A Systematic Approach to Humane Handling and Slaughter

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A Systematic Approach to Humane Handling and Slaughter Dean Danilson Vice President Food Safety & Quality Assurance Tyson Foods, Inc.

A Systematic Approach to Humane Handling and Slaughter FSIS Notice: Federal Register, September 9, 2004 FSIS believes a systematic approach is beneficial in meeting the requirements for humane slaughter and handling in the Humane Methods of Slaughter Act (HMSA), Federal Meat Inspection Act (FMIA) and implementing regulations. The notice encourages livestock slaughter establishments to use a systematic approach to humane handling and slaughter to best ensure that they meet the requirements of the HMSA, FMIA, and implementing regulations. In this 2004 notice, FSIS listed four activities that establishments should do to develop and maintain a systematic approach to humane handling and slaughter.

A Systematic Approach to Humane Handling and Slaughter Step1: Conduct an initial assessment of where and under what circumstances livestock may experience excitement, discomfort, or accidental injury while being handled in connection with slaughter and under what circumstances stunning problems may occur; Step 2: Design facilities and implement practices that will minimize excitement, discomfort, or accidental injury; Step 3: Evaluate periodically their handling methods to ensure they minimize excitement, discomfort, or accidental injury and evaluate periodically their stunning methods to ensure that all livestock are rendered insensible to pain by a single blow; and Step 4: Improve handling practices and modify facilities when necessary to minimize excitement, discomfort, and accidental injury to livestock.

Tyson Fresh Meats Systematic Approach to Humane Handling & Slaughter FSIS Notice: Federal Register, September 9, 2004 Hallmark-Westland, February 2008 FSIS Notice 16-08 (03/10/08), Humane Handling Activities and Documentation in Livestock Slaughter Establishments Tyson Foods, Code of Conduct

Tyson Fresh Meats Systematic Approach to Humane Handling & Slaughter Utilized FMEA (Failure Modes and Effects Analysis) - a common quality tool used to improve the reliability of a [manufacturing] process - used to revitalized and improve our previous SOP-GMP approach for humane handling and slaughter programs and procedures in beef & pork slaughter plants. RACE (Risk Analysis, Controls and Evaluations) New program developed and implemented at each TFM slaughter facility in Spring 2008. RACE provides formalized platform that guides facility in risk assessment for conditions [old or new] that warrant change to the facility or existing procedures, in order to avoid and prevent egregious or offensive situations or events, and to minimize excitement, discomfort, and accidental injury to livestock in our care.

Tyson Fresh Meats Systematic Approach to Humane Handling & Slaughter RACE program s risk assessment format and flow process has made it relatively easy to gain plant buy-in and implementations and understandings at plants, as it was something that looked-smelt-felt similar to what they were familiar in the plant [HACCP-like]. RACE program, however, is not HACCP, and is not a regulatory or regulated program. (Caution use of direct HACCP reference or inference in trainings or discussions, both internally and externally, to avoid regulatory creep within the plants). RACE program has been well received by plants, and by USDA observer s.

System: Pork Slaughter Prepared By: AH Committee Facility Name - Establishment Number Subsystem: Animal Handling / Slaughter Date Created: 03/22/2008 Component(s): Humane Handling / Humane Slaughter Humane Handling Risk Assessment, Controls & Evaluation - Flow Chart Last Revision Date: New 1. Live Hog Receiving 2. Sort Hogs 3. Scale 4. Tattoo 6. Holding Pens US Passed For Slaughter 9. Drive Alley - Circle Drive 10. Drive Chute 5. USDA Ante-mortem Inspection 7. Holding Pens - US Suspect 11. Restrainer As Necessary / Directed - Any Step Humane Handling / Slaughter Process Euthanize As Directed Euthanize 8. Condemn Pork Slaughter Further Processes 14. Stick 13. Shackle 12. Stunning (Captive Bolt / Electrical)

