Operational guideline: Humane slaughter guidelines for avian food animals, including ratites

Understanding electrical flow in stunning

To assess compliance in slaughter establishments using electrical stunning, it is essential that you understand how to interpret voltage and amperage displays. Electricity behaves like water flowing in a river, following the path of least resistance:

• voltage (V) in volts: is like the power or pressure pushing the water forward
• resistance (R) in ohms: is like rocks and obstacles that slow down the flow
• current (I) in amperes: is like the actual flow of water through the river

According to Ohm's law: I = V/R

The current needs to be strong enough to penetrate the skull and depolarize the neurons to effectively render the animal immediately unconscious or to cause a cardiac arrest. A current that is too weak will travel over the bird's body surface instead of penetrating the skull, resulting in electro-immobilization (rendering the bird paralyzed but conscious/sensible) rather than inducing an effective stunning.

There are 2 outcomes for effective electrical stunning:

• electronarcosis – the stunning is reversible so the animal is well stunned but can regain consciousness over time if not bled rapidly
• electrocution – the stunning is irreversible and since it also causes cardiac arrest

Both outcomes are acceptable if they effectively cause immediate unconsciousness that lasts until death due to rapid bleeding (in the case of electronarcosis) or until death due to cardiac arrest followed by bleeding (in the case of electrocution). Electro-immobilization is an unacceptable outcome and can happen if birds receive an electrical shock but are not stunned, in this case birds will be paralyzed but will remain fully conscious.

The stunning effectiveness should be verified just after the stun, before and during bleeding and up to the point of the scalder entrance.

The electrical parameters used by the licence holder should be assessed, as they could raise doubts about the stunning efficiency and may be confirmed by the presence of indicators of sensibility: if these parameters are aligned with CFIA recommendations, there is greater confidence in the effectiveness of stunning, but the assessment of birds still needs to be performed.

The electric current intensity (measured in amperes) passing through each bird (calculated as the total intensity divided by the number of birds which are simultaneously in contact with the equipment) must always be sufficient to ensure effective stunning of each bird upon contact with the equipment.

The animal must remain unconscious until death: immediate corrective action must be taken if there is any doubt the animal is regaining sensibility.

Pre-stun shocks

A pre-stun shock occurs when the bird has contact with electrified water or metal grid before proper head stunning and so the bird receives an unintended electrical shock. Pre-stun shocks are avoidable issues in electrical systems that cause animal suffering; they can be easily fixed by the licence holder. Pre-stun shocks are more common in species with long wingspans, such as turkeys and waterfowl, where wings may hang lower than the head.

Tips to help you assess pre-stun shocks

• monitor for wings flapping on the shackle line which could lead them to contacting the stunner upon entry
• check if birds are touching each other on the shackle line
• assess if the stunner height is adjusted so excess brine flows out the exit end, not the entry end
• assess if significant size variation among birds is causing inconsistent immersion or contact
• assess that the descent of the birds is not too gradual, which could cause the beak to slowly touch water or grid and trigger shocks.
• assess birds while they approach and come into contact with the brine solution or metal grid
  • water-bath: the ramp should be inclined and the stunner height adjusted so that birds enter smoothly and are fully submerged up to the base of the wings in one motion
  • signs indicative of pre-stun shocks include:
    • sudden vigorous wing flapping
    • sudden high-pitch vocalizations
    • avoidance behaviour (lifting the head and sometimes the body)
  • more than one contraction upon coming into contact with water or grid may indicate interrupted application of current flow (repeated shocks)
• verify if pre-stun shock monitoring procedures, corrective action and preventive measures are part of the licence holder's PCP for animal welfare
  • verify if pre-stun shock incidents, along with root cause analysis, corrective actions and preventive measures, are documented

Electrical water-bath stunning

Electric water-bath stunning effectiveness involves more than a given set of parameters (voltage, current, frequency, stun duration); it also involves consideration of a variety of bird and equipment factors.

