The Congress passed the Humane Slaughter Act in 1958 in response to intense and broad-based public concerns about cruelty and abuse of livestock in meat-packing plants. At that time, the Congress determined that using humane methods of slaughter prevented the needless suffering of livestock, resulted in safer and better working conditions for employees, and brought about improvements in products and economies of slaughter operations, among other benefits. The act established as U. S. policy that the handling and slaughtering of livestock should be carried out using humane methods. However, the act applied only to plants wishing to sell meat products to federal government agencies. In 1978, the Congress passed the HMSA, which amended the Federal Meat Inspection Act and extended the policy nationwide by requiring that all federally inspected slaughter establishments adopt humane handling and slaughter methods. The HMSA requires that animals be “rendered insensible to pain by a single blow or gunshot or an electrical, chemical or other means that is rapid and effective, before being shackled, hoisted, thrown, cast, or cut.” The act also provides for a ritual slaughter exemption that allows the slaughter of animals in accordance with the ritual requirements of any faith “that prescribes a method of slaughter whereby the animal suffers loss of consciousness by anemia of the brain caused by the simultaneous and instantaneous severance of the carotid arteries with a sharp instrument and handling in connection with such slaughtering.” FSIS has issued regulations and directives to enforce the act. Important requirements of these regulations and guidance include the following: All animals must be effectively stunned before they are slaughtered. Stunning is effective when the animal feels no pain, is rendered instantly unconscious, and remains unconscious until slaughtered; Dragging of disabled and other animals unable to move, while conscious, All holding pens and driveways and ramps must be designed, built, and maintained to prevent injury to livestock; Livestock should be provided with water in holding pens, and food if held for more than 24 hours; The use of electrical prods and other devices to move livestock must not be excessive and should be used as little as possible. Figure 1 illustrates two separate stunning efforts—-one of a cow being stunned with a mechanical captive bolt and another of a sheep being stunned with an electrical stunner. As of October 2002, 918 plants were covered by the HMSA in the United States. Figure 2 shows the distribution of these plants. While the plants are concentrated heavily in the Northeast, they tend to be smaller plants. The 49 large producers, who account for approximately 80 percent of total production of meat in the country during fiscal year 2002, are mainly located in the Midwest, as figure 3 illustrates. FSIS is responsible for ensuring compliance with the Humane Methods of Slaughter Act. The FSIS is organized into 15 district offices that include: Alameda, Albany, Atlanta, Beltsville, Boulder, Chicago, Dallas, Des Moines, Jackson, Lawrence, Madison, Minneapolis, Philadelphia, Raleigh, and Springdale. Table 1 shows the states, number of plants, and type of plant, by size, for each FSIS district. In 2002, FSIS employed about 7,600 inspectors at red-meat plants and poultry facilities to inspect each carcass after it is slaughtered to ensure that it is safe for human consumption. Inspectors include at least one veterinarian assigned to each plant, who is required to evaluate the general health of animals before they are slaughtered, and Consumer Safety Inspectors, who are not veterinarians and have varying inspection responsibilities throughout the plant. FSIS officials maintain that as they carry out their food safety and other activities, all inspectors are responsible for monitoring compliance with humane handling and slaughter requirements at plants that are covered by the HMSA from the time livestock come into the custody of the plant to the time of slaughter. According to the FSIS, while the HMSA requires inspectors to observe the entire handling and slaughter process, inspectors do not have to observe all animals all the time for HMSA compliance. In contrast, the Federal Meat Inspection Act requires that each animal be examined prior to slaughter and each carcass be individually inspected after slaughter to ensure that the meat is safe for human consumption. Typically, animals arrive on plant premises, are unloaded from trucks, and then are held in the stockyard area where FSIS inspectors perform the required antemortem inspection. During this inspection, disabled animals are separated from the herd. Animals are then moved through curved holding chutes and forcing pens onto the stunning platform, where they are stunned before being slaughtered. Figure 4 illustrates the areas in a typical, mid-size plant from which inspectors can observe for HMSA compliance, although inspectors are not always present in all areas. When inspectors observe a violation of the HMSA or its implementing regulations, they are required to notify