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NMA Agenda
Introduction
Review of FSIS Systematic Approach
Government Verification
Components of a Robust Systematic
Approach
Common Humane Handling
Challenges and Solutions
Open Discussion and Questions2
NMA Agenda
Introduction
Reasons for Changes to FSIS
Directive 6900.2, Revision 2
“Humane Handling and Slaughter of
Livestock”
Webinar Objectives
3
NMA Reasons for Changes to 6900.2, Rev. 2:
The new directive incorporates:
FSIS Directive 6900.1 related to
humane handling of disabled livestock
FSIS Notice 06-11 related to Humane
Handling at All Entrances and the
APHIS Twenty eight hour law
regarding transport
4
NMA
The new directive provides:
A definition of “egregious inhumane
handling”
Actions to take if a violation occurs
5
Reasons for Changes to 6900.2, Rev. 2:
NMA
Instructions for Inspection Program
Personnel (IPP):
For verification when an establishment
has a written animal handling program
that incorporates a “robust systematic
approach”
For actions if IPP observe inhumane
handling of animals under Custom
Exempt (issue an MOI)6
Reasons for Changes to 6900.2, Rev. 2:
NMA
The new directive:
Provides instructions to inspectors to verify that
an establishment:
Does not use any secondary entrances or
equipment to handle livestock inhumanely or
to violate the Humane Methods of Slaughter
Act (HMSA) or
the Federal Meat Inspection Act (FMIA)7
Reasons for Changes to 6900.2, Rev. 2:
NMA Webinar Objectives
To understand the benefit of
developing and implementing a
written humane handling program
incorporating the components of
the “Systematic Approach” and how
managing humane handling can
prevent regulatory action.8
NMA Agenda
Introduction
Review of FSIS Systematic
Approach
9
NMA Systematic Approach
September 9, 2004:Notice 04-13N:
With a systematicapproach,establishmentsfocus on treatinglivestock in such amanner as to
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NMA
Minimizeexcitement,discomfort, andaccidental injurythe entire time theyhandle livestock inconnection withholding andslaughter
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Systematic Approach
NMA
LivestockEstablishments can
1) Conduct an initialassessment todetermine whenanimals can experienceexcitement, discomfortor injury12
Systematic Approach
NMA
2) Design facilities and practices tominimize the possibility ofexcitement, discomfort or injury
13
Systematic Approach
NMA
Livestock Establishments can
3) Periodically evaluate handlingmethods including stunning
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Systematic Approach
NMA
4) Improve practicesand modifyfacilities whennecessary
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Systematic Approach
NMA
1) Animal movement
2) Livestock type andgenetics
3) Electric prod use isminimized
4) Access to water
Step 1Assess
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Systematic Approach
NMA
5) Sufficient room in holding pens foranimals held overnight (feed)
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Systematic Approach
NMA
6) Training of personnelon prod use, stunningand proper animalrestraint
7) Whether potentialweather conditionscould lead to inhumanetreatment
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Systematic Approach
NMA
1) pens, drivewaysand ramp design
2) pens preventinjuries
Step 2: Analyze compliance
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Systematic Approach
NMA
4) Driveways donot have sharpturns or suddenreversals
3) Floors arenon-slip
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Systematic Approach
NMA
Step 3 Evaluate methods
1) Handling
2) Stunning
Be sure to documentevaluations!
Step 4 If deficiencies arefound, improve practices
Be sure to documentactions and changes!
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Systematic Approach
NMA
After issuance of this directive IPPwill:
Hold a meeting withestablishment management
Inform the plant that if it has arobust systematic approach:
• FSIS will take that intoconsideration should it benecessary to determine how toproceed in the circumstancesinvolving an egregiousinhumane treatment incident.22
Systematic Approach
Voluntary!
NMA
If the plant states that it has ananimal handling program thatequates to a robust systematicapproach: IPP will verify that:
Procedures are observed
Documentation is reviewed
Establishment’s program isfollowed
Program complies with thehumane handling regulations
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Systematic Approach
NMA Agenda
Introduction
Review of FSIS Systematic Approach
Government Verification:
HATS
Enforcement and Non-Compliance
Benefits of the Systematic Approach
Egregious inhumane handling24
NMA HATS
Definition: Humane-handlingActivities Tracking System
Part of eADRS (electronic AnimalDisposition Report System)
Activities should be performed atrandom times
At least one activity performedeach slaughter shift (15 minutesor more for larger plants)
NMA
Prioritize based on:
previous activity
historical documentationand
DVMS (District VeterinaryMedical Specialist)direction
HATS
NMA
Inspectors verify (basedon ISP code 04C02):
I) Adequate measures forinclement Weather
II) Truck Unloading
III) Water and Feed Availability
HATS Categories
NMA
IV) Handling duringAnte-MortemInspection
V) Handling ofSuspect andDisabled Livestock
VI) Electric Prod andAlternative ToolUse
HATS Categories
NMA
VII) Observationsfor slips and falls
VIII) StunningEffectiveness
IX) Check forConsciousAnimals on therail
HATS Categories
Photos by Temple Grandin
NMA
For establishments with a“robust systematicapproach”, IPP verifythrough:
Observation of procedures
Record review
IPP assure that:
Establishment is followingits animal handling program
Taking corrective actionwhen appropriate.30
Systematic Approach
NMA
31
Systematic Approach
If the IPP observes that the plant is notfollowing the program: Discuss their observations with plant
management. Document discussion in MOI
(Memorandum of Interview) If IPP continues to observe ineffective
implementation, notify the District Office(DVMS or DDM) by email.