Tips to help you verify an electrical water-bath stunning system:

• assess that the water level and stunner height is adjusted regularly so that the birds' heads are consistently fully immersed in the water-bath
• assess that there is adequate spacing so that birds are not in contact with each other when they enter the stunner
• assess that the shackles are clean and that there is effective shackle grounding (the ground bar must contact all shackles) so that contact is made with the birds and current flows well and steadily (an uninterrupted electrical circuit is maintained)
• if necessary, assess the parameters used and the number of birds in the water bath at the same time:
  • the amperage reading on a water-bath stunner shows the total current in the bath, not per bird.
    • to estimate current per bird, divide the total amperage by the number of birds in the bath (this is only an approximation as each bird's resistance varies)
• if necessary, assess if the salt concentration of the brine is maintained throughout the day to facilitate the flow of an effective electric current through the birds

Electric grid/plate stunning

When using this system, the licence holder must ensure that the bird's eye contacts the electrified grid or plate; this provides a direct path for current through the optic nerve to the brain. Contact with feathers, head, beak or neck alone offers high resistance or bypasses the brain, causing immobilization rather than stunning.

Grid/plate stunners usually do not cause cardiac arrest and may be of shorter duration than a water-bath stun.

2 phase electrical stunning plate system

This system uses a combination of Direct Current (DC) pulsed current for the first wet plate and Alternative Current (AC) sinusoidal current for the second grid/ plate.

1. DC Pulsed Current: High-frequency, direct pulsating current
2. AC Pulsed Current: Lower frequency alternating current with a sinusoidal waveform

Tips to help you verify that a 2-phase electrical stunning plate system is effective:

• assess that the bird's eye is in contact with the electric grid or plate
  • the electric current can enter the skull more easily if the electrified brine solution or the electric grid/plate is in direct contact with the eye
• assess that both DC and AC sections supply enough current to render birds insensible (neither section should simply immobilize birds)
  • if necessary, assess the parameters used and the number of birds in the system at the same time for each phase:
    • the amperage reading shows the total current in the system, not per bird
    • to estimate current per bird, divide the total amperage by the number of birds in the system for each phase (this is only an approximation as each bird's resistance varies)
• assess that the shackles are clean and that there is effective shackle grounding (the ground bar must contact all shackles) so that contact is made with the birds and current flows well and steadily (an uninterrupted electrical circuit is maintained)

Tips to help you assess sensibility, insensibility and return to sensibility after electrical stunning (all systems)

When inspecting birds after any electrical stunning system, consider both the parameters used and the presence of these indicators (outcomes).

• Electronarcosis :
  • presence of tonic and clonic seizures
    • the tonic signs include a mildly arched neck (position should be comparable for all birds at the exit of the stunner), constant rapid body and wings tremors and wings held tightly against the body
    • the clonic signs follow the tonic ones but because birds are shackled, they can be more difficult to observe; when the convulsions cease, the wings will droop (hang down limply) and the body will be relaxed including the neck
• Electrocution :
  • relaxed body including the neck, limp wings dropping away from the body

Effective electrical stunning will result in:

• absence of rhythmic breathing (observed by 2 movements or more of the body wall in the cloacal area)^Footnote 1
• absence of spontaneous blinking (3rd eyelid)^Footnote 1
• absence of beak movement associated with spontaneous swallowing^Footnote 1
• absence of head shaking^Footnote 1
• absence of righting reflex^Footnote 1
• absence of reaction to the cut (no vigorous wing flapping)
• absence of neck tension, arched neck

Differentiating between an unconscious and an electro-immobilized (conscious but paralyzed) bird

At the exit of the stunner, they may appear the same as unconscious birds but careful observation reveals key differences:

