ASSESSMENT AND VERIFICATION REVIEWS OF AN OFFICIAL LIVESTOCK ESTABLISHMENT’S ROBUST SYSTEMATIC APPROACH PLAN FOR HUMANE HANDLING AND SLAUGHTER
This notice provides instructions to FSIS Public Health Veterinarians (PHVs), inspection program personnel (IPP) and District Veterinary Medical Specialists (DVMSs) about assessing and informing official livestock establishments whether their written systematic approach for humane handling and slaughter meets the criteria for being a robust plan or not. This notice also indicates the expected frequency for PHV and DVMS verification reviews of an existing robust systematic approach to humane handling and slaughter.
In 2004, FSIS recommended that establishments develop and implement a systematic approach for humanely handling and slaughtering livestock by effectively addressing the four aspects of a systematic approach; those are: assessment, design, evaluation and response.
The industry was told that if we developed and implemented a robust systematic approach then this would be taken into consideration along with other factors when deciding whether to issue a Notice of Suspension (NOS) or Notice of Intended Enforcement (NOIE) action. Experience tells me that this has not been the case. The over enforcement and inconsistency of enforcement of humane handling and slaughter regulations over the last few years has been an ongoing issue for processors. This issue will be at the forefront of AAMP’s efforts in Washington in 2017 once the dust settles on the transition of a new administration. The enforcement of humane handling has been all over the spectrum, and not just between districts, but also within districts. It appears that there are different sets of rules depending on where you are in the country. One district may receive an NOIE and under the same set of circumstances may receive a Notice of Suspension in another district.
If having a robust humane handling program is recommended and not a requirement, and there does not appear to be any difference in the level of enforcement between those who have and those who don’t, why would you open yourself up to the increased scrutiny of this notice? Here is what will be required of you if you choose to have a robust plan. When the establishment management wants to implement an animal-handling program it believes to be a robust systematic approach, it is to request an FSIS review. Once an establishment has a program in place, the associated plan, corrective actions and records produced will be subject to monthly verification reviews by PHVs. DVMSs are to evaluate establishments’ robust systematic approach plans during their Humane Handling Verification visits, which are performed every 12-18 months.
AAMP and its members are fully supportive of humane handling and slaughter regulations. We support having a robust plan in place to make sure we are paying attention to the details and handling animals in our facilities correctly. My opposition to it is that FSIS should get their own house in order and have a clear set of rules and a decision tree in place so that inspectors and DVM’s are responding to incidents in the same way. If a plant has a plan in place and there is a mis-stun and they follow their plan with a follow up stun, then there should be no action taken by FSIS. FSIS cannot continue to enforce from a zero tolerance point of view; that is not reality and they know that, which is why they are requiring a robust plan.
I trust all of our members will continue to do the right thing and handle the animals in their facilities to the best of their ability to ensure a safe, humane kill. A formal response will be sent to Washington explaining AAMP’s position on this and it will be followed by a visit.