NMA Enforcement: Non-egregious
If IPP observe a non-compliance that is notegregious
• Facility condition
• Actions of employees
• HH non-compliance thatdoes not involve injury ordistress to livestock
• (Ex: Animals driven fasterthan a normal walkingspeed)32
NMA Enforcement
If IPP does not receiveadequate response orCA or NC continues,IPP will take regulatorycontrol action
33
IPP will:
• Inform the establishment to correct orstop the Non-Compliance (NC)
• Issue an NR
NMA Enforcement
IPP will:
• Verify that theestablishment takes theappropriate corrective orpreventative actionsbefore removing theregulatory control action.
34
If NC continuesor is notadequatelycorrected, IICwill contact FLSand DVMS todetermine if anNOIE should beissued
NMA Enforcement: Egregious
If IPP observe a non-compliance that is of anegregious nature, IIC will:
• Immediately stop theinhumane slaughter orhandling of livestock
• Take regulatory controlaction
35
• Orally notify plant management
• Correlate with FLS, DO or DVMS to discuss andrecommend that a suspension action be taken
NMA HOWEVER:
In a situation where an establishment:
• Does not have any recent HH relatedenforcement actions
• Has consistently been meeting HHregulatory requirements
• Has been operating under a written animalhandling program that the plant considersa “robust systematic approach”
• Has demonstrated the robustness of theprogram by effectively and consistentlymeeting all aspects of the program36
NMA NOIE, not Suspension:
The IIC, based on consideration of the above, mayrecommend in an MOI to the FLS, DO, andDVMS that the egregious act be subject toenforcement discretion and recommendissuance a Notice of Intended Enforcement(NOIE) rather than a notice of suspension.
37
NMA Decision Points:
• The decision to recommend this enforcementaction is based on the Rules of Practiceregulation (9 CFR 500.3(b)) that states: “FSISalso may impose a suspension withoutproviding the establishment prior notificationbecause the establishment is handling orslaughtering animals inhumanely.”
• In determining whether the egregious act is an“anomaly”, and whether the plant should beallowed to continue to operate, IIC, FLS, DO andDVMS are to consider:
38
NMA Considerations:
Whether the establishment:1. is operating under an animal handling
program that provides for how theestablishment will respond if anunforeseeable event of this type occurs;
2. has any basis for concern that the plannedresponse in the establishment’s animalhandling program will not effectively addressthe problem;
3. has consistently and effectively implementedtheir animal handling program over time.
39
NMA Decision Points:
In situations where the establishment has:• no written animal handling program or• IPP have not determined that the
establishment has implemented a robustsystematic approach
• where an immediate suspension actionwould be warranted but is likely to result ininhumane treatment of additional animals(e.g., a line stoppage that may result inanimals having to stay on a truck during anextremely hot day)
40
NMA Suspension Delay:
• the IIC may delay implementation of thesuspension action until he/she can ensurethat animals on-site or in-transit havebeen handled humanely.41
NMA Suspension Delay:
In deciding whether to delay implementation of asuspension, the IIC is to consider:
• What immediate corrective action theestablishment is taking?
• How likely is it, given the establishment'shistory, that the corrective action will beeffective in preventing a recurrence of the rootcause of the situation?
• How many animals are on premises or enroutethat will need to be slaughtered?
• What conditions threaten the welfare of theanimals if they are not promptly slaughtered?
42
NMA Suspension Delay:
The IIC:• will move an inspector trained on HH to directly
observe handling and slaughter• may allow slaughter to continue at reduced line
speed• is to promptly effect the suspension once he or
she determines that animals will not be furthersubjected to inhumane handling
• is to document their observations and actionson an MOI and submit this to DO
43
NMA Linking NR’s:
44
To determine whether a non-compliance trend exists, IPP willanswer the following questions:
• How much time has lapsed since the previousNR was written?
• Was this non-compliance from the same orrelated cause as the previous NR?
• Were the establishment’s further plannedactions effectively implemented?
• Is the establishment implementing additionalplanned actions that reduce the possibility ofrecurrence?
NMA Benefits of a SystematicApproach:
45
• Chances of the IIC observing a non-compliance are greatly reduced!