• duration of effect
  • effective electrical stunning typically lasts between 30 and 45 seconds, whereas ineffective stunning may be apparent immediately or very shortly after electrical stunning
• seizure activity
  • electro-immobilized birds show no seizures or only weak, partial seizures
  • their wings hang limply with brief immobility (for a few seconds)
• response during neck cutting
  • electro-immobilized birds often flap their wings vigorously when their neck is cut, continuing intermittently until blood loss induces unconsciousness and death
    • this differs from a nerve reflex reaction which can occur (for example, in turkeys) during decapitation or when the knife reaches the spinal cord during the neck cut. In such cases, there is only 1 wing flap when the knife contacts the spinal cord with no further flapping or signs
• due to the paralysis, these indicators of sensibility might be observed but may be subtle – including HPV^Footnote 1 indicators
  • neck tension, arched neck
  • rhythmic breathing in the cloacal area^Footnote 1
  • mouth/beak movements (associated with swallowing)^Footnote 1
  • 3rd eyelid spontaneous blinking^Footnote 1

Thus, if 1 HPV indicator is observed on a few birds or several indicators (including HPV and/or non-HPV) are observed on the same bird, this is an indication of consciousness or return of consciousness and corrective actions must be immediately taken. In ambiguous situations (for example, if only 1 non-HPV indicator is present on multiple birds), further observations of the birds and the parameters used must be performed to ensure that no HPV indicators are observed as well as no other non-HPV indicators so that the birds are efficiently stunned and not electro-immobilized.

The return of rhythmic breathing movements (observed by 2 movements or more of the body wall in the cloacal area) after electrical stunning indicates that some brain functions are resuming due to neuronal reorganization and activity. This suggests that the birds are regaining consciousness or may be already conscious.

The presence of a corneal or palpebral response elicited after stunning and/or neck cutting in electrically stunned animals are not reliable indicators of sensibility or return to sensibility. Due to variability and inconsistent interpretation, these indicators should not be used routinely for electrical stunning. While these eye reflexes confirm that a bird is alive, they do not necessarily indicate that the bird is conscious, especially in the absence of other indicators of return to sensibility. However, spontaneous blinking of the 3rd eyelid (nictitating membrane) is a HPV sign of consciousness or its return in birds.

The presence of beak movements alone can indicate sensibility but particularly if other indicators are observed on a few birds:

• if only beak movement(s) is/are observed, meaning:
  • absence of swallowing
  • absence of water or bubbles coming out of the beak (mouth/nostrils)
  • no HPV indicators
    • no immediate action is required but continue to observe closely for additional signs
• if beak movements persist and occur with swallowing or with any other indicator(s) (HPV or non-HPV)
  • birds are conscious or regaining consciousness and immediate action is required

The CAS system must be designed to allow rapid induction with continuous visual monitoring of birds in the event of a system failure. Under no circumstances should birds show signs of distress, piling, vocalization, standing or falling on top of each other or attempting to escape during the induction, or regaining consciousness during or while awaiting the continuation of the stunning process. Immediate corrective action must be taken if any of these signs are observed during induction, line stoppages or breakdowns. 

Appropriate back-up stunning equipment must be readily available and functional for immediate use in case of main stunning equipment failure: birds must not experience distress or regain consciousness while being transferred to the backup stunning equipment.

Leaving animals in an operating CAS system during breaks is unacceptable and non-compliant with SFCR 128, 141 and 135 (1) (b) due to the risk of avoidable suffering, injury or death to the animals. When the conveyor is stopped, birds are not rendered unconscious rapidly and may regain consciousness before death while waiting in the chambers. Additionally, conscious birds exposed to certain concentrations of gas may experience nasal mucosa irritation, which constitutes an animal welfare concern.

Tips to help you verify sensibility, insensibility, and return to sensibility after CAS

When inspecting birds after CAS, consider both the parameters used and the following indicators (outcomes):

During induction:

• absence of excessive agitation and distress
  • absence of continuous wing flapping
  • absence of escape behavior
  • absence of piling

It is normal to see some degree of discomfort, head movements and gasping but this must not be excessive as severe or rigorous head shaking may indicate painful or irritating inhalation of gas mixture.

