A Tale of Two Plants* *(with apologies to Charles Dickens)
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1 A Tale of Two Plants* or *(with apologies to Charles Dickens)
2 Improving Animal Care and Handling Through Collaboration Craig Shultz, DVM Food Safety and Inspection Service Cargill Regional Beef Wyalusing, PA Jerry Karczewski AVP/General Manager Cargill Regional Beef Milwaukee,WI
3 It was the best of times and the worst of times.how two plants with similar processes took different paths to improve animal care and handling.through collaboration (With apologies to Charles Dickens) Milwaukee WI Wyalusing, PA
4 Collaboration: A trusting, respectful, and cooperative relationship that seeks to create distinctive value.
5 Collaboration Today we will consider how collaboration between FSIS and plant personnel can create distinctive value in animal care and handling
6 Part 1: The Wyalusing Story Craig Shultz, DVM Food Safety and Inspection Service Cargill-Taylor Beef Wyalusing, PA A Regulatory Perspective
7 Cargill Taylor Beef Wyalusing
8 The Market Cow
9 Humane Handling GMPs GMP = Good Management Practice Non-food safety initiative addressing improved compliance, product quality, etc. Example Humane Handling Audit Identifies areas critical to compliance in plant s s animal handling system A preemptive approach to regulatory humane handling compliance
10 Know the Rules Acts MPIA, HSA Regulations 9CFR Part 313 Directives FSIS Directive Disabled Livestock FSIS Directive Humane Handling and Slaughter of Livestock Notices FSIS Notice Humane Handling Documentation
11 Addressing Overall Compliance in Facilities Animal Handling Stunning Disabled Animals Self-Assessment Assessment parameters will be plant-specific based on factors such as age and layout of facility, slaughter class, etc. The goal is to meet and preferably exceed regulatory requirements.
12 Facilities 9 CFR CFR (a) Livestock pens, driveways and ramps shall be maintained in good repair. They shall be free from sharp or protruding objects which may, in the opinion of the inspector, cause injury or pain to the animals. Loose boards, splintered or broken planking and unnecessary openings where the head, feet, or legs of an animal may be injured shall be repaired. (b) Floors of livestock pens, ramps, and driveways shall be constructed and maintained so as to provide good footing for livestock. Slip resistant or waffled floor surfaces, cleated ramps and the use of sand, as appropriate, during winter months are examples of acceptable construction and maintenance. (d) Livestock pens and driveways shall be so arranged that sharp corners and direction reversal of driven animals are minimized.
13 Self-Assessment of Facilities Program should address regulatory standard rather than local paradigms Recognize a dynamic process that will change with age of facility, slaughter population, changing environmental conditions, etc.
14 Animal Handling 9 CFR CFR (a) Driving of livestock from the unloading ramps to the holding pens and from the holding pens to the stunning area shall be done with a minimum of excitement and discomfort to the animals. Livestock shall not be forced to move faster than a normal walking speed. (b) Electric prods, canvas slappers, or other implements employed to drive animals shall be used as little as possible in order to minimize excitement and injury. Any use of such implements which, in the opinion of the inspector, is excessive, is prohibited. Electrical prods attached to AC house current shall be reduced by a transformer to the lowest effective voltage not to exceed 50 volts AC. (c) Pipes, sharp or pointed objects, and other items which, in the opinion of the inspector, would cause injury or unnecessary pain to the animal shall not be used to drive livestock.
15 Animal Handling FSIS Directive Once a vehicle carrying livestock enters an official slaughter establishment s premises, the vehicle is considered to be a part of that establishment s premises. The animals within that vehicle are to be handled in accordance with
16 Stunning FSIS Directive Appropriate stunning methods are required for an establishment to be in compliance with the HMSA. When stunning is done correctly, animals feel no pain, are rendered instantly unconscious, and remain unconscious until slaughtered.
