation.  This 

was determined to be an isolated event and not a 

loss of process control. Birds must not be 

breathing at the point they enter the scalder to 

avoid unnecessary suffering and death by means 

other than slaughter.  Every effort must be made 

by the establishment to prevent injury, 

unnecessary suffering, and death by means other 

than slaughter for birds which have come onto 

the official premises and are under their control. 

A meeting was held at approximately 

2015 hours to discuss the preceding incident with 

were 

present.  No cause for the incident given. 

was advised a GCP Memorandum of 

(b) (6)

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

Information would be issued after review by (b) (6) (b) (6)

Respectfully submitted, 

(b) (6)

Supervisory Veterinary Medical Office Office of 

Field Operations DO-90, Jackson Food Safety and 

Inspection Service, USDA 713 S. Pear Orchard Rd. 

Ridgeland, MS 39157 cc: 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 266 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

(b) (6) (b) (6) (b) (6)
■ 

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 267 

EstNbr EstName MOINbr 

P6510 Peco Foods, Inc WED00101 

21619G 

Date 

19DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

December 12, 2019 Mr. Ronnie Tolbert Peco 

Farms, Inc., Bay Springs Plant Manager 95 

Commerce Dr.  Bay Springs, MS 39422 Mr. 

Tolbert,  At approximately 1805 hours, while 

performing the Good Commercial Practices 

verification task at P6510, Peco Foods, Bay 

Springs, MS, the following less than GCP incident 

was observed. One (1) live young chicken from an 

approximate 500 bird random sample with 

uplifted head, rhythmic breathing, pupillary 

reflexes, and no visible cut to the neck entered the 

scald tanks while still breathing.  The carcass was 

red in appearance with ventral pooling of blood in 

the neck, head, breast and no cut to the neck. 

were both notified and observed. 

(b) (6)

(b) (6)

Allowing bird(s) to enter the scald tank while still 

breathing is not consistent with GCP and results in 

adulterated product. Poultry must be handled and 

treated in a humane manner while under the 

establishment's control on the official premises. 

Birds must not be breathing at the point they 

enter the scalder to avoid unnecessary suffering 

and death by means other than slaughter. Every 

effort must be made by the establishment to 

prevent injury, unnecessary suffering, and death 

by means other than slaughter for birds which 

have come onto the official premises and are 

under their control. In a discussion with 

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

at approximately 1815 

hour, I informed these members of management 

that the employee that was supposed to be 

stationed in the kill room was performing other 

duties in the blood room and was not paying full 

attention to the birds passing through the kill 

machine. I was informed by that the 

only job assigned to the employee was to focus 

on the birds and to be a backup cutter for the kill 

machine. stated that the employee 

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

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 268 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

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

"Treatment of Live Poultry Prior to Slaughter", the 

Food Safety Inspection Service (FSIS) strongly 

encourages all establishments engaged in the 

slaughter of poultry to make every effort to 

abide by Good Commercial Practices (GCPs) as 

described in industry guidelines. Respectfully 

submitted, China Pace Consumer Safety 

Inspector Food Safety and Inspection Service, 

would receive disciplinary actions for this isolated 

incident. was informed that a GCP 

Memorandum of Information would be issued 

after review by , Jackson 

District Office. As per Federal Register Notice 

USDA 713 S. Pear Orchard Rd. Ridgeland, MS 

39157 cc: 

(b) (6)

(b) (6)
 

-

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 269 

EstNbr EstName MOINbr 

P6510 Peco Foods, Inc WED58220 

13316G 

Date 

16JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

January 16, 2020 Mr. Ronnie Tolbert Peco 

Farms, Inc., Bay Springs Plant Manager 95 

Commerce Dr. Bay Springs, MS 39422 Mr. 

Tolbert, At approximately 1532 hours, while 

performing the Good Commercial Practices 

verification task at P6510, Peco Foods, Bay 

Springs, MS, the following less than GCP incident 

was observed. One (1) live young chicken from an 

approximate 500 bird random sample with 

uplifted head, rhythmic breathing, pupillary 

reflexes, and no visible cut to the neck entered the 

scald tanks while still breathing 

were both notified and observed. 

(b) (6)

(b) (6)

Allowing bird(s) to enter the scald tank while still 

breathing is not consistent with GCP and results in 

adulterated product. In a meeting with 

(b) (6)

at approximately 

(b) (6)

1620-hour, Inspection Personnel was notified 

verbally by 

(b) (6)

that management would 

increase management checks in the kill room and 

that the responsible employee that was backing 

up the kill machine had received disciplinary 

actions for this isolated incident. 

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

was 

informed that a GCP Memorandum of Information 

would be issued after review by 

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

Jackson District Office. Respectfully 

submitted, China Pace Consumer Safety 

Inspector Food Safety and Inspection Service, 

USDA 713 S. Pear Orchard Rd. Ridgeland, MS 

39157 cc: 

(b) (6)

(b) (6)
 

-

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 270 

EstNbr EstName MOINbr 

P6510 Peco Foods, Inc WED08010 

21715G 

Date 

15FEB2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

February 14, 2020 Mr. Ronnie Tolbert Peco 

Farms, Inc., Bay Springs Plant Manager 95 

Commerce Dr. Bay Springs, MS 39422 Mr. 

Tolbert, At approximately 2031 hours, while 

performing the Good Commercial Practices 

verification task at P6510, Peco Foods, Bay 

Springs, MS, the following less than GCP incident 

was observed. One (1) live young chicken from an 

approximate 500 bird random sample with 

uplifted head, rhythmic breathing, pupillary 

reflexes, and no visible cut to the neck entered the 

scald tanks while still breathing. 

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

was 

notified of this GCP violation. Allowing bird(s) to 

enter the scald tank while still breathing is not 

consistent with GCP and results in adulterated 

product. In a meeting with 

(b) (6)

at 

approximately 2053-hour, I (CSI China Pace) was 

notified verbally by 

(b) (6)

that the 

responsible employee that was to be backing up 

the kill machine was disciplined with the outcome 

of termination for this isolated incident. 

was 

informed that a GCP Memorandum of Information 

would be issued after review by 

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

, Jackson District Office. Respectfully 

submitted, China Pace Consumer Safety 

Inspector Food Safety and Inspection Service, 

USDA 713 S. Pear Orchard Rd. Ridgeland, MS 

39157 cc: 

(b) (6)

(b) (6)
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 271 

EstNbr EstName MOINbr 

P6510 Peco Foods, Inc WED34210 

25017G 

Date 

17FEB2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

February 17, 2020 Mr. Ronnie Tolbert Peco 

Farms, Inc., Bay Springs Plant Manager 95 

Commerce Dr. Bay Springs, MS 39422 Mr. 

Tolbert, At approximately 2020 hours, while 

performing the Good Commercial Practices 

verification task at P6510, Peco Foods, Bay 

Springs, MS, the following less than GCP incident 

was observed. Two (2) live young chickens from 

an approximate 500 bird random sample with 

each containing a bright cherry red color, uplifted 

heads, rhythmic breathing, pupillary reflexes, and 

no visible cut to the necks entered the scald tanks 

while still breathing. 

was notified of this 

GCP violation. Allowing bird(s) to enter the scald 

tank while still breathing is not consistent with 

GCP and results in adulterated product. There 

was no formal response given on this isolated 

incident. 