• absence of vocalization (can be difficult to assess as the birds are confined inside the gas chamber, but you could see beak movements)

After stunning:

• relaxed body posture, wings dropping
• dilated pupils
• absence of rhythmic breathing (observed by 2 movements or more of the body wall in the cloacal area)
• absence of spontaneous blinking of the 3rd eyelid
• absence of beak movement associated with spontaneous swallowing

Captive bolt stunning (penetrative or non-penetrative) is normally used in birds as a backup or emergency stunning method. It can be used as a main stunning method for small-throughput slaughtering as in small slaughterhouses or on-farm slaughter.

Tips to help you assess sensibility, insensibility and return to sensibility after captive bolt stunning

When inspecting birds after captive bolt stunning, consider both the equipment used and the following indicators (outcomes):

• vigorous wing flapping is normal (loss of brain control over the spinal cord)
• head is limp ("dead")
  • absence of neck tension, arched neck
  • absence of spontaneous blinking of the 3rd eyelid
  • absence of beak movement associated with spontaneous swallowing
• absence of rhythmic breathing (observed by 2 movements or more of the body wall in the cloacal area)

Immediate corrective actions must be taken on each bird that is missed or ineffectively stunned. The following options of corrective actions may be considered acceptable:

• re-stunning with a backup stunning equipment or system
• humanely killing by
  • decapitation, provided that it is performed
    • with an equipment (guillotine or knife) that is sharp and appropriate for the bird's size
    • in one quick motion resulting in a complete severance of the bird's head
    • on a bird that is securely restraint
  • cervical dislocation, provided that it is performed
    • using an acceptable technique by a trained, competent and qualified employee
    • on small birds (under 3 kg)
    • with a device that is designed and appropriate for the bird's size, if mechanical
    • at low speed, where birds can be removed from the shackles, if applicable

It is unacceptable to subject birds that remain fully or partially sensible after gas or electrical stunning to a second pass through the same system, as this causes avoidable suffering (SFCR 128). The licence holder must have emergency procedures in place, including:

• appropriate, functional backup equipment for humane killing or stunning
• equipment kept at hand so ready for immediate use

During prolonged line stoppage or breakdown, if feasible and on a case-by-case basis, the following options of corrective actions may be considered acceptable:

• carefully removing conscious birds from the slaughter line or stunning system and putting them back into crates/modules, if applicable
• stunning conscious birds either directly into the stunning system or on the slaughter line (for example, using a captive bolt)
• humanely killing birds either into the stunning system, on the slaughter line or after their removal from the line, as applicable

Understanding what an objective performance criterion of minimum 98% for stunning effectiveness means

An effective stunning equipment/system must render at least 98% of birds immediately insensible and the unconsciousness must last until death, whether the stunning is reversible or irreversible. Any bird that is missed or has been ineffectively stunned, must be immediately re-stunned or humanely killed by an approved method.

If the effectiveness of the stunning equipment is below 98%, the licence holder must:

• take immediate corrective actions on all conscious birds
• reassess the stunner's performance to identify the root cause and prevent recurrence by taking appropriate preventive measures

When more than 2% of birds are ineffectively stunned, this is an indicator of a potential equipment issue (though other issues could be the cause, for example, improper use of the equipment). Allowing poorly stunned birds to experience avoidable suffering, injury, or death due to equipment malfunction/misuse is unacceptable, regardless of the percentage, so immediate corrective action must be taken on every conscious bird.

Bleeding must occur as soon as possible after reversible stunning to prevent birds from regaining consciousness. As outlined in CFIA Industry Guidance – Guidelines for stunning techniques for avian food animals, including ratites, it is recommended that the maximum time interval between stunning and bleeding be:

• electrical stunning and non-penetrating captive bolt: within 10-15 seconds after stunning
• gas stunning: within 60 seconds after leaving the gas chamber

Recommend method

Cutting both carotid arteries and jugulars veins is strongly recommended as it ensures faster exsanguination resulting in rapid blood loss and death. However, cutting at least 1 carotid artery and 1 jugular vein is compliant provided bleeding is efficient to cause rapid death before the animal's recovery.