plant management and document, with a noncompliance record, the violation and the actions taken by the plant to correct it. Inspectors can document more than one violation, and different types of violations, in a single noncompliance record. According to FSIS guidance, each noncompliance record should include the following information: A unique record number, The date of the violation, The plant identification number, Humane handling regulations applicable to the incident reported, A written description of the violation, The name of plant personnel notified of the violation, and The plant management’s written response stating both the immediate action to correct the violation and any subsequent action to prevent its recurrence. In response to HMSA noncompliance, FSIS can take a number of enforcement actions—actions that impose restrictions on a facility’s ability to operate. These actions include the following: For less serious violations of the HMSA, inspectors at a facility can issue a “reject tag” to quickly respond to violations that management can readily address. Inspectors physically place these reject tags on a piece of equipment or an area of the plant. This action temporarily prohibits the use of a particular piece of equipment or area of the facility until the violation is corrected. For more serious violations, the district manager can suspend inspection until the violation or violations are addressed. This action, which removes FSIS inspectors from facility premises (or part of the facility), suspends operations at the facility (or part of the facility) because slaughter facilities may not operate without federal inspectors present. In cases where a plant fails to respond to FSIS concerns about repeated and/or serious violations, the administrator of FSIS can withdraw inspection. This enforcement action removes the grant of inspection from a facility, which prevents the facility’s products from entering interstate and foreign commerce. The facility must reapply for and be awarded a grant of inspection before it may resume operations. This action is rarely used. Agency supplemental appropriations in 2001 included $3 million, of which no less than $1 million was to be used to enhance the agency’s humane slaughter practices. USDA used $1.25 million of these funds to hire 17 DVMSs to serve as program coordinators for all humane handling issues. By March 2002, a DVMS was at work in each of the FSIS district offices. The DVMSs, who received extensive training on humane handling and slaughter techniques and related inspection procedures, are the primary contacts for inspectors in each FSIS district office and the liaisons between the district offices and headquarters on humane handling and slaughter compliance. As of May 2003, the 17 DVMSs had visited 576, or about 63 percent, of 918 plants covered by the HMSA. Thirteen of the 16 DVMSs we interviewed said that they had visited all or almost all of their assigned plants at least once. According to these 16 DVMSs, when they came on board, all of them participated in a number of district activities that went beyond the scope of humane handling and slaughter of animals, such as biosecurity and food safety issues. For example, nine DVMSs reported that these activities took 40 to 50 percent of their time. In March 2003, however, an FSIS memorandum directed all but five of the DVMSs to only perform humane handling activities. As a result, the activities of 12 DVMSs changed, and their current focus is solely the implementation of the HMSA. Despite these actions, concerns about the treatment of animals at U.S. slaughterhouses persist. For example, two animal welfare groups, the Humane Society of the United States and the Humane Farming Association, believe that enforcement of the act could be improved. These groups maintain that more continuous monitoring of compliance with the HMSA is necessary. Also, according to the Humane Society, USDA oversight is especially critical at facilities that specialize in disabled animals and old dairy cattle, as well as those with slaughter production lines that operate at high speeds. Conversely, meat industry associations we contacted maintain that the way animals are handled and slaughtered has improved in response to pressure from customers of fast food restaurants and industry audits of slaughter establishments. When Dr. Temple Grandin, a renowned animal science authority, conducted a survey of 24 slaughterhouses in 1996 at USDA’s request, she found that only 36 percent were able to stun 95 percent of the cattle on the first try. When she repeated the survey in 2002, this time visiting 80 different plants, she found that 94 percent were able to do so. While Dr. Grandin’s second survey shows a significant improvement, it still indicates that hundreds of thousands of animals were not stunned on the first try, as required by the act. Thus, there may be undetected instances of inhumane treatment. Dr. Grandin believes that effectively stunning animals on the first try 100 percent of the time is unachievable—that is why she proposed an objective scoring method as an alternative.