17 Many adult cattle that enter slaughter market channels in a disabled state become non- ambulatory during delivery or after arrival at the slaughter facility Transport Livestock Markets Packinghouse
18 Current US regulations state that all non-ambulatory disabled cattle are to be condemned and disposed of in accordance with 9 CFR
19 9CFR 309.2(b) defines non-ambulatory disabled livestock, including cattle as livestock that cannot rise from a recumbent position or that cannot walk, including, but not limited to, those with broken appendages, severed tendons or ligaments, nerve paralysis, fractured vertebral column or metabolic conditions.
20 Down-Cow Humane Handling Additional in-plant measures to minimize handling and discomfort of disabled cattle Minimize handling Provide adequate comfort and protection Timely euthanasia
21 Ambulatory Disabled Cattle
22 Lamenesses Observed in Dairy Cattle at Slaughter Tibial Nerve Paralysis Peroneal Nerve Paralysis
23 Handling Ambulatory Disabled Cattle
24 FSIS Daily Verification of In-Plant Humane Handling: The Humane Handling Checklist Measures for inclement weather Truck unloading Water availability Ante mortem inspection Disabled animals Prod use Slips & falls Stunning efficacy Insensitivity on the bleeding rail Subsets of these tasks are performed daily by veterinarians and/or inspectors. Results are recorded in an electronic database. FSIS Notice 12-05
25 Ante Mortem Findings in Suspect Cattle Est Ante Mortem Suspects to % 20% Surgery 10% 8% Lame Metabolic/Inflam 18% 34% Facial Ocular Misc. 921Suspect Cattle: 885 Holstein Cows, 10 Non-Holstein Dairy, 19 Beef, 7 Bulls
26 Reducing the Ambulatory Disabled Cow Problem Producer quality assurance programs for on-farm humane handling Preconditioning cull dairy cows Direct marketing by larger herds Regulatory controls on the transportation marketing, and slaughter of ambulatory disabled cattle
27 New York State Cattle Health Assurance Program Cattle Welfare Module A Certification Program requiring written SOPs addressing on-farm cattle welfare: Non-ambulatory Cattle Euthanasia Decision Plan Euthanasia Action Plan Lameness Hospital Animals Newborn calves Facilities Movement and handling Routine/Elective Surgical Procedures Transport Decision Plan
28 New York State Cattle Health Assurance Program Animal Welfare Module SOPs reviewed by NYSCHAPS Veterinarian Employees involved in animal care trained and evaluated Signed statement of commitment to animal welfare principles
29 Cornell/Taylor/NCBA Cow Feeding Study 65 head of Holstein cows from auctions Preg. checked and eliminated bred cows 2 pens at Cornell beef T&R center Half implanted with Revalor Fed High grain with Melengesterol Acetate Tested for antibiotic residues and Johnes One pen fed Optaflexx (Ractopamine) last 28 days
30 Adding value through feeding (after culling from the milking herd) Gain significant weight Increase dressing percent Replenish muscle tissue Make yellow fat white Market timing Solving lameness problems (get off concrete) Reduce antibiotic residues Utilize free feeds --- refusal feeds
31 Unseen Cow Defects Johnes Disease Based on tests of fecal samples 24 cows culled 1 mortality 16 (29.1%) diagnosed positive for Johnes Antibiotic Positive Based on Urine Sample 5 (9.4%) initially positive 0 positive at slaughter
32 Direct Marketing by Producers Has the potential to reduce transit time and commingling at cattle markets Recognition of producers consistently delivering high quality cattle (= $?) Problems: Chargeback for condemned cattle can be costly with a BLV herd. Discounting of cattle suspected and residue tested (FAST positives with ceftiofur, subtolerance tetracycline, etc. is a problem).
33 Regulatory Controls on the Movement of Disabled Cattle From a field regulatory standpoint, consistent application is a challenge. When, where, and by whom would transport decisions be made? Ambulatory disabled cattle do not have a high condemnation rate. Therefore, a significant loss of usable protein to the edible channel would occur.