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

was informed that 

a GCP Memorandum of Information would be 

issued after review by 

(b) (6) , 

Jackson District Office. Respectfully submitted, 

China Pace Consumer Safety Inspector Food 

Safety and Inspection Service, USDA 713 S. Pear 

Orchard Rd. Ridgeland, MS 39157 

(b) (6)

(b) (6)
-

-

- -

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 272 

EstNbr EstName MOINbr 

P6519B Coastal Processing, LLC AGJ430906 

4113G 

Date 

13JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

To: Coastal Processing LLC, P6519B 1670 

Forstman Rd. Louisville, GA 30434 On 

Thursday, June 13, 2019 at approximately 0800 

hours while observing operations in the live 

hang/receiving area, I, 

(b) (6)

, observed 

an issue with the implementation of Good 

Commercial Practices. While observing birds that 

had passed the back-up killer’s position just prior 

to entering the scalding tank, I observed an uncut 

bird (i.e. live bird) enter the scalder. I followed the 

bird down the line and instructed a plant 

employee stationed after the pickers to remove 

the bird from the line for my inspection. I quickly 

found 

(b) (6)

, in 

live hang and showed him the bird. There was no 

visible cut on the neck and the head and neck 

were swollen and red/dark purple in color. I 

informed 

(b) (6)

that I would be issuing a 

MOI for this occurrence. He called 

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

, who also came to look at the bird in 

question. It was agreed that this bird was a 

cadaver and it was condemned. Both 

(b) (6)

and

(b) (6)

 went directly to observe operations 

at the back-up killer to ensure proper cuts were 

being administered by the automatic blade and 

after finding no issue with this, counseled the 

back-up killer on his job performance. No other 

live birds were observed entering the scalder at 

the time of this occurrence.  After I returned to 

the USDA office, 

(b) (6)

came to speak with me 

further regarding this issue. He stated he would be 

writing an official response for this incident 

documenting the establishment’s planned 

corrective actions and preventative measures. 

This MOI serves as a reminder that the PPIA and 

Agency regulations require that live poultry be 

handled in a manner that is consistent with good 

commercial practices (GCPs). Poultry are to be 

slaughtered in a manner that ensures that 

breathing has stopped before scalding, so that 
-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 273 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

birds do not drown and that slaughter results in 

thorough bleeding of the poultry carcass. Poultry 

carcasses that show evidence of having died from 

other means other than slaughter are considered 

adulterated and must be condemned. Compliance 

with these regulations helps ensure poultry are 

treated humanely.  Respectfully, 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 274 

EstNbr EstName MOINbr 

P6519B Coastal Processing, LLC AGJ200810 

5029G 

Date 

29OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Friday, October 25, 2019 at approximately 

0755 hours while observing operations in the live 

hang/pre-evisceration area, I, 

(b) (6) , 

observed an issue with the implementation of 

Good Commercial Practices. While observing birds 

that had passed the back-up killer’s area just prior 

to entering the scalder, I observed a live bird enter 

the scalder. The bird was a large rooster that had 

a shallow cut on his neck. He was blinking, 

moving his head, and rhythmically breathing. I 

followed the bird down the line and instructed a 

plant employee stationed at the plant condemn 

sorting area to remove the bird from the line for 

my inspection. I informed an employee with a 

walkie talkie to radio Bubba Roberts, plant 

manager. After a minute, Mr. Roberts met me in 

the pre-evisceration area. I showed him the bird. 

The bird had a shallow cut on the lower neck that 

did not allow proper bleed out prior to entering 

the scalder. The bird’s head and neck were 

swollen and red/dark purple in color. It was 

agreed that this bird was a cadaver and it was 

condemned. Mr. Roberts went directly to observe 

operations at the back-up killer to ensure proper 

cuts were being administered by the automatic 

blade. No other live birds were observed entering 

the scalder at the time of this occurrence. After I 

returned to the USDA office, Mr. Roberts came to 

speak with me about the establishment’s 

immediate corrective actions. Mr. Roberts 

informed me that he got maintenance to change 

out the cutting blade to a new blade, adjusted the 

guide bars, and adjusted the blade height. He also 

said that he would be checking for a new part for 

the cutter that will help the positioning of the 

blade in the future. He assured me that 

establishment would change out the blades in a 

timely manner to prevent this from occurring in 

the future. This MOI serves as a reminder that 

the PPIA and Agency regulations require that live 
■ 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 275 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

poultry be handled in a manner that is consistent 

with good commercial practices (GCPs). Poultry 

are to be slaughtered in a manner that ensures 

that breathing has stopped before scalding, so 

that birds do not drown and that slaughter results 

in thorough bleeding of the poultry carcass. 

Poultry carcasses that show evidence of having 

died from other means other than slaughter are 

considered adulterated and must be condemned. 

Compliance with these regulations helps ensure 

poultry are treated humanely. Respectfully,  (b) (6) (b) (6)
-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 276 

EstNbr EstName MOINbr 

P6519B Coastal Processing, LLC AGJ351312 

5612G 

Date 

12DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Thursday, December 12, 2019 while observing 

operations in the live hang/pre-evisceration area, 

I, 

(b) (6)

, observed the following issues 

with the implementation of Good Commercial 

Practices. At approximately 0830 hours, while 

observing the live hang operations, I saw a pile of 

25-35 carcasses on the floor. The dead birds were 

being picked up and put on a conveyor belt to go 

into the DOA bin. While watching an employee 

remove the dead birds from the floor, I observed 

approximately 8 live, weak birds that were either 

on top of the carcass pile on the floor or being 

smothered/crushed by the carcasses on top of 

them. The live, weak birds and the dead birds 

were comingled in the pile, subjecting the live 

birds to potentially suffocate or die by means that 

are not Good Commercial Practices. I showed the 

weak birds to the live hang supervisor, who got off 

the live hang line and immediately euthanized the 

weak birds. At approximately 0857 hours, while 

observing birds that had passed the back-up 

killer’s area just prior to entering the scalder, I 

observed a live bird enter the scalder. The bird 

was a small hen that did not have a cut on its 

neck. The bird was blinking, moving its head, 

rhythmically breathing, and trying to right itself in 

the shackle. No other live birds were observed 

entering the scalder at the time of this 

occurrence. I followed the bird down the line and 

instructed a plant employee stationed at the plant 

condemn sorting area to remove the bird from the 

line for my inspection. The plant employee pulled 

the bird and placed it in the condemn container. I 

pulled it from the condemn container to get a 

better observation of the bird. The bird did not 

have a cut on its neck. The bird’s head and neck 

were swollen and red/dark purple in color. I called 

for Bubba Roberts, plant manager, on the walkie 

talkie. I then called for 

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

to come and observe the cadaver and 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 277 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

to inform Mr. Roberts of the finding. While 

waiting on Mr. Roberts to arrive, I proceeded to 

look at the other birds in the condemn container. 

I pulled 8 cadaver birds from the condemn 

container at the pre-sorting station that either 

had no cut or a superficial cut on their neck. The 

cadaver birds had a similar appearance as the bird 

that I observed entering the scalder alive. Mr. 

Roberts examined the bird that I found enter the 

scalder alive as well as the other birds from the 

condemn barrel and agreed that they were all 

cadavers. He said he would speak to live hang and 

maintenance supervisors to see what was 

happening. Since this was during establishment 

break, no other birds were being run at the time 

of this meeting. After I returned to the USDA 

office, Mr. Roberts came to speak with me about 

the establishment’s immediate corrective actions. 

Mr. Roberts informed me that there was a 

miscommunication between maintenance and 

live hang supervisors on the walkie talkies. The 

bird size had drastically reduced, and the kill 

blade was not making proper cuts. Live hang 

attempted to notify maintenance of the issue, but 

there was a problem understanding the question 

over the walkie talkie. Upon further investigation, 

there was also a loose bolt on the kill blade that 

made the blade shift upwards slightly, making the 

cuts ineffective. Mr. Roberts informed me that the 

miscommunication issue would be resolved in a 

timely manner. He also told me that there would 

now be two back up killers for the rest of the day 

to prevent any more cadavers and that the bolt 

would get fixed as well. Mr. Roberts also brought 

extra employees into the live hang room to 

prevent the buildup of dead birds on the floor. 