Assessment of the cut

The automatic neck cutter must be properly adjusted for the size of the birds to ensure:

• all the birds are cut and the cut is properly placed below their mandible
• birds are not piling in front of the equipment

Minimum bleeding time

The absence of visible signs of sensibility does not guarantee that all birds are dead before entry into the scalding tank. Therefore, bleeding time of at least 90 seconds is applicable to all bird's species and to all slaughter methods.

Automatic neck cutting equipment

A properly functioning automatic neck cutter must bleed at least 99% of birds efficiently. Any bird missed or poorly cut by the neck cutter must be:

• cut by a backup neck cutter immediately –as long as the bird is unconscious
• humanely killed immediately (specifically if close to the scalder)

If the effectiveness of the equipment is below 99%, the licence holder is required to take immediate corrective action and reassess the equipment performance to identify the root cause and prevent recurrence. For detailed requirements, refer to the Objective performance criteria for humane handling, stunning and slaughter – birds.

When more than 1% of birds are ineffectively cut, this is an indicator of a potential equipment issue (though other issues could be the cause, for example, improper use of the equipment). Allowing poorly bled birds to experience avoidable suffering, injury, or death due to equipment malfunction or misuse is unacceptable, regardless of the percentage, so immediate corrective action must be taken on every poorly bled bird.

Decapitation as an alternative to automatic neck cutting

Some licence holders may wish to decapitate all the birds just after stunning (continuous decapitation). Due to the inability to monitor the potential return to sensibility downstream from decapitation, this practice is only acceptable if the licence holder can validate that the stunning process (including the parameters) is constantly effective. The purpose of validation is to make sure that decapitation does not mask ineffective stunning. When decapitation occurs a few seconds after stunning, it becomes impossible to confirm compliance with SFCR 141.

Verify that the licence holder has a system in place to detect any bird missed by the automatic decapitating equipment, and immediate corrective action procedures for such birds.

Application of a post-stun electrical shock to promote rapid bleeding

Some licence holders may wish to apply an electrical shock on already stunned birds to enhance bleed-out.

This practice is only acceptable if the licence holder can validate that the original stun was effective because:

• electro-immobilized birds, or those regaining consciousness from the stun before dying of blood loss will be subject to avoidable suffering. 
• the electrical shock may be used to mask inadequate stun, preventing observable signs of sensibility during the bleeding process.

A licence holder wishing to apply a post-stun electrical shock must demonstrate that:

• original stunning is reliably inducing an effective stun
• bleeding occurs rapidly after the stun
• bleeding is effective
• employees are present to:
  • monitor for poorly stunned and poorly bled birds
  • rapidly re-stun or cut or humanely kill poorly stunned or bled birds before the electrical shock
  • stop the line to assess the equipment in order to put the process back into control if stunning or bleeding is ineffective

Inadequate bleeding

Inadequately bled birds have a neck cut, but they have not bled out properly. The licence holder must establish and document a critical limit in their PCP for animal welfare along with a procedure to address this deviation. When the limit has been reached, the licence holder must identify the root cause and take preventive measures to avoid recurrence.

Since automatic cutting equipment shall perform effectively at least 99% of the time, a 1% limit for inadequately bled birds may be considered reasonable.

Uncut birds

Uncut birds have no neck incision, either because they missed the cutter or were cut in an incorrect location on their body. Uncut birds are zero-tolerance deviations requiring the licence holder to take immediate corrective action on the birds for each occurrence.