on oc wn to ould o ably ally im System: Subsystem: Component(s): Pork Slaughter Animal Handling / Slaughter Humane Handling / Humane Slaughter Facility Name - Establishment Number Humane Handling Risk Assessment, Controls & Evaluation Prepared By: Date Created: Last Revision Date: AH Committee 03/22/2008 New # Process Step or Function Potential Issue Cause Control Measure(s) Probability of Occurrence At This Facility Reason for Decision 1 1 Live Hog Receiving 5 USDA Antemortem Inspection Injury Inclement weather, Poor unloading techniques, Inadequate unloading equipment or facilities None Identified N/A N/A Training, Written procedures, Proper Execution by trucker and in-plant team members, Routine Inspection and Preventive maintenance 3. Could occur The Animal Well Being team recognizes there is a potential for animal injuries occurring and have determined that the movement of animals should be performed with a minimum amount of excitement and discomfort to the animal, and at a suitable pace. The facility maintains, at a minimum, an ACCEPTABLE audit rating with respect to slips (<3/100 head audited) and falls (<1/100 head audited). 6 Holding Pens - US Passed for Slaughter 6 Holding Pens - US Passed for Slaughter 6 Holding Pens - US Passed for Slaughter 7 Holding Pens - US Suspect 7 Holding Pens - US Suspect Injury No water available Leaving disabled livestock exposed to adverse climate conditions while awaiting disposition Injury No water available Poor handling techniques, Inadequate or poorly repaired facilitly. Inadequate or poorly repaired facility Inadequate or poorly repaired facility Poor handling techniques, Inadequate or poorly repaired facilitly. Inadequate or poorly repaired facility Training, Written procedures, Proper Execution by team members, Routine Inspection and Preventive maintenance Routine inspection; Preventative maintenance Routine inspection; Preventative maintenance Training, Written procedures, Proper Execution by team members, Routine Inspection and Preventive maintenance Routine inspection; Preventative maintenance 4. Not reasonably likely to occur 4. Not reasonably likely to occur 5. Practically impossible 4. Not reasonably likely to occur 4. Not reasonably likely to occur The facility maintains, at a minimum, an EXCELLENT audit rating with respect to slips and falls (0/100 head audited) and excessive prod use (<5/100 head audited). All pens have water. Repairs are made promptly; temporary water troughs are available for use in the interim. There have been no egregious acts of inhumane handling observed in the holding pens. The facility maintains, at a minimum, an EXCELLENT audit rating with respect to slips and falls (0/100 head audited) and excessive prod use (<5/100 head audited). All pens have water. Repairs are made promptly; temporary water troughs are available for use in the interim. 7 Holding Pens - US Suspect Leaving disabled livestock exposed to adverse climate conditions while awaiting disposition Inadequate or poorly repaired facility Routine inspection; Preventative maintenance 5. Practically impossible There have been no egregious acts of inhumane handling observed in the holding pens.

System: Pork Slaughter Prepared By: Facility Name - Establishment Number AH Committee Subsystem: Animal Handling / Slaughter Date Created: 03/12/2008 Component(s): Humane Handling / Humane Slaughter Humane Handling Risk Assessment, Controls & Evaluation - Master Sheet Last Revision Date: New Process Step Threat Control Measure Critical Limit Monitoring Corrective Action System Record (s) System Verification 1 Live Hog Receiving Inhumane Treatment (including egregious acts) All live hogs are unloaded in accordance with established humane handling procedures for live hog receiving. Any animal not handled in an humane manner. (Based on AMI guidelines and FSIS Notice 16-08 date 03/10/08) Who: One designee randomly selected from list in each group (Operations, QA, and Procurement) What: Evaluate all processing steps Where: Yards, Stunning area When: Once per production period How: Visually observe employee animal handling practices, facility conditions, and equipment maintenance procedures Take control of the situation and notify the Plant Manager and/or Plant Superintendent to evaluate the significance of the deviation, initiate corrective and preventive actions, and determine animal disposition. Animal Well-Being Monitoring Form Who: One random Management designee from list What: will randomly monitor and verify employee animal handling practices, facility conditions, and equipment maintenance procedures Where: Yards, Stunning area When: Once per week How: Visually observe employee animal handling practices, facility conditions, and equipment maintenance procedures