Upon verification of the establishment’s corrective 

actions, the establishment had additional 

employees in the live hang room picking up dead 

birds to prevent a buildup on the floor. There was 
(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 278 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

an employee before the DOA bin checking the 

birds to be sure that they were dead prior to 

being placed in the DOA bin. There were also two 

back-up killers as stated after the kill blade to 

ensure no live birds would enter the scalder. I 

observed the birds after the stunner go through 

the kill blade to verify the blade was effectively 

cutting the birds. Within the 3 minutes that I 

observed the birds, the back-up killers only had to 

cut 2 birds. The bolt adjustment allowed the kill 

blade to effectively cut the 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. I gave Mr. Roberts a 

copy of the 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 Mr. Roberts 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, 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 279 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

P6519B Coastal Processing, LLC AGJ380901 

5829G 

29JAN2020 04C05 Poultry Good 

Commercial 

Practices 

Finalized On January 25, at approximately 0655 hours, 

Coastal Processing informed USDA of a 

catastrophic event that occurred earlier in the 

morning. The offal drainage system was 

completely submerged in water for an unknown 

amount of time. The establishment immediately 

started working on the area in order to start 

slaughtering that day since they already had birds 

on the premises. They informed USDA that they 

would slaughter as many as possible that day to 

reduce the number of birds that would be carried 

over until Monday. The establishment stated that 

the carry over birds would be in trailers in the live 

shed area with misters running intermittently to 

allow them to drink. The establishment also 

elected to spray water in each of the cage layers 

to reduce the chance of dehydration and decrease 

the number of DOAs. The birds would not have 

access to feed for the time (approximately 48 

hours) that they were on the premises. I informed 

the establishment that due to the extended 

period without food, this is not adhering to Good 

Commercial Practices. Their animal welfare 

program states that “The plant should minimize 

DOA’s by proper shed/holding conditions.” The 

establishment carried over 7 trucks which 

contained 25,644 birds. The birds were 

slaughtered on Monday, January 27. The total 

number of DOAs was 286 birds, which was 

approximately 1.1% of the carry over. FSIS 

encourages establishments to develop and 

implement a systematic approach to ensuring 

poultry presented for slaughter are treated in a 

manner that minimizes excitement, discomfort, 

and accidental injury. Establishments should have, 

and implement as needed, an emergency plan 

that addresses animal welfare in the event of an 

emergency shutdown. The establishment has a 

response to emergency situations in their animal 

welfare program; however, it does not address 
(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 280 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

birds that are carried over in trucks. 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 gave 

establishment a copy of the 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 Coastal 

Processing Management 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, 
-

-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 281 

EstNbr EstName MOINbr 

P6519B Coastal Processing, LLC AGJ231001 

3331G 

Date 

31JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Thursday, January 30, 2020 while observing 

operations in the live hang/pre-evisceration area, 

I, 

(b) (6)

, observed the following issues 

with the implementation of Good Commercial 

Practices. At approximately 1311 hours, while 

observing birds that had passed the back-up 

killer’s area just prior to entering the scalder, I 

observed a live bird enter the scalder. The bird 

was a small hen that did not have a cut on its 

neck. The bird was blinking, moving its head, 

rhythmically breathing, and trying to right itself in 

the shackle. No other live birds were observed 

entering the scalder at the time of this 

occurrence. I followed the bird down the line and 

instructed a plant employee stationed at the plant 

condemn sorting area to remove the bird from the 

line for my inspection. The plant employee pulled 

the bird and handed it to me. The bird did not 

have a cut on its neck. The bird’s head and neck 

were red/dark purple in color and swollen. There 

was an area of bruising present in the caudal 

portion of the neck, close to the breast. I called for 

Bubba Roberts, plant manager, and 

(b) (6)

, on the walkie talkie. 

(b) (6)

Plant management ( 

(b) (6)

, Bubba Roberts, and 

(b) (6)

) and the live hang supervisor arrived 

to examine the bird that I found enter the scalder 

alive. They agreed that it was a cadaver. Their 

immediate corrective action was to replace the 

backup killer with another trained employee. 

They also observed the kill blade for a few 

minutes to verify that it was cutting the birds 

appropriately. At approximately 1345 hours, 

while observing the live hang operations, I saw a 

pile of 25-35 carcasses on the floor. The dead 

birds were being picked up, dispositioned, and put 

on a conveyor belt to go into the DOA bin. While 

observing an employee disposition the dead birds 

on the floor, I observed movement within the pile 

of carcasses. I initiated regulatory control action 
-

-

-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 282 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

and stopped the employee from continuing to 

move the DOA’s until I could assess where the 

movement was coming from. I then saw a weak 

bird that was being smothered/crushed by at least 

three carcasses on top of it. The live, weak bird 

and the dead birds were comingled in the pile, 

subjecting the live bird to potentially suffocate or 

die by means that are not Good Commercial 

Practices. I notified the live hang supervisor of this 

occurrence and showed him the weak bird. The 

supervisor implemented the immediate corrective 

action of removing the weak bird from the pile 

and euthanizing it. I verified that another trained 

employee was at the backup killer area and that 

no other live birds entered the scalder. I also 

monitored the employees sorting through the 

DOA pile on the floor to ensure that no other 

weak birds were being smothered. 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 gave the 

establishment management a copy of the 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 Mr. Roberts 

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 283 

EstNbr EstName MOINbr 

P6519B Coastal Processing, LLC AGJ221402 

5504G 

Date 

04FEB2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On Tuesday, February 4, 2020 at approximately 

1321 hours while observing birds that had passed 

the back-up killer’s area just prior to entering the 

scalder, I observed a live bird enter the scalder. 

The bird was a small hen that was improperly cut. 

The cut was at the area of the beak instead of on 

the neck. The bird was blinking, moving its head, 

rhythmically breathing, and trying to right itself in 

the shackle. No other live birds were observed 

entering the scalder at the time of this 

occurrence. I followed the bird down the line and 

instructed a plant employee stationed at the plant 

condemn sorting area to remove the bird from the 

line for my inspection. The plant employee pulled 

the bird and handed it to me. The bird had a cut 

straight across its beak. The bird’s head and neck 

were red/dark purple in color and swollen. I called 

for Bubba Roberts, plant manager, and 

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

, on the walkie talkie. 

Bubba and arrived to examine the bird. 

(b) (6)

They agreed that it was a cadaver. Bubba stated 

that there was a misfeed at the kill blade. Since 

the bird was bleeding from the miscut, the backup 

killer was unable to detect the miscut and 

properly recut the bird. 

(b) (6)

and Bubba 

observed the kill blade and the backup killer for a 

few minutes to verify that every bird was cut 

properly prior to entering the scalder. I also 

verified that the blade and backup killer were 

properly and effectively cutting every bird after 

the occurrence. 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 gave the establishment management a 

copy of the 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 Mr. Roberts that this MOI will be 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 284 

EstNbr EstName MOINbr 

P6529 Koch Foods of Alabama AVI511110 

4129G 

Date 

29OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Open 

MOI Agenda 

forwarded to the District Office and the District 

Veterinary Medical Specialist (DVMS) in case 

additional follow-up is recommended. 

Respectfully, 

Upon performing PHV inspection tasks at 

approximately 1040 hours, I observed 2 large piles 

of DOA birds on the floor cornered near the west 

wall of live hang area. The pile was approximately 

1-2 ft high. There was no room available for 

walking for inspecting the birds nor the bird line. I 

immediately ordered live hangers to stop hanging 

birds and to begin clearing the floors of DOAs. I 

saw many employees removing birds from the 

floor, but there were many that stepped on top of 

the DOAs to cross over the large pile. The pile 

consisted of both big and small birds on the floor 

along with heavy debri and bird fecal matter. 

While employees were clearing the floor, I saw 3 

live birds pulled out from the pile of DOAs. Those 

live birds were quickly euthanized by cervical 

disarticulation. Eventually after ~ 20 minutes had 

passed, majority of birds were cleared from the 

floor and they were permitted to resume hanging. 

I informed Plant manager, Johnny Gill of my 

findings and about the issuance of this 

Memorandum of Information (MOI). A copy of 

this Memorandum of Information (MOI) will be 

forwarded to the Jackson District Office and the 

District Veterinary Medical Specialist (DVMS). 

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

Respectfully, Cc: 

(b) (6)
 

 

-

16 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 285 

EstNbr 

P6616+V66 

EstName 

Peco Foods, Inc. 

MOINbr 

IRE042108 

2808G 

Date 

08AUG2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Mr. Josh Walsworth Plant Manager Peco Foods, 

Sebastopol 15292 Hwy. 21 S. Sebastopol, MS 

39359 Mr. Walsworth, At 

approximately 1442 hours on August 8, 2019 

while performing the routine PHIS Good 

Commercial Practices (GCP) in Poultry verification 

task, a less than GCP incident was observed.  One 

(1) live bird from a 500-bird random subgroup 

sample was observed entering the scald tank on 

picking line #2 while still exhibiting rhythmic 

breathing movements. 

approximately 1450 hours. 

was notified at 

approximately 1455 hours.  An additional 

verification of the line could not be performed 

due to operations ending at approximately 1502 

hours.  This incident was determined to be an 

isolated incident and not a systemic failure or loss 

of process control.  Management personnel were 

advised a Memorandum of Information (MOI) 

would be documented. 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. A meeting was held in the plant 

manager’s office on August 9, 2019 at 

approximately 1400 hours to discuss the less than 

GCP incident which occurred on August 8, 2019. 

