The Food Safety and Inspection Service of USDA has issued a revision to Directive 6900.2: The Humane Handling and Slaughter of Livestock.
This directive informs inspection program personnel (IPP) of the requirements, verification activities, and enforcement actions for ensuring that the handling and slaughter of livestock, including disabled livestock and livestock slaughtered by religious ritual methods, is humane. This directive provides instructions to IPP (e.g., public health veterinarian (PHV), consumer safety inspector (CSI)) for conducting humane handling activities randomly throughout their tour of duty and provides instructions to IPP, in establishments that assert that they have put in place a systematic approach, on how to assess whether that approach is robust. PHVs are to no longer perform a monthly verification task (Verification of a Robust Systematic Approach) to determine whether an establishment maintains a robust systematic approach for humane handling as they are expected to make this assessment on an ongoing basis and inform the establishment of any status change in this regard. FSIS has modified the definition of egregious inhumane treatment and instructs IPP to document egregious inhumane treatment on a noncompliance record (NR) instead of a memorandum of interview (MOI). This revision also updates instructions for entering humane handling verification data into the Public Health Information System (PHIS).
This revision is something that AAMP has been in discussion with FSIS on for several years, particularly in the definition of an egregious act as it relates to a mis-stun. Let us look at the highlights of this revision and what it means for you. Changes are highlighted in bold red font below.
(1) The Definition of an Egregious act has changed. A mis-stun is no longer considered an egregious act if an establishment has corrective actions in place and they are applied immediately to render an animal unconscious. There are exceptions to this as you will see in the list of egregious acts listed in FSIS definition below. What this means is that you would receive an NR for the mis-stun and not an N.O.I.E or a Suspension unless the incident rose to the level listed in the definition below, then you would receive and NR pending review by the district office, which could result in an enforcement action.
V. HUMANE HANDLING TERMINOLOGY
Egregious inhumane treatment: An egregious situation is an act or condition that results in severe harm to animals, for example:
- Making cuts on or skinning conscious animals.
- Excessive beating or prodding of ambulatory or nonambulatory disabled animals or dragging of conscious animals.
- Driving animals off semi-trailers over a drop off without providing adequate unloading facilities (animals are falling to the ground).
- Running equipment over conscious animals.
- Stunning of animals and then allowing them to regain consciousness.
- Failing to immediately (or promptly) render an animal unconscious after a failed initial stunning attempt (e.g., no planned corrective actions).
- Multiple ineffective stun attempts (2 or more) that are due to one or more of the following establishment failures to properly handle or stun the animal:
- Failure to immediately (or promptly) apply the corrective actions that demonstrate a blatant disregard for animal discomfort and excitement.
- Failure to adequately restrain an animal.
- Failure to use adequate stunning methods (e.g., inadequate air pressure, inadequate caliber, insufficient electric current) for the animal being stunned (e.g., species of animal, size of the animal, etc.).
- Poorly trained/untrained operator or inexperienced operator; or 2
- Prolonged discomfort and excitement of the animal due to the inability to render it insensible/unconscious after the application of the immediate (or prompt) corrective actions.
- Dismembering conscious animals, for example, cutting off ears or removing feet.
- Leaving disabled livestock exposed to adverse climate conditions while awaiting disposition, or
- Otherwise causing unnecessary pain and suffering to animals, including situations on trucks.
(2) FSIS has instructed IPP to document egregious inhumane treatment on a noncompliance record (NR) instead of a memorandum of interview (MOI).
This is new as stated above. IPP will issue NR’s to establishments and verbally inform them of their observations of inhumane handling of livestock. The IPP will then send their observations to their immediate supervisors and the district office to be reviewed and determined if there is a need for enforcement action such as an N.O.I.E of N.O.S to be issued.
(3) Public Health Veterinarians (PHVs) are to no longer perform a monthly verification task (Verification of a Robust Systematic Approach) to determine whether an establishment maintains a robust systematic approach for humane handling as they are expected to make this assessment on an ongoing basis and inform the establishment of any status change in this regard.
What is important to understand here is that if you have decided to have a robust humane handling program, it will no longer be a monthly task for the PHV to review but instead, they will be monitoring it on an ongoing basis and informing you if they feel it is not up to where it needs to be. The reason for having one in place is to ensure that you have an effective plan in place for handling livestock throughout your slaughter process and that it is a written plan that can be followed with corrective actions. FSIS has said that this will be considered when evaluating an egregious act or non-compliance. It is also important to understand that this is not a regulatory requirement, you can have a good humane handling plan written down that you follow and not call it a robust plan as stated below in the directive.
VI. SYSTEMATIC APPROACH TO HUMANE HANDLING AND SLAUGHTER (SYSTEMATIC APPROACH) IN A WRITTEN ANIMAL HANDLING PROGRAM
(A) There is no regulatory requirement for a written systematic approach to humane handling. However, an establishment may choose to develop and implement a robust written animal handling program that effectively addresses the four aspects of a systematic approach that FSIS outlined in the Federal Register Notice [Docket No. 04-013N] Humane Handling and Slaughter Requirements and the Merits of a Systematic Approach to Meet Such Requirements.
(B) These four steps are:
- Conduct an initial assessment to determine where, and under what circumstances, livestock may experience excitement, discomfort, or accidental injury while being handled in connection with slaughter, and where, and under what circumstances, stunning problems may occur.
- Design facilities and implement practices that will minimize excitement, discomfort, and accidental injury to livestock.
- Evaluate periodically the handling methods the establishment employs to ensure that those methods minimize excitement, discomfort, or accidental injury and evaluate the stunning methods periodically to ensure that all livestock are rendered insensible to pain by a single blow.
- Respond to these evaluations, as appropriate, by addressing problems immediately and by improving those practices and modifying facilities when necessary to minimize excitement, discomfort, and accidental injury to livestock.
(C) When establishment management believes they have an animal handling program that equates to a robust systematic approach and would like it reviewed by FSIS, IPP is to review the program and any records generated during its implementation.
(4) IPP are to take into consideration whether the establishment has implemented and maintained a robust systematic approach in determining how to proceed in the circumstances set out in Chapter V, III, A (e.g., how to proceed when an incident occurs that involves egregious inhumane treatment of an animal).
D. The establishment is not required to provide IPP access to a written humane handling program. However, IPP will not be able to verify the effective implementation of a program that the establishment believes reflects a robust systematic approach without access to the written program. Because a documented systematic approach is not a regulatory requirement, failure to implement provisions of such a program is not a non-compliance unless such failure to implement results in an identifiable failure to meet specific regulatory requirements.
E. If the establishment develops and implements what it considers to be a robust systematic approach and IPP has informed the establishment that the Agency agrees, IPP is to verify the implementation of the establishment’s robust systematic approach, as described in Chapter IV. II.
F. NOTE: If an establishment is suspended (Notice of Suspension (NOS)) or receives a Notice of Intended Enforcement Action (NOIE) due to egregious inhumane handling and slaughter event, they will no longer be considered by FSIS to have a robust systematic approach. The establishment will need to proffer corrective actions and preventive measures to the DO to develop a verification plan (Refer to FSIS Directive 5100.3 “Administrative Enforcement Action Decision-Making and 4 Methodology”). The establishment may request a review of their system after the suspension has been lifted to determine if their system is again robust.