Stunning and bleeding are necessary to ensure birds remain unconscious until death. Bleeding the animal is also part of the requirements of SFCR 141, 142 and 145. For these reasons, the absence of a proper neck cut is non-compliant with the regulation and constitutes an animal welfare issue, as the bird may regain consciousness and enter the scalding tank alive (SFCR 128).

Although there is a zero-tolerance for uncut birds, this does not mean that zero incidence is guaranteed. The licence holder must implement preventive measures to minimize this risk to keep the occurrence as close to zero as possible. For instance, when operating at high speeds or processing flocks with variable bird sizes, assigning additional back-up employees as well as reducing the line speed and triaging smaller birds are among options to help comply with the regulation.

In practice, it is impossible to completely eliminate uncut birds, just as it is impossible to qualify the "acceptable" number of uncut birds, since any bird entering (or likely to enter) the scalding tank alive is unacceptable. Therefore, the operator must aim for zero incidence while incorporating into the PCP for animal welfare a system to identify and respond to deviations. For instance, the occurrence of 1 uncut bird must trigger an immediate response to prevent recurrence. An effective PCP for animal welfare therefore ensures that, when these rare cases of uncut birds occur, the licence holder immediately takes effective corrective action for each bird, conducts a root cause analysis, and implements preventive measures to prevent recurrence.

Any bird missed by the neck cutter must be immediately cut by a backup neck cutter (as long as the bird is unconscious) or humanely killed without delay.

When their limit for inadequately bled birds is reached, or when uncut bird(s) are observed, stunning and killing procedures must be evaluated and corrective actions must be immediately taken by the licence holder to correct the deviations and prevent recurrence.

It is a non-compliance if the incidence of uncut birds is no longer exceptional – indicating a pattern of failure.

Refer to section 6.2.3.3 for more details on zero-tolerance deviations. CFIA should ask for the collaboration of the licence holder in order to be notified when they observe that their pre-determined limit for inadequately bled birds has been reached or when uncut bird(s) are detected by employees on the line.

The use of live animals for initial testing (to set the parameters) of any type of stunning equipment is unacceptable as it poses a significant risk of causing avoidable suffering if the equipment is not immediately and fully capable of producing an effective stun. Before testing begins, the equipment must be set according to recognized standards and parameters for the species, size/weight, sex and age to ensure an effective stun. If the equipment cannot produce an effective stun either immediately (in case of electrical and mechanical stunning) or rapidly (in case of gas stunning), avoidable suffering would occur, resulting in a non-compliance with SFCR 128 and 135 (1)(b) and 141.

For electrical stunning, commercially available equipment can simulate the resistance of a live bird and provide an estimate or actual measurement of the current delivered to each bird. There are a few different types of equipment available, such as in-line, stand-alone meters or remote stun monitors; these are often referred to as "dummy loads" or "dummy birds". Carcasses of recently dead birds in good body condition can also be used to calibrate the equipment.

If a licence holder wishes to electrically stun birds prior to performing a religious cut, the requirements of SFCR 141 fully apply to all birds; this means:

• the stun must be effective
• monitoring must confirm stunning is compliant
• immediate corrective action must be taken if stunning is ineffective
• the birds must stay unconscious until their death by bleeding

Light stunning or electro-immobilization, intended only to immobilize birds prior to a religious cut, is unacceptable. The licence holder may adjust electrical stunner settings to ensure birds are not killed by voltage/current/frequency combinations and use parameters known to cause electronarcosis, but the electrical current applied to each bird must be strong enough to effectively stun each bird, so they do not regain consciousness before death. The religious cut must be performed as soon as possible after stunning (within 10-15 seconds).

The term "avoidable" in the SFCR animal welfare provisions implies that some degree of suffering, injury or death is considered "unavoidable" during specific steps of the slaughter process. For example, death by slaughter or the brief suspension of conscious birds immediately (meaning, promptly/for a minimum amount of time) before stunning are considered "unavoidable". However, the intent of the regulation is not to apply the concept of "unavoidable" broadly across multitude situations within a slaughter establishment, such as to justify deficiencies in the implementation of a licence holder's PCP for animal welfare.