Mr. Josh Walsworth, Plant Manager

 were notified at 

(b) (6)

(b) (6)

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

were present.  Mr. 

Walsworth stated the incident had been 

investigated and corrective measures had been 

taken to prevent the recurrence of this event. Mr. 

Walsworth was advised a MOI would be issued 

after review by 

Respectfully 

Jackson District FO Relief SPHV, Starkville Circuit 

9024 1039 W. Fulton St. Canton, MS 39046 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 286 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

cc:  Dr. Larry Davis, DM Dr. David Thompson, 

DDM Dr. Gregory Brookhouser, DDM 

Mr. William Griffin, DDM , 

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 287 

EstNbr EstName MOINbr 

P6638 Pilgrim's Pride Corporation UDG58220 

11228G 

Date 

28JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On January 28, 2020 at approximately 2228 

hours; I observed Less than Good Commercial 

Practice at establishment P-6638 Pilgrim’s in 

Enterprise, AL.  While performing a Good 

Commercial Practice verification task, I observed 

one (1) live bird about to enter the scalder on 

Picking Line 2.  I was performing observation to 

ensure all birds had their necks cut and/or heads 

removed prior to entering the scalder.  As I was 

monitoring this, I noticed a smaller framed bird 

with no visible neck or enter the head puller area 

but bypassing the actual head puller completely. 

There was no visible blood on the bird, and it 

appeared the bird’s vent was moving to indicate it 

was breathing.  I leaned down and noticed the 

bird still had the head and neck attached.  At that 

point, I had stopped the Picking Line and removed 

the fully alert and alive bird from the shackle past 

the head puller.  This prevented the bird from 

entering the scalder alive which would have 

resulted in a cadaver. The head puller is the 

establishment's final intervention prior to entering 

the scalder which the bird bypassed due to the 

bird not being stunned. I handed the bird to

(b) (6)

 who had approached me 

as I restarted the line.  The bird did not have its 

neck cut, it did not appear to be stunned and was 

looking around at its surroundings.  I informed 

of the documentation of this 

(b) (6)

Memorandum of Information (MOI).  A copy of 

this MOI will be forwarded to the Jackson District 

Office and the District Veterinary Medical 

Specialist (DVMS) in case additional follow-up is 

recommended. Respectfully Submitted, 

(b) (6)

(b) (6)
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 288 

EstNbr EstName MOINbr 

P687 House of Raeford XRA38111 

15912G 

Date 

12NOV2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At approximately 1018 on November 12th, 2019, 

as part of a scheduled Good Commercial Practice 

task, I went into the scald/picking room to 

monitor chickens entering the scald tank to 

ensure none were entering while still alive. Within 

approximately 90 seconds, I saw a conscious bird 

without any visible neck cut enter the scald tank. I 

followed the line around and removed the bird 

after it came out of the scald tank. The body was 

red/purple with blood suffused in the neck and 

head. No neck cut of any kind was evident. Within 

30 seconds of pulling that bird off the line, I saw 

another with the same characteristics (red/purple 

body, blood suffused in neck and head, no neck 

cut) and pulled it off the line as well. I brought 

both carcasses to 

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

at 1023, and informed him of my 

findings. The previous day, November 11th, 

2019, I had also spoke to both 

, and 

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

presented two similar carcasses to . An 

(b) (6)

additional back-up neck cutter was added to the 

line at that time to ensure no live birds were 

entering the scald tank. It is unknown the number 

of back-up neck cutters that were stationed 

during today’s incident as that area is not visible 

from the entrance to the scald tank. The findings 

on both days indicate a possible problem with the 

establishment's system of ensuring chickens are 

not entering the scald tank alive. Live chickens 

entering the scald tank and dying by means other 

than slaughter is not following PPIA and Agency 

regulations requiring that live poultry be handled 

in a manner consistent with good commercial 

practices. This MOI has been forwarded to the 

FLS and DVMS at the Atlanta District Office. 
1111 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 289 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

P7044 Tyson Foods, Inc. GJJ241601 13JAN2020 04C05 Poultry Good Finalized 

2013G Commercial 

Practices 

Est. P7044, Tyson Foods, Inc. January 7, 2020 at 

At approximately

(b) (6)

(b) (6)

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

2040 hours. In attendance: , 

1720 hours, 7th of January 2020, 

found 7 young chicken cadavers at post 

hock cutter station.  I was summoned to the area 

and I verified the cadaver disposition.  All the 7 

young chicken’s neck and head are intact and 

with hematoma, reddish-dark in color.  The 

carcass is also reddish in color. 

was collecting the cadavers for 

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

disposal when came and 

concurred those are cadavers. I discussed the 

aforementioned with 

together with 

said they will 

address the issue as soon as possible and make 

sure that there will be no more cadaver on the 

line. At approximately 1120 hours, 10th of 

January 2020, I, Relief 

observed the following while performing poultry 

GCP:  At the post hock cutter station, I found 2 

young poultry cadavers on the barrel on 1 young 

poultry cadaver on the floor, 3 feet away.  The 

head and neck are intact with hematoma, dark 

red in color.  The carcass is reddish in color. 

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

is notified accordingly and he 

concurred they are cadavers. I reminded the 

est. management officials in attendance 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 to them to review Federal Register 

Notice Vol. 70, No. 187, published September 

2005 [Docket No. 04–037N] for FSIS 

recommendations concerning treatment of live 

poultry before slaughter and provided them a 
I 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 290 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

copy of this document. I notified the est. 

management 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)

at P7044 Tyson 

Foods Inc. 
- -

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 291 

EstNbr EstName MOINbr 

P7044 Tyson Foods, Inc. GJJ131501 

3423G 

Date 

23JAN2020 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Est. P7044, Tyson Foods, Inc. January 22, 2020 at 

1815 hours. In attendance: Relief 

, Plant 

Manager Tommy Brown, 

. At 

approximately 1530 hours, 22nd of January 2020,

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

 observed the 

following while performing poultry GCP 

verification task:  The floors of the bird cages at 

the rear end of five trailers are wet and with 

retained water.  One cage is made up of 3 

sub-cages in 5 tiers. These sub-cages contain 

approximately twenty young chicken each which 

are 33-34 day old and approximately 3.70-3.80 

pounds. The feathers of all young chicken are 

soaked wet, they are huddled together at the far 

end of the cage.  There are at least 2 dead and 2 

moribund on each cage.  Few more are shivering, 

gasping for breath with closed eyes and ruffled 

feathers.  The young chicken in the upper 

sub-cages are less wet and there are less dead and 

moribund. The temperature outside is 39 degrees 

Fahrenheit, it is moderately raining with 4mph 

wind speed. There is one cage in the middle of 

one trailer without a side board and all the young 

chicken therein are wet, huddled together.  The 

sub-cage at the bottom, there at least 8 dead or 

moribund young chicken. The upper sub-cages 

has fewer dead or moribund numbers. The young 

chicken in other cages which are not wet do not 

have the aforementioned clinical observation. I 

notified 

Following are establishment’s 

(b) (6)

(b) (6)

immediate corrective action:  The cages by the 

rear end of the trailer are immediately unloaded. 

The cage without side board is immediately 

unloaded and separated.  The loading crew at the 

farms are notified accordingly by 

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

Other corrective actions that maybe be 
(b) (6)

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 292 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

implemented are the following:  (1) No cage 

without side board will be transported; (2) The 

cages by the rear end will be covered with 

tarpaulin or wrapped; (4) The trailer drivers will be 

advised to drive slowly.  I reminded the est. 

management officials in attendance 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 

to them to review Federal Register Notice Vol. 70, 

No. 187, published September 2005 [Docket No. 