34 Producer Quality Assurance
35 The End Product: Measurable and Meaningful Progress Improved cattle movement Improved facilities that better address the needs of the slaughter population Reduction in prod use Reduction in number of fallen cows in the serpentine Improved equipment maintenance procedures Increased awareness employees, producers and transporters - outreach
36 Process Failure Vortex Poor Communication Failure to address written standard Local Paradigms Aggressive Approach Non-compliance Inability or Unwillingness to comply
37 Industry FSIS Dialog Scheduled periodic discussions of in-plant humane handling Can be included periodically in weekly HACCP meetings Should include HH auditors and animal handling supervisors Audits and findings Facilities improvements Incident reports Non-compliances/corrective actions/preventive measures
38 Effective In-Plant Environment FSIS Verifiable Compliance Industry Documentation Consistent Application of Regulations, Directives, and Notices Dialog Active Monitoring HATS Monitoring Knowledge of Standards Commitment to Principles of Animal Welfare
39 Prioritization Animal Handling
40 Thanks
41 Part II:The Milwaukee Story: A Plant Perspective Cargill Milwaukee Jerry Karczewski AVP/General Manager Cargill Regional Beef Milwaukee,WI
42 Milwaukee Facility Current Footprint
43 Animal Care and Handling: Milwaukee Plant Profile Diverse Cattle Population Internal Auditing Program Animal Handling and Employee Safety Reliability Centered Maintenance Robust People Process Animal Handling and Innovation Reaching beyond Plant Walls: Transportation Collection point auditing
44 Diverse populations include: Dairy cows Fed Steer Beef Cow Bulls Slow Cattle
45 Diverse Populations:Flight Zone Variability Feedlot Cattle - large flight zone Easy to move Behave as a herd Beef Cows - large to medium flight zone Range cattle that are excitable Generally behave as a herd, dangerous if separated Dairy Cattle - small to no flight zone Behave as individuals with herd instincts Bulls- unpredictable, distracted Always handle with caution
46 Animal Handling and Stunning Audit We manage what we measure Reinforces corporate policies and commitment to animal welfare Identifies operator specific tendencies Track other influences such as weather and time of day Details issues like the excitability of the livestock prior to stunning Foundation of our program
47 Animal Handling and Stunning Audit Dedicated auditor Performed daily Biased and unbiased audits
48 The Intersection of Animal Handling and Employee Safety: Why it s s important It s s the right thing to do It s s the law OSHA 29 CFR (a)(1) Humane Methods of Slaughter Act of1978 CFR9 Part 313 Humane Slaughter of Livestock
49 Measuring the Process: Critical Task Audit We manage what we measure Reinforces corporate commitment to animal welfare and employee safety Identifies operator specific tendencies Process improvement tool Biased and unbiased audits
50 Five Critical Task Elements Identified Maintaining a safe position relative to cattle Working in areas with no escape route Handling animals with wild behavior Entering the serpentine with cattle in it Wearing the correct Personal Protective Equipment
51 Handling Safety:Maintain a Safe Position Follow AMI s GMPs for animal care and handling Understand animal behavior Know the flight zone Be conscious of your position Be aware of the position of other people
52 Barn Hot Spots Identified
53 Moving Cattle out of Pen with a No Escape Zone The wall in the back is a no escape zone. When moving cattle out of this pen, always walk along the fence line and keep out of the cattle s path
54 Handling Animals with Wild Behavior Beef cows and bulls exhibit wild behavior Expect the unexpected Always be Alert Be conscious of escape route 2 injuries in the past 2 years Bull rushing gate Employee in serpentine
55 Critical Element 4: Entering the Serpentine A cow s s eye view inside the chute
56 Entering the Serpentine: the Challenge If an animal goes down in the chute, a herdsman enters to attend to the animal Humane handling considerations mean that cattle cannot walk over the downed animal to clear the chute A 1, lb animal in a confined area is a dangerous combination Chute can t t be entered until cattle is backed up to previous barrier No live animal contact
57 Wearing the Chest Protector for Stunner Operators The chest protector is required equipment for all stunner operators for both hand held and pneumatic stunners. Annual refresher training on importance of critical task. Gerardo is wearing gall s Lite contour level III body Armour.