Interpretation of "unavoidable" and "avoidable" suffering, injury or death when you verify compliance with the SFCR:

• "Unavoidable" suffering, injury or death refers to situations where suffering, injury or death
  • are inextricably tied or inherent to the slaughter process itself and cannot be prevented or eliminated despite the application of best practices and management of all risk factors under the control/responsibility of the licence holder
  • arise from unforeseen/unpredictable events beyond the licence holder's control

Note: a rare situation does not in itself make it unavoidable. For a situation to be considered unavoidable, it must be unpredictable and/or impossible to prevent. Emergency plans must be an integral part of the PCP for animal welfare in order to minimize suffering, injury, or death of animals during unforeseen situations.

• "Avoidable" suffering, injury or death refers to all other cases where suffering, injury or death may occur in the context of slaughter processes and which must be prevented or eliminated
  • In general, "avoidable" situations of suffering, injury or death are
    • foreseeable – known/documented risks, predictable based on the circumstances or on the fact that they have occurred before
    • preventable –best practices or reasonable means exist under the control/responsibility of the licence holder to prevent or eliminate the risk of their occurrence
• Licence holders are responsible for identifying all risk factors and implementing mitigation preventive measures for all risk factors within their control or responsibility. If certain risk factors are beyond their control, they must demonstrate this through a thorough root cause analysis
• Preventive measures must be adapted to the specific operational conditions and associated animal welfare risks encountered at each establishment. The licence holders must aim for continuous improvements, striving for maximum control of their processes and reducing avoidable suffering to zero or very rare incidences
• Examples of risk factors for which licence holders have direct control/responsibility
  • selecting, training, and supervising employees to ensure they have the necessary competencies and qualifications for humane stunning and bleeding of animals (SFCR 49, 75, 135)
  • preparing, keeping, maintaining and implementing appropriate measures and procedures for humane stunning and bleeding of animals (SFCR 86, 88, 89, 128, 141, 142, 143)
  • preparing, keeping, maintaining and implementing corrective action procedures, when required, for humane stunning and bleeding of animals as per their PCP for animal welfare ( SFCR 86, 88, 89, 128, 130 (4), 131 (c), 140, 141, 142, 143, 166)
  • using equipment that is suitable for humane stunning and bleeding of animals (meaning, design, construction, and maintenance) (SFCR 49, 53, 128, 135)
  • using equipment for humane stunning and bleeding of animals in a proper and humane manner (SFCR 128, 135)
  • using areas of the establishment that are suitable for humane stunning and bleeding of animals (meaning, design, construction and maintenance) (SFCR 49, 57, 58, 63, 64, 65, 128, 135)
• Refer to Annex 3 for more details on how to differentiate unavoidable from avoidable suffering, injury or death

The licence holder is responsible for ensuring compliance with the SFCR at all times. As such, under SFCR 86, 88 and 89 (1) (d), the licence holder who slaughters (stuns and bleeds) and humanely kill food animals must prepare, keep, maintain and implement a written PCP for animal welfare.

The expected outcome is for the process to be under control; this means that whenever an animal welfare deviation occurs, the licence holder must:

• rapidly identify non-compliances, take immediate and effective corrective actions, as outlined in their PCP for animal welfare
• implement effective preventive measures to avoid recurrence after a root cause analysis
• document the corrective actions taken to address the deviation identified, as well as any new preventive measures to avoid recurrence

It is not a non-compliance with the SFCR:

• if the licence holder identifies the deviation independently (without your notification) and takes immediate and effective corrective action(s)
  • Example: you notice that the employee on the slaughter line is suddenly overwhelmed, decapitating one chicken after another because the automatic neck cutter is malfunctioning. After a few seconds, the employee runs to the line's stop button and shuts it down. The supervisor arrives, talks to the employee, then adjusts the faulty bleeding equipment and carefully observes the process after restarting the line. The problem is quickly resolved