04–037N] for FSIS recommendations concerning 

treatment of live poultry before slaughter and 

provided them a copy of this document. I notified 

the est. management that this MOI will be 

forwarded to the District Office and the District 

Veterinary Medical Specialist (DVMS) in case 

additional follow-up is recommended. 

P7044 Tyson Foods, Inc. 

Respectfully, at 
1111 1111 

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 293 

EstNbr EstName MOINbr 

P7101 Tyson Foods, Inc. LUC260712 

1812G 

Date 

12DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Open 

MOI Agenda 

On 12/11/2019 at approximately 0450 I

(b) (6)

 was going down stairs to perform an 

Ante-Mortem inspection and observed the 

following MOI; The team member that was 

dumping the birds from the cages to the transfer 

belt was banging the cages to force the birds out 

of the cages.  In doing this the birds were flapping 

their wings and cackling.  It was obvious that the 

birds were very alert and nervous.  I observed the 

dumper do this 3 times before he noticed I was 

watching him. According to the GCP procedure 

IPP are to observe establishment employees and if 

they are mistreating birds or handling them in a 

way that will cause death or injury, prevent 

thorough bleeding, or result in excessive bruising. 

I then found 

(b) (6)

and notified 

him of my observation.  Later I Talked to

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

and asked him if the 

team members get any training on Humane 

Handling and he stated that: “they do annually” 

and that the team member running the dumper 

was the regular member, and that he would be 

retrained on the proper procedures for dumping. 
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 294 

EstNbr EstName MOINbr 

P713 Gentry's Poultry Co., Inc. HDA36150 

43424G 

Date 

24APR2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 1505 on April 24th, 2019, I went into the 

scald/picking room to monitor chickens entering 

the scald tank and ensure that no birds were 

entering the scald tank alive. Within a few 

minutes of arrival, a chicken that was not stunned 

(head was pulled up) and without any obvious 

neck cut was seen to enter the scald tank. Unable 

to remove the live bird or to stop the line, I 

followed the line around and removed the chicken 

from the line before the hock cutter. The body 

was red with blood suffused in the neck and head. 

No neck cut of any kind was evident. I walked 

back to the scald tank to determine if this was an 

isolated incident or not. I immediately saw two 

chickens without any neck cuts enter into the 

scald tank. I followed the line around and 

removed both of these chickens off the line with 

similar findings to the first - the bodies were red 

with swollen heads and no neck cuts were 

evident. I immediately took all three carcasses 

and showed them to 

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

at 1514. I told him that it was 

unacceptable to have live birds entering into the 

scald tank. Looking back at post-mortem 

condemned records over the last two weeks, 

there have been cadavers reported on 8 of the last 

11 days. One of the days, April 11th, there were 

22 carcasses condemned by inspection as 

cadavers. This indicates a possible problem with 

the establishment's overall system of ensuring 

chickens are not entering into the scald tank alive. 

Live chickens entering into the scald tank and 

dying by means other than slaughter is not 

following PPIA and Agency regulations requiring 

that live poultry be handled in a manner 

consistent with good commercial practices. This 

MOI has been forwarded to 

and 

. 

(b) (6) (b) (6) (b) (6)
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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 295 

EstNbr EstName MOINbr 

P713 Gentry's Poultry Co., Inc. HDA20080 

51307G 

Date 

07MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 1445 on May 6th, 2019, I went into the 

scald/picking room to monitor chickens entering 

the scald tank and ensure that no birds were 

entering the scald tank alive. Within one minute 

of arrival, a chicken that was not stunned (head 

was pulled up) and without any obvious neck cut 

was seen to enter the scald tank. Within 30 

seconds, a second conscious chicken without a 

neck cut entered the scald tank. Unable to remove 

either bird due to the height of the line or to stop 

the line, I followed the line around and removed 

both chickens from the line before the hock 

cutter. Both bodies were red with blood suffused 

in the neck and head. No neck cut of any kind was 

evident on either chicken. I immediately took the 

two carcasses and showed them to 

at 1500. I told him that it 

was unacceptable to have live birds entering into 

the scald tank. This is a repetitive issue that the 

establishment has been notified about on 

multiple occasions. Corrective actions have failed 

to be effective in preventing live chickens from 

entering into the scald tank. A MOI was 

documented on April 24th, 2019 for the same 

finding (HDA3615043424G). This issue has been 

brought up at USDA/establishment meetings, 

including 4-2-19 (HDA1513045902E) and 5-2-19 

(HDA0207050103E). The establishment has been 

unable to prevent live chickens from entering into 

the scald tank. Live chickens entering into the 

scald tank and dying by means other than 

slaughter is not following PPIA and Agency 

regulations requiring that live poultry be handled 

in a manner consistent with good commercial 

practices. This MOI has been forwarded to 

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

(b) (6)
1111 1111 

-

56 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 296 

EstNbr 

P7156+V71 

EstName 

Tyson Foods, Inc. 

MOINbr 

JTF150710 

0310G 

Date 

10OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

P-7156, Tyson Foods, October 7, 2019, 0945 

hours. In attendance: 

. While performing a 

routine Good Commercial Practice Task, I 

observed a live bird on the south side kill line 

about to enter the scalder. I motioned for the 

backup killer to stop the line which he did, 

pointed the live bird out to him and he made a kill 

cut before turning the line back on to continue 

processing. I discussed this matter with 

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

and reminded him that all birds should be 

handled in a manner consistent with good 

commercial practices according to CFR 381.65(b) 

" 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.." and that they not die from causes 

other than slaughter which would be drowning in 

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

this case. talked to 

(b) (6)

about the matter. 

Management has addressed the issue with their 

employees. 
• 

-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 297 

EstNbr EstName MOINbr 

P72 Tyson Foods, Inc JPJ231205 

1707G 

Date 

07MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 0500 Hrs on 5/06/2019 while performing Ante 

Mortem inspection prior to First shift beginning 

and 3rd shift ending, I stepped up on the platform 

cage dumping area platform. I observed a chicken 

that appeared not to be breathing with its head 

caught between the live hang conveyor belt and 

the plastic flap attached to the right side metal 

frame. 

was entering the area and I showed 

the condition of the bird.  When the belt was 

started the chicken carcass came out from 

underneath the plastic flap and conveyed up the 

belt. It was evident the bird was deceased. 

condemned the bird in the Live hang area. 

According to the establishment Good Commercial 

Procedure plan “ The conveyor belt that moves 

chickens to the hangers and the cover over it must 

be routinely observed for damage or signs of 

wear.  Any damage to the slides, conveyor belt or 

any frame work that may cause injury to a bird 

should be reported to management 

immediately.”  Dumping area team member is 

responsible to check live bird infeed belt for any 

caught up birds”.  This created a concern that the 

equipment caused the injury and death of a bird 

and I expressed my concerns of why this was not 

addressed when it occurred. 

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

was to 

investigate the reason by reviewing footage from 

the camera system.  Later in the afternoon,

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

 stated the area could not be viewed from 

this angle on the camera footage.  Additional 

investigation will be performed and repairs if 

needed. Repairs were made to the equipment to 

prevent the ability of chickens to get caught up in 

the area and was verified on 5/7/2019. 
-

-

-

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Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 298 

EstNbr EstName MOINbr 

P727+V727 Simmons Prepared Foods, Inc. VCF041207 

1019G 

Date 

19JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

At 0723 Hours While performing the Poultry GCP 

Task I observed live Chickens being placed into the 

Blue DOA Bin between the #1 & #2 Dumpers. I 

was on the walkway between the dumper 

operator stations, when I observed the Boomer 

Team Member placing the live birds into the DOA 

Bin. I went into the back door of the 

establishment and found a Blue hat Maintenance 

Employee with a radio and requested that he 

please contact someone with management to 

come to the Live Dock Area. 

(b) (6)

came to the 

area about 5 minutes later, at approximately 

0730 hours, and accompanied me outside and we 

proceeded to the 

(b) (6)

fished 

around in the top of the DOA Bin and pulled out 2 

live chickens that had not been euthanized, by 

cervical dislocation as per the establishments DOA 

procedure states.  I explained that the Live 

chickens could have died of means other than 

slaughter. 