Frequency Rating Table for Risk Analysis Matrix for Humane Handling Issues Effect Rating Common occurance 1 Known to occur 2 Could occur 3 Not reasonably likely to occur 4 Practically impossible 5 Egregious Act Table* 1 2 3 4 5 6 7 8 9 10 Making cuts on or skinning conscious animals Excessive beating or prodding of ambulatory or nonambulatory disabled animals Dragging 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 animals Stunning of animals and then allowing them to regain consciousness Multiple attempts, especially in the absence of immediate corrective measures, to stun an animal verses a single blow or shot Dismembering live animals, such as removing feet from live animals Leaving disabled livestock exposed to adverse climate conditions while awaiting disposition Otherwise causing intentional unnecessary pain or suffering to animals, including situations on trucks * FSIS (03/10/08), FSIS Notice 16-08: Humane Handling Activities and Documentation in Livestock Slaughter Establishments

Tyson Fresh Meats Systematic Approach to Humane Handling & Slaughter TESTIMONIALS Plant Manager - "The RACE concept has made us think twice and act once when considering modifications to handing procedures associated with live animals. It's been a rewarding process to see our animal handlers involved in the process and taking ownership instead of just being trained with a sticker on their hard hat". Plant AWB Team - "Our RACE team includes hourlies and even our front office nurse - whose inclusion onto this team has provided new and different insights to the traditional plant management thoughts on animal handling in our plant Plant AWB Team - Including team members from other departments has brought a new perspective to how we look at the process. Plant AWB Team - Reviewing the entire process as a whole instead of simply relying our previous auditing points has improved our overall system. USDA IIC - This is a great program and should be followed the systematic approach has shown it works in HACCP and it s about time it was adopted for other uses (Local FSIS, in a weak moment of candor). Plant Manager [after suspension]: $%#^&*@# we wished we had listened to you guys and done this right.

Systematic Approach to Humane Handling and Slaughter THE TOTAL SYSTEM Plant AWB TEAM Approach [Diverse, Empowered, Committed, Encompass, Trained] RACE systems approach FMEA model of process step risk assessment / monitoring / corrective actions / preventive actions / trending-tracking / reporting-documenting. Best Practices AMI-Grandin & Industry best practices function as SOP support procedures [prerequisites] within the formalized RACE systems approach program. AMI Audits function to verify the effectiveness of the total systems. Audit findings reviewed and assessed by Plant AWB Team. Daily - conducted periodically at key AWB process control points [i.e. stunning, sensibility, etc], conducted by trained QA/OP s team members as a daily work tasks Weekly full audit conducted by Operations management to verify systems are performing as intended. Monthly full audit conducted by QA management as independent verification of plant AWB system. 3 rd Party Audits periodically conducted by independent 3 rd Party Auditor [PAACO certified] as verification of plant AWB systems. At least annual, but often more frequently [customers, special reviews, etc]. Annual Assessment [Plant-Corporate] at least annually, conduct a full program and system review of the plant[s] programs, results, achievements.

Systematic Approach to Humane Handling and Slaughter CONCLUSION Systems Approach coupled with existing AMI-Industry Best Practices and AMI Auditing actions provides a comprehensive animal well being program for a slaughter facility. FMEA [Failure Modes & Effects Analysis] is a good model to use for designing an AWB systems approach program. An effective Systems Approach should be helpful in establishing more consistent and rational interpretations of egregious situations [and associated actions]. IF done appropriately a Systems Approach to animal well being will take us to the next level of animal well being improvement, similar to what effective HACCP can do for food safety. Thank you