58 Training Introductory training on Critical Tasks and Humane Handling for all new and transfer barn employees OJT for first 90 days. Trainer and Supervisor then qualify barn new hire. Annual refresher for all barn employees and stunner operators. Safety and humane handling roundtables several times/year Awareness training for all Cargill Milwaukee employees
59 Reliability Centered Process: The Team Will vary depending on size of facility. Could join forces with Another facility. Members should be familiar with the property/equipment. Use a mix of operators, handlers QA and maintenance people.
60 Animal Welfare and Nurturing People Kurt Vogel-- --Post graduate UW student Animal Handling special projects for Cargill Milwaukee Member of Plant Animal Welfare committee Presenter at this conference!
61 Animal Care and Handling and Innovation
62
63 Innovation:Stun Checking Tool Worked with Jarvis to develop the AST 100 Stun Checking tool to measure the velocity of the captive bolt
64 Innovation Quick Close Latch Developed by Milwaukee Team
65 Innovation: Borrowing Best Practices: (aka Shamelessly Stealing)
66 Once and Future Innovation: Kevin Repsher and Dingo, the Pens Herd Dog
67 Reaching Outside Our Walls Transporting Cattle Collection Point Audits
68 Reaching Outside Our Walls:Transporting Cattle Semi-annual Seminar and Roundtable Expectations Training Accountability In Development: The Ten Commandments Watkins, Figueroa, O Toole
69 Winter Protocol Trailers delivering cull dairy cows to the plant in cold weather must be boarded up to company specifications
70 Expectations Understanding cattle care and handling Humane handling requirements Transportation GMPs Safety: Responsible and Accountable Special handling, bulls and dairy cows
71 Training Transportation Brochure for Cargill Regional Beef
72 Reaching Outside Our Walls:Collection Point Audits In 2005 instituted audit process for auction barns Water availability biggest opportunity Potential for more activity Cargill/Taylor Beef Auditor: Livestock Market Audit Date: Market Location: Cattle Type Cow Bull Fed Sale Ring Slipping and Falling Excessive slipping and falling No slips or falls Prod and Whip Usage Excessive w hipping or prodding No w hipping or prodding Facility Condition Broken boards, exposed nails, jutting objects Excellent condition Holding Facility Number of Pens Indoor Outdoor Pen Cleanliness Filthy, w et, little or no bedding Clean, dry, w ell bedded Ventilation Lighting No air movement, stale, hard to breathe Air is fresh, easy to breathe Difficult to see Excellent
73 Summary We have a multi-faceted, proactive animal care and handling process. We have been diligent and responsible about training and accountability. We have people who care. We are committed to making a difference in animal welfare.
74 Is it Possible. To have a high level commitment to animal welfare Maintain a regular internal auditing program Provide regular training to handlers and stunners Perform well on 3 rd party and DVMS reviews
75 And encounter regulatory difficulties??? YES!!
76 What happened.. Three NRs in a 3 month period 2 NRs for loose boards NR for gate that a steer put it s s head through Plant entered into FSIS food safety assessment 1 NR for cattle walking around a recumbent animal Inspection suspended for 5 hours
77 What happened. One month into the food safety assessment received an NR for cows walking around a recumbent cow. Inspection suspended for 5 hours until a corrective response written Response included an in depth review of cattle movement through our process
78 Questions We Asked. How did this happen to us? Aren t t we the good guys? Isn t t this a facilities issue? We have a staff of skilled and conscientious handlers. There was no mishandling, abusive or careless behavior. What have we been missing?