(b) (6)

euthanized the birds by 

cervical dislocation and he explained he would 

have the Bin gone trough to make sure no other 

live birds which didn't get euthanized. I entered 

the Establishment and found 

(b) (6)

and informed him of the issue found just minutes 

earlier. 

(b) (6)

informed me that the 

establishment had a program which took care of 

the euthanization of live birds in the DOA Bins. I 

informed 

(b) (6)

of the Directions stated in the 

GCP Directive 6110.1. He followed me to the 

USDA Office and I presented him a copy of said 

Directive and I showed him the GCP example of a 

similar GCP MOI written in the Attachment 3 

example. I explained that a MOI for the observed 

Mishandling of live poulry would be documented 

and presented to the establishment and DO 

DVSM. 
-

42 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 299 

EstNbr 

P7342+V73 

EstName 

Wayne Farms LLC 

MOINbr 

SCJ461306 

5307G 

Date 

07JUN2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On 06/07/2019, at approximately 1310 while 

performing my Good Commercial Practices at the 

entrance of the scalder on Line 2 (New 

Kill/Picking/Evisceration Line), I 

observed two uncut, live birds pass by at 

approximately 1311 and 1312. I noted that the 

birds were breathing and alert to their 

surroundings. At the point of observation, the 

establishment has no further humane measures in 

place to ensure that all breathing has stopped 

prior to entering the scalder. I visually followed 

the birds as they entered and exited the head 

puller (prior to the entrance of the scalder) and 

into the scalder where both entered still 

breathing. I completed my check and went to the 

exit of the picking system where I observed four 

cadaver birds (two that had previously passed 

prior to my GCP check and two mentioned 

above), head attached and bright red in color, exit 

the picking system at the rehang table. 

Establishment personnel promptly removed all 

four cadaver birds and threw them into the drain. 

I also observed during this time another bird with 

the same appearance had been taken off the line 

and placed next to the main drainage area exiting 

the evisceration department. I immediately 

notified 

of my observations. After notifying 

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

, I 

returned to the stunning, cutting/kill, and back-up 

cutting/kill area where I observed approximately 

every 7th-8th bird missing the kill blade. The 

back-up killer (establishment personnel with 

knife) was able to effectively keep up with the 

missed birds during my observations 

(approximately 5-10 minutes). 

(b) (6)

stated 

that once notified he also immediately observed 

back-up killer personnel and did not note any 

deficiencies. Equipment effectiveness was also 

evaluated and no obvious issues were noted. He 

stated that retraining would be implemented, as 
-

... 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 300 

EstNbr 

P7342+V73 

42 

EstName 

Wayne Farms LLC 

MOINbr 

SCJ351510 

2310G 

Date 

10OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

well as, additional documented checks. At 

approximately 1330, I again performed another 

GCP check on this line and observed no birds 

entering the scalder alive. No other vulnerabilities 

were noted during today's production. 

On October 9, 2019, at approximately 0957 hours 

I observed poor good commercial practice at 

establishment P-7342 Wayne Farms in Dothan, 

AL. While performing a Good Commercial Practice 

verification task, I observed one live bird in the 

DOA dumpster outside across from the cage 

dumper in the live receiving area of the 

establishment. The live bird was of average size 

and was squeezed in between DOA birds. I looked 

at the bird for about a minute to be sure it was 

alive or not, then I saw its eyes blinking and it was 

breathing lightly. The bird was alert and appeared 

to be unharmed. The one live bird including the 

DOA birds all had denaturant on it, so I called for 

to the DOA dumpster. When 

arrived, I showed him the live bird in the DOA 

dumpster. He said that he would take care of it 

right away and then motioned for 

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

to remove the bird and to euthanize it. 

removed the bird and then we both 

inspected it to be sure the bird was bright, alert, 

and responsive (and it was) then he euthanized 

the bird by cervical dislocation. I informed 

who was standing near the area to come 

(b) (6)

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

of the documentation of 

the MOI. A copy of this Memorandum of 

Information (MOI) will be forwarded to the 

Jackson District Office. Respectfully submitted, 

(b) (6)
42 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 301 

EstNbr 

P7342+V73 

EstName 

Wayne Farms LLC 

MOINbr 

SCJ260710 

5617G 

Date 

17OCT2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On October 17, 2019, at approximately 0615 

hours, while performing a Good Commercial 

Practice verification task, I observed one live bird 

in the DOA dumpster outside across from the cage 

dumper in the live receiving area of the 

establishment. I walked outside to observe the 

DOA bin and while I was there a live hang 

employee was approaching the DOA bin and 

began to spray denaturant on the birds. At that 

same time, we saw a small bird that was barely 

noticeable, in between DOA birds and was already 

partially sprayed with denaturant by the plant 

employee. He immediately withdrew the bird out 

of the bin and threw it back inside the live hang 

area first without properly performing cervical 

dislocation of the bird’s neck. I went back inside 

to look at the bird and asked him is he going to 

euthanize the bird, and he said yes and 

immediately did it. I eventually called for

(b) (6)

 and told him about my 

findings and that it would be documented on a 

MOI. I strongly encourage the establishment to 

review Federal Register Notice Docket No. 

04-037N dated September 28, 2005, Treatment of 

Live Poultry before Slaughter for 

recommendations concerning treatment of live 

poultry before slaughter. A copy of this 

Memorandum of Information (MOI) will be 

forwarded to the Jackson District Office. 

(b) (6)

(b) (6)

Respectfully submitted, Cc: 
 

-

85 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 302 

EstNbr 

P7485+V74 

EstName 

Wayne Farms LLC 

MOINbr 

QBM46150 

73330G 

Date 

30JUL2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On July 29, 2019, at approximately 2132 hours I 

observed Less than Good Commercial Practice at 

establishment P-7485 Wayne Farms in Jack, AL. 

While performing a Good Commercial Practice 

verification task, I observed one (1) live bird in the 

DOA (Dead on Arrival) dumpster by the cage 

dumper in the Live Receiving area of the 

establishment. The live bird was very small in 

frame and standing on top of other DOA birds. 

The bird was alert and appeared to be unharmed. 

I motioned for 

(b) (6)

who 

was standing next to the hourly employee 

operating the cage dumper to come to the DOA 

dumpster.  When 

(b) (6)

arrived, I 

showed him the live bird standing on top of the 

pile of DOA birds.  He removed the bird from the 

pile and walked away with it with no further 

communication.  I then entered the establishment 

and requested for other available management to 

speak with and I was informed the only senior 

management available was 

met with 

me in the USDA Office to discuss the incident 

further at approximately 2140 hours.  I informed

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

 that there were several 

dead birds on the conveyor belt above the 

dumpster and that the last layer of birds placed 

into the DOA dumpster did not have denaturant 

applied to them.  I informed 

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

of the documentation of the MOI.  A copy 

of this Memorandum of Information (MOI) will be 

forwarded to the Jackson District Office and the 

District Veterinary Medical Specialist (DVMS) in 

case additional follow-up is recommended. 

Respectfully submitted, 

cc: 

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

85 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 303 

EstNbr 

P7485+V74 

EstName 

Wayne Farms LLC 

MOINbr 

QBM36210 

91820G 

Date 

20SEP2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

On September 20, 2019, at approximately 2052 

hours I was performing a Good Commercial 

Practice at establishment P-7485 Wayne Farms in 

Jack, AL. While performing a Good Commercial 

Practice verification task, I observed one (1) live 

bird in a yellow condemn can in the new Live 

Hang department.  The bird had a rapid 

respiratory rate and was unable to stand due to 

being partially trapped under other DOA birds.