• If a non-compliance is observed, thepresence of a written, robust systematicapproach can prevent a plant suspension
• By considering potential non-compliancesand outlining corrective actions, the plantteam will be better prepared for an“anomaly” or non-egregious HH situation
NMA
Egregious Situations
Making cuts on orskinning a consciousanimal
Excessive beating orprodding of animals
Dragging aconscious animal
Egregious Situations
NMA
Driving animals off a truckor over a drop-off withoutproviding adequateunloading facilities
Running equipment overconscious animals
Stunning of animals andthen allowing them toregain consciousness
Egregious Situations
NMA
Multiple attempts,especially in theabsence of immediatecorrective measures, tostun an animal verses asingle blow or shot
Dismembering aconscious animal
Egregious Situations
NMA Egregious Situations
Leaving disabledlivestock exposedto adverse climateconditions whileawaitingdisposition
NMA
Otherwise causingintentional orunnecessary painor suffering toanimals includingsituations ontrucks
Egregious Situations
NMA Agenda
Introduction
Review of FSIS Systematic Approach
Government Verification
Components of a Robust
Systematic Approach
51
NMA
Describes: Procedures implemented to stay in
compliance
Records kept to demonstrate that program isimplemented as written
Records to demonstrate the program willprevent potential non-compliances
Actions the establishment will take when itfails to implement program as written or failsto prevent a non compliance
Written Program
NMA
Include: Diagrams or blueprints of
the animal handlingsystems
• Receiving area
• Holding pens and alleys
• Crowd pen and lead upchute
• Stunning area
• Restrainers
• Bleed rail
Initial Assessment
NMA
Can Include:
Flowcharts (riskassessment)
Written evaluations
Photographs (beforeand after)
Initial Assessment
Minutes of team meetings
Written Standard Operating Procedures(SOP’s)
NMA Before / After
Photos byT. Grandin
NMA
Cargill AMI Presentation
NMA Factors that Affect AnimalHandling: Issues
Make a table to outlineareas where the followinghumane handling issuescan occur:
Slips and falls
Bruising and cuts
Truck discomfort
Ease of movement
NMA
Lighting
Reflections
Sunlight/shadows
Machinery noise
Other noise
Air flow/smell
Insensibility issues
Factors that Affect AnimalHandling: Causes
Photos: T. Grandin
NMA Map of potential problem areas
Cargill AMI Presentation
NMA Facility Design andHandling Practices
Address:
SOP’s for live animalhandling:
• Providing water and feed
• Providing ample penspace (stocking density)
• Special procedures fordisabled or young animals
NMA Employee Training
Training should include:
Initial training for animalhandlers and truckers, priorto working with animals.
Training methods
Training materials (videos, slides, etc.)
A quiz to measure understanding
Visual review (verification) of practices toassure effectiveness
Quarterly or annual retraining
NMA Implementation andOngoing Evaluation
Monitoring anddocumentation shouldinclude:
Work orders and records forcorrective actions
Maintenance records forstunners and otherequipment used to handleanimals
A log book works well forsmall plants
NMA Implementation andOngoing Evaluation
Monitoring can include: Internal audits of HH practices (follow AMI
and industry formats, document frequencyand points reviewed)
3rd party or corporate audits of HH practices
Video surveillance, including review of livefeed or recordings
Statistical Process Control (SPC) or trendingto review measures and deficiencies
Program Reassessment at least annually
NMA Pro-active Actions
Document actions to take and actuallytaken when issues occur:
Emergency management plan for livestock:considering floods, tornados, poweroutages, fire or mechanical breakdowns, etc.
Corrective action documentation fordeficiencies identified during daily activitiesand monitoring
Guidance for employees when unanticipatedincidents occur:
• AW Corrective Action Report
NMA Corrective Actions
Example of Program CorrectiveActions for audit deficiency:
1. Notify supervisor and superintendent of thefailure. Recheck in 30 minutes.
2. Notify supervisor and superintendent of thefailure. Recheck in 30 minutes.
3. Notify supervisor and superintendent of thefailure. A 10% line speed reduction until 2consecutive rechecks at 30 minutes apartmeet the process control standards.
NMA Agenda
Introduction
Review of FSIS Systematic Approach
Government Verification
Components of a Robust Systematic
Approach
Common Humane Handling
Challenges and Solutions66
NMA Slipping and Falling
Short Term:
• Barn lime
• Sand
• Salt
Medium Term:
• Scrub Cement
• Acid Etch Cement
• Utilize Mats (ddfamilymats.net)
NMA Slipping and Falling
Long Term:
• Score or stampconcrete
• Add rebar orcleats
NMA
Noise:
Sound Baffles andSilencers
Distractions and Balking
Light / Contrast: Spot Light Tarp
Visibility: Cardboard Curtains Walls
NMA
Reduce electricalprod use
Alternative:
• Vibrating Prod
• Air operatedengraver withsoftenedcarbide tip
Balking
• http://www.mcmaster.com/#1564t68/=3fhywv
Keep animals calm!!!
NMA Agenda
Introduction
Review of FSIS Systematic Approach
Government Verification
Components of a Robust Systematic
Approach
Common Humane Handling
Challenges and Solutions
Open Discussion and Questions71
AMI Website:
www.animalhandling.org
www.grandin.com
Auditing: Interpreting AMIGuidelines
More Info
72
Summary
Humane Handling
1.Use a systematicapproach
2.Minimize animalexcitement, injury
3.Facility design andmaintenance arecritical
73
4. Provideemployeetraining5. Measureresults
6. Document!!