79 Findings of Food Safety Assessment No animals were harmed in the writing of the documentation of the NRs Our animal handlers were credited with a highly demonstrated level of care and skill Our barn is old and high maintenance Our biggest opportunity was to become more predictive of facility and cattle movement problems resulting from the facility
80 What We Did: Mapped the process Six Sigma Team developed process flow diagram that depicted every step of the process Tiffany Quantrell,, Walter Jagiello,, Todd Christianson
81 Barn Process Map M ilw au kee B arn Process M ap Cattle Truck A rr iv e s a t Guard Shack C attle T r uc k Driv es to U n lo a d in g D o c k Cattle Truck W aits in the Queue C attle T ruc k backs into U n lo a d in g D o c k Drive r Ch ec ks in w / B a r n B a rn EE Re vie w s Paperw ork A S u ita b le holding pen is chosen & In s p e c t e d Is t h e c h o s e n Hold ing P en C lean & U seable? C attle A re of f - Is a n im a l a b le loaded and Y E S to wa lk to th e N O directed to the p e n? pen S lo w C a ttle S lo w to R is e Non-A mbulatory N O IF P e n N e e d s t o b e c le a n e d : Pen is Cleaned and/or Saw Dust is added to the floor. Q A C h e c k Y E S Id e n t if ie d w / p a in t & n o t e d o n ca rds fo r p e n p e rs o n n e l. A n im a l is e n c o u r a g e d & a id e d t o f e e t. N O A n im a l is s t u n n e d 3 t im e s E y e is p o k e d t o c h ec k fo r s h u t re s p o n s e IF P e n R ailin g s a r e brok e n: Railings are repaired and cleared. Y E S Is a n im a l a b le to m o v e to p e n? W a s th e r e a resp ons e? A n im a l is s t u n n e d a g a in Y E S A different clean and s u ita b le p e n is chosen. D o e s A n im a l p a s s U S D A A n e m o r t e m Ins p e c t io n? N O N O N o n - A m b u la t o ry Y E S c a ttle m o v ed to D e a d P it N o n - A m b u la t o ry c a tt le a r e B S E te s te d by U S D A N o n - A m b u la t o ry N O c a t tle a re p ic k e d u p by K are m a n d re m o v ed C a tt le M o v e d t o Holding pen. C attle M ov e d to K ill P e n s D o e s A n im a l pass U S DA A n e m o r t e m In s p e c t i o n? Y E S Ca ttle M o ve d to Serpentine Q A C h e c k Q A C h e c k Th e A nim al is K n o c k e d. D o e s A n im a l Y E S make it to the N O re s tra ine r? Th e A n im al is K n o c ke d a n d w in c he d fo rwa rd to the kill floo r. The A nimal is Bled and Proc es sed TC : 11 /14 /20 0 6
82 What We Did Using a HACCP approach, converted to a flowchart based on risk categories Mike Shea, John Buchman
83
84 What We Did: Performed a cattle handling risk analysis, identifying critical handling points throughout the process
85
86 What We Did Created Cattle Animal Welfare System (CAWS) based on HACCP principles and documentation Shea, Buchman
87
88 Analysis: Process Failure Vortex Poor Communication Failure to address written standard Local Paradigms Failure to recognize change
89 Some Factors: Lack of collaboration Events in our circuit Change in Personnel DVMS training for ante mortem vet Inadequate NR review Static rather than dynamic process
90 What We Did Engage in active and dynamic collaboration between in plant Cargill and FSIS staff Renewed and reinvigorated high level weekly meetings Expanded the facility Animal Care committee Committed to Managing Above the Audit!!
91 Managing Above the Audit Animal Handling Audit is a process improvement tool A means,, not an end The audit is a measure to drive improvement Dynamic not static Dr. Mike Siemens will discuss tomorrow morning in the Beef Track
92 Effective In-Plant Environment FSIS Verifiable Compliance Industry Documentation Consistent Application of Regulations, Directives, and Notices Dialog Active Monitoring HATS Monitoring Knowledge of Standards Commitment to Principles of Animal Welfare
93 Summary Examined the stories of two plants who took different roads to collaboration Both plants have similar business profiles, but different dynamics No process exists in a vacuum Plants must focus on the regulations, and not the local paradigm Process must be dynamic, not static Collaboration not just beneficial, but necessary Collaboration improves animal care and handling
94
95 The most important factor in care and handling of a diverse cattle population.
96
97 is the human factor
98
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