 There were no immediate management in the 

area.  I requested the Live Hang hourly employees 

to retrieve someone from management.  They 

informed me a Lead was on his way.  When the 

Lead arrived, I showed him the live bird in the 

yellow condemn can partially covered by 3 large 

frame DOA’s.  The Lead removed the live bird 

from the can.  The bird was fully alert and 

responsive.  At that point, 

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

arrived.  I showed him the live bird and 

informed him of the conditions in which I found 

the live bird.  I also explained this to 

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

when he 

arrived.  This area of Live Hang uses a CO2 gas to 

anesthetize the live birds prior to hanging.  What 

is presumed to be DOA’s are removed and placed 

into the yellow condemn cans located directly 

behind the Live Hanger’s.  After speaking with 

management, there are no steps in place to 

ensure the bird(s) are dead prior to placing them 

into the yellow condemn can.  I informed 

of the documentation of this MOI. A 

(b) (6)

copy of this Memorandum of Information (MOI) 

will be forwarded to the Jackson District Office 

and the District Veterinary Medical Specialist 

(DVMS) in case additional follow-up is 

recommended. Respectfully submitted, 

(b) (6)

(b) (6)
-

-

-

85 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 304 

EstNbr 

P7485+V74 

P7485+V74 

85 

EstName 

Wayne Farms LLC 

Wayne Farms LLC 

MOINbr 

QBM26131 

04623G 

QBM51141 

03326G 

Date 

23OCT2019 

26OCT2019 

Task 

Code 

04C05 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

Finalized 

MOI Agenda 

The mistreatment of a live and conscious bird 

occurred on Tuesday, October 22, 2019 at 

approximately 2300 hours at Wayne Farms, LLC. 

Establishment number P7485 + V7485 located in 

Jack, AL.  I, 

(b) (6)

, observed a 

live and conscious bird inside the DOA dumpster 

that is used to collect the DOA birds from the 

evisceration department lines #1 and #2.  I 

observed the bird breathing and I observed the 

bird turn it’s head towards me to look at me and 

then turn it’s head away from me.  When the bird 

turned it’s head towards me I observed the bird 

blink it’s eyelids.  I immediately notified 

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

of the bird 

mistreatment and the GCP MOI that would 

follow. 

(b) (6)

removed the live and 

conscious bird from the DOA bin.  The bird was 

immediately humanely euthanized by rapid 

cervical dislocation. 

The mistreatment of a live and conscious bird 

occurred on Friday, October 25, 2019 at 

approximately 2000 hours at Wayne Farms, LLC. 

Establishment number P7485 located in Jack, AL. 

I, 

(b) (6)

, observed a live and 

conscious bird inside the DOA dumpster that is 

used to collect the DOA birds from the 

evisceration department lines #1 and #2.  I 

observed the bird breathing and I observed the 

bird attempt to stand while flapping its right 

wing.  The bird then turned its head towards me 

to look at me and then it turned its head away 

from me.  I immediately notified 

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

of the bird 

mistreatment and the GCP MOI that would 

follow. 

(b) (6)

removed the live and 

conscious bird from the DOA dumpster.  The bird 

was immediately humanely euthanized by rapid 

cervical dislocation. 
1111 

■ 

-

85 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 305 

EstNbr 

P7485+V74 

EstName 

Wayne Farms LLC 

MOINbr 

QBM24151 

22509G 

Date 

09DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

The mistreatment of live and conscious birds 

occurred on Friday, December 6, 2019.  These 

observations began at approximately 2120 hours 

at Wayne Farms, LLC. Establishment number 

P7485 located in Jack, AL.  I, 

(b) (6) , 

(b) (6)

observed the following from approximately 

2120 - 2150 hours:  One of the live hang 

employees removed a bird from his foot stand 

with a forward motion of his leg and foot in a 

front to back swinging motion.  When the foot of 

the employee came into contact with the 

underside of the bird the bird flapped both wings 

as it was exiting the stand to come to rest on the 

concrete floor in front of the employee.  This bird 

was later retrieved and hung onto a shackle to 

begin the slaughter process. One of the live hang 

employees attempted to hang a very small bird by 

the hock in a shackle of the hang back rack.  The 

shackles on this rack are approximately 3 feet 

from the concrete floor.  The bird was allowed to 

fall to the floor with its head and neck impacting 

the concrete floor before the rest of its body 

made contact.  The employee picked up the bird 

by the leg and again attempted to hang the very 

small bird by the hock.  The bird again was 

allowed to fall to the floor and in the same 

manner.  The employee left the bird where it fell 

until I could intervene by requesting that the 

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

intervene.  The bird was picked up and humanely 

euthanized as it was too small for its hock to 

remain in the shackles that are designed to move 

the birds through the slaughter process. 2 very 

small live birds were found at the end of the live 

hang conveyor belt buried under a pile of manure, 

feathers, and other birds.  These birds were 

discovered due to my intervention of asking that 

the pile was looked through in the search of live 

birds. The 

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

indicated that he was going to use 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 306 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

scissors to cut the neck in order to remove the 

head of a bird that was alive, conscious, and 

flapping its wings.  This was also a very small bird 

whose hocks were too small to remain in the 

shackles.  The 1st Processing Superintendent and I 

stopped the Assistant Supervisor prior to him 

making scissoring cuts on the neck of the live and 

conscious bird.  The 1st Processing 

Superintendent gave instruction that the birds are 

to be humanely euthanized via cervical dislocation 

prior to the removal of the head with scissors. 

There were numerous live and conscious birds of 

varying sizes in each area of the live hang room: 

underneath the dumper belt, around the foot 

stands of the live hang employees, behind 

condemned barrels, underneath piles of feathers, 

behind the shovel, and in the open walkways of 

the room.  These birds were all retrieved and 

either placed into the slaughter process or were 

humanely euthanized. On seven different 

occasions I intervened to point out a bird that was 

not noticed and retrieved by the live hang floor 

employee, the Assistant Supervisor, or the 

Superintendent. The 1st Processing 

Superintendent stepped onto a very small live 

agonal bird with the front half of his boot two 

times while attempting to retrieve more mobile 

and active live birds.  I picked the bird up to show 

to the Superintendent that it was breathing.  The 

bird was humanely euthanized. I observed the 

following from approximately 2150 – 2215 hours: 

There were approximately 30 very small birds in 

the picking room; some were alive, and some 

were dead. Many of the birds that were alive 

were cold to the touch, wet, and agonal. Some of 

both the live birds and the dead birds were found 

in pools of bloody water. One dead bird was 

found with its head over into the circular drain 

hole with water flowing over its head. The 

hanging of very small birds in the shackles for 
Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 307 

EstNbr EstName MOINbr Date 

Task 

Code TaskName Status MOI Agenda 

slaughter was discontinued after my intervention, 

therefore, no additional birds fell off the shackles 

and onto the concrete floor of the picking room. 
■ 

85 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 308 

EstNbr 

P7485+V74 

EstName 

Wayne Farms LLC 

MOINbr 

QBM36191 

20912G 

Date 

12DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

The mistreatment of a live and conscious bird 

occurred on Thursday, December 12, 2019 at 

approximately 1845 hours at Wayne Farms, LLC. 

Establishment number P7485 located in Jack, AL. 

I, 

(b) (6)

observed a live and 

conscious bird become entangled in a cage of the 

Evisceration Line(b) (4)

 carbon dioxide stunning 

system.  This entrapment led to the bird 

becoming injured and its wing mutilated by the 

movement of the equipment of this system.  I 

observed the bird flap its wings when the cage 

that it was in became separated from the other 

cages.  The right wing of the bird became 

entrapped in the bottom of the cage directly 

above.  The bird then became suspended in the air 

when it’s cage moved out from under it and into 

the stunning system.  The bird began to violently 

flap its wings and the body of the bird began to 

move erratically.  Several seconds passed and the 

cage that the bird was attached to then was 

lowered and began to enter the system.  The 

bird’s right wing was squeezed in between the 

bottom of the cage and the metal framework at 

the entrance to the carbon dioxide chamber.  The 

bird’s wing was dislodged from the bottom of the 

cage and the bird fell to the concrete floor.  It ran 

approximately 12-15 yards and then sat down.  I 

requested that the Establishment capture the bird 

for humane euthanasia so that I could assess any 

injuries.  I also informed the Establishment that I 

would document my observations on an MOI for 

the mistreatment of a live and conscious bird. The 

visible and palpable injuries to the bird consisted 

of the following:  the midsection (flat) and the 

wingtip were bruised, the outside of the 

midsection at the distal end was absent of 

feathers and blood was smeared across the 

adjacent feathers, and there was a compound 

fracture at the distal end of the midsection. 
■ 

85 

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 309 

EstNbr 

P7485+V74 

EstName 

Wayne Farms LLC 

MOINbr 

QBM09201 

24816G 

Date 

16DEC2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

The mistreatment of a live and conscious bird 

occurred on Monday, December 16, 2019 at 

approximately 1804 hours at Wayne Farms, LLC. 