It is a non-compliance with the SFCR:

• if you identify a non-compliance and the licence holder takes immediate and effective corrective action(s) after being made aware by you or another inspector
  • Example: an employee does not notice a turkey regaining sensibility until you draw his attention to it; the employee then immediately decapitates it
• if the licence holder identifies a deviation but fails to take immediate corrective action, responds with incorrect action, or the corrective action is ineffective
  • Example: an employee does not notice a goose regaining sensibility until you draw his attention to it; the employee then either ignores it, cuts the vessels on the already cut side of the neck (inefficient action for a still partially conscious bird) or decapitates it but it takes several sawing motions due to a dull knife (incorrect action)
• if the licence holder identifies deviations and takes immediate and effective corrective actions each time, but the non-compliances are related to the same SFCR provision, and the analysis reveals the same root cause; it represents a pattern of failure. This can occur even if preventive measures have been put in place, indicating that they are ineffective

A pattern of failure:

• is associated with repeated deviations having the same root cause, indicating a trend towards a loss of process control even if the licence holder identifies them and responds appropriately in the short-term
• is unique for each case so a thorough understanding of the recurrent non-compliant situation at the establishment is required before concluding to a pattern of failure

When you observe a non-compliance with the SFCR, you must:

• verify if the licence holder has observed the deviation and has implemented immediate and effective corrective actions or interim measures
• take immediate control actions, if required
• performed the PCI-Implementation Verification (IV) task, if required
• record the non-compliance in a non-compliance record in the Digital Service Delivery Platform (DSDP)
• follow-up in accordance with the SIP

Zero-tolerance deviations are avoidable incidents having effects on the health of the animal such as harm, injury, suffering or death. Zero-tolerance does not mean zero incidence as the risk 0 doesn't exist; it rather means that when such a deviation occurs, the licence holder must:

• take effective corrective action(s) immediately
• conduct a root cause analysis
• implement preventive measures for factors under their direct control/responsibility to prevent recurrence
• document the corrective actions taken as well as the preventive measures

Zero tolerance deviations during stunning and bleeding of avian food animals, including ratites, include the following, but are not limited to:

• pre-stun shocks or electro-immobilization
• birds left on the shackles line or exposed to gas in the gas chamber during breaks
• conscious birds being injured or dead by escaping or getting caught in the CAS system during induction
• uncut birds

As mentioned in section 6.2.3.2, control and/or enforcement actions will depend on the licence holder's response.

Zero-tolerance deviations and deliberate acts of cruelty are different.

Deliberate acts of cruelty are actions where a single occurrence is non-compliant and unacceptable due to the willful nature of the act (a clear intention to harm the animal).

Determine whether an action was unintentional or truly deliberate with a clear intention to cause harm to animals.

Deliberate acts of cruelty during stunning and bleeding of avian food animal could include the following, but are not limited to:

• deliberately shackling birds by only one leg
• stunning birds and deliberately allowing them to recover
• deliberately letting conscious birds enter the scalding tank

Note: depending on the harm, history and intent factors, a non-compliance can be recorded in a non-compliance record along with an enforcement response as per the SRRP, even if the licence holder has responded to the situation.

Your role is to verify compliance with regulatory requirements. When you are not performing a PCI- IV animal welfare task but observe an animal welfare potential non-compliance, you must evaluate the situation and the need to add the appropriate PCI-IV to the inspection scope.

• Example: you notice that birds are left in the gas stunner chamber during coffee break. The supervisor tells you not to worry as the gas is stopped. You may perform the PCI-IV tasks Animal Welfare, Stunning & Bleeding and/or Animal Welfare, Facilities & Equipment to verify whether the gas is really stopped during breaks or if birds have been exposed to gas; you may also review the PCP for animal welfare to confirm what it specifies about this situation.