Establishment number P7485 located in Jack, AL. 

Evisceration Line 

observed a live and 

(b) (6)

(b) (6)

(b) (4)

conscious bird hanging from the bottom of a cage 

at the entrance to the Evisceration Line (b) (4)

carbon 

dioxide chamber tunnel.  The bird’s feet were 

hanging towards the ground and the abdomen 

and chest were facing towards us.  The bird was 

flapping both wings violently.  The equipment was 

in motion when we initially observed the bird 

hanging and then the equipment came to rest for 

several seconds with the bird suspended in the air 

and flapping its wings.  The equipment then 

began to move the cage into position to enter the 

tunnel of the carbon dioxide chamber.  A metal 

beam of the equipment moved upwards to come 

into contact with and to support the cage from 

which the bird was hanging.  This led to the bird’s 

left wing becoming squeezed in between the 

beam and the bottom of the cage from which the 

bird hung.  The bird was dislodged onto the 

concrete floor below when the cage began to 

move into the tunnel.  The Evisceration 

Superintendent immediately humanely 

euthanized the bird.  I informed the Establishment 

that I would document my observations on an 

MOI for the mistreatment of a live and conscious 

bird. 
 

-

-

.....: 

-

-

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 310 

EstNbr EstName 

P7487 Koch Foods, LLC 

P758 Tyson Foods, Inc 

MOINbr 

SPG22131 

10126G 

ILK111511 

0404G 

Date 

26NOV2019 

04NOV2019 

Task 

Code 

04C05 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

Finalized 

MOI Agenda 

On Tuesday, November 26, 2019, at 

approximately 07:10 performed the good 

commercial practices check. I was standing at 

the entrance of 140 scalder , and observed one 

live chicken entered into the scalder. It was 

blinking its eyes, lifting its head, and had not 

observed cuts to the neck nor any observed 

bleeding. During the GCP check I saw no 

additional live birds enter the scalder. I 

immediately notified the 

about the finding and 

forthcoming GCP MOI. Sincerely, 

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

P-7487 cc . 

DDM , Jackson District Office 

. FLS Chattanooga , TN , Jackson District 

office. 

At approximately 1635 hours on November 01, 

2019 while performing an Ante Mortem 

verification task, the following was observed 

outside of live receiving in the DOA vat: one live 

bird was seen inside the DOA Vat. The live bird 

was breathing, moving its head and was alert. 

The DOA vat was seventy five percent full to the 

top with DOA, water and denaturant. 

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

was immediately notified 

concerning this issue. 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. A copy of this Memorandum of 

Interview will be  forwarded to appropriate 

personal in the District Office. CC: 

(b) (6)

(b) (6)
                                                                                     

                                                                                     

                                                                          

                                                                                     

                                                                                     

                                                                          

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 311 

EstNbr EstName MOINbr 

P764 Perdue Foods, LLC CUA41090 

51620G 

Date 

20MAY2019 

Task 

Code 

04C05 

TaskName 

Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Memorandum of Interview 

May 

20, 2019 

Perdue Foods, LLC 

P-764 

Salisbury, MD Attendees: 

, 

, USDA, P-764 A meeting was held at

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

(b) (6)

Perdue Foods, LLC , 

approximately 0840 hours in the office of the 1st 

Processing Business Unit Leader, P-764, Perdue 

Foods, LLC in Salisbury, Maryland between 

and me. I identified myself as 

He acknowledged that 

(b) (6)

(b) (6)

(b) (6)

he understood my official capacity through the 

conversation. The purpose of the meeting was to 

discuss the poultry good commercial 

practices / poultry welfare concern that I had 

observed at 0704 this morning.  At 0704 while 

performing the good commercial practices check 

in the picking / dressing room, I observed a 

cadaver (a bird with bright red skin color all over) 

on kill line 2 as it moved through the post-pick 

PAA dip tank.  As it exited the dip tank, I could see 

that the head was still attached and that it had no 

kill cut (or other cut) on its neck or throat.  I 

removed it from the line before it went to the 

hock cutters.  I notified 

at that time and 

had call over to the area. 

When arrived at 0712 hours, I showed 

him the cadaver bird.  While waiting for 

(b) (6) (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 312 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda

 to arrive, I continued to observe the birds 

on kill line 2 and saw no further cadavers.  I went 

into the kill room and observed the stunning and 

slaughter process and could not see any problems 

there.  The slaughter process appeared to be 

under control. I reminded that the 

regulations require that live poultry be handled in 

a manner consistent with good commercial 

practices and that they not die from causes other 

than by slaughter.  I told that this 

memorandum of interview will be forwarded to 

the district office and the District Veterinary 

Medical Specialist (DVMS) in case additional 

follow-up is recommended.  told me 

position of the back-up killer for kill line 2.  The 

back-up killer said that excessively small birds 

were being hung on the line, leading them to miss 

the kill blade.  said he coached him 

about stopping the line if such a problem was 

identified, to bring it to their attention (as 

excessively small birds were not supposed to be 

hung by the live hang associates). I attest that 

this memorandum includes all the information 

discussed during the meeting to the best of my 

knowledge. 

Poultry Products Inspection Act and Agency 

that he had spoken with the associate in the 
                                                                                     

                                                                                     

                                                                                     

                                                                                     

 

               

                

                                                    

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 313 

EstNbr EstName MOINbr Date 

Task 

Code TaskName 

P764 Perdue Foods, LLC CUA23080 

61314G 

14JUN2019 04C05 Poultry Good 

Commercial 

Practices 

Status 

Finalized 

MOI Agenda 

Memorandum of Interview 

June 14, 

2019 

Perdue 

Foods, LLC 

P-764 

Salisbury, 

MD Attendees: 

USDA, P-764 

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

(b) (6)

(b) (6)

(b) (5)

A meeting was held at 0744 hours in 

(b) (6)

office at P-764, Perdue Foods, LLC in 

Salisbury, Maryland between establishment 

management and me.  I identified myself as 

.  The 

(b) (6)

(b) (6)

establishment management acknowledged they 

understood my official capacity through the 

conversation. The meeting was held to discuss a 

poultry good commercial practices (GCP) incident 

that I observed while performing a routine poultry 

welfare GCP check in the receiving department at 

0736 hours.  At the dead on arrival (DOA) area of 

the receiving department, I was checking the DOA 

tank and DOA sorting table/tank.  The sorting 

tank is where some birds go immediately from the 

live hang department to be sorted: well birds, 

unwell birds (to be euthanized), and dead birds 

(DOA to go into the DOA dumpster).  Here at the 

sorting tank, I observed a large quantity 

(approximately 400-500) of small birds.  There 
-

-

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

Table: MOIs in Response to FOIA2020-110 10:12 Friday, February 21, 2020 314 

Task 

EstNbr EstName MOINbr Date Code TaskName Status MOI Agenda 

were so many birds that live birds were piling on 

top of dead and non-ambulatory disabled birds. 

took regulatory control of the live hang 

department by tagging the room with U.S. 

Rejected tag number B-45337992 after informing

 that I was doing so and the reason. I 

informed the establishment management that 

this was a poultry welfare concern because birds 

could suffocate due to being piled so high upon 

each other.  The process was out of control during 

this incident and was not acceptable.  The 

establishment management concurred and said 

they would reduce the kill line speed, to decrease 

the rate which the birds were arriving to the DOA 

sorting area.  I reminded the management that 

the PPIA and Agency regulations require that live 

poultry be handled in a manner consistent with 

good commercial practices and that they not die 

from causes other than by slaughter.  I notified 

establishment management that this MOI would 

be forwarded to the district veterinary medical 

specialist (DVMS) and district office in case 

follow-up is recommended. Regulatory control 

was relinquished at 0820 hours upon verification 

of acceptable conditions at the DOA sorting tank. 

I attest that this memorandum includes all the 

information discussed during the meeting to the 

best of my knowledge. 

There were 4 to 5 layers of birds in some areas of 

the table.  I notified 

immediately of my concerns.  Birds 

kept coming from the live hang conveyors, so I