Final report of an audit conducted in the United States of America to evaluate the food safety systems governing the production of meat and poultry products intended for export to Canada – January 23^rd to February 10^th, 2017
3 Ante-mortem, humane handling and animal welfare controls

3.1 Ante-mortem inspection, humane handling and animal welfare (poultry)

3.1.1 Ante-mortem

It was observed that the definition of lot is determined by the operator not FSIS. In the establishments visited, the definition of lot varied from being poultry per grower to poultry processed in 1 shift. Therefore, a lot could include more than one truck load, or farm(s). The auditors observed the IIC or the CSI performing ante-mortem a few times a day within the framework of the task poultry GCP verification task. As described in 9 CFR 381.70, an ante mortem inspection of poultry shall be made of poultry on the day of slaughter in any official establishment. Although the FSIS training module on ante-mortem inspection of poultry requires the trainee to perform ante-mortem inspection on a lot basis, US regulations seem to be flexible and require ante-mortem to be performed on the day of slaughter "where and to the extent considered necessary by the administrator" as described in 9 CFR 381.70.

As per the meat inspection regulations "ante-mortem examination" means, in respect of a food animal that is slaughtered at a registered establishment, the examination of the animal, or the examination of a sample from a shipment of animals that includes the food animal, and the examination of the animal information document in respect of the animal or the shipment of animals, by the operator under the supervision of an official veterinarian. Advanced copies of flock sheets for each scheduled lot are reviewed by the operator. The flock sheets contain information on the health of the flock, medication withdrawal, extra-label usage of medications or food additives, and percentage of mortality and disease. The verification of flock sheet by the FSIS is not a requirement as per 9 CFR part 381 and FSIS directive 6100.3 ante mortem and post mortem poultry inspection.

3.1.2 Dead on arrival (DOA)

The auditors observed the FSIS inspection personnel performing the poultry good commercial practices inspection task which included the verification of the operator's animal welfare program. The FSIS GCP verification task did not include the direct observation of the truck and the crates maintenance, however the operator poultry GCP program contains clear instructions, monitoring and training procedures about humane handling, crates, and extreme climate temperatures to prevent DOAs. This was consistent finding across the three establishments audited. The operator provided the total number of DOA to FSIS on the following day to add the DOA number to the condemnation certificate. The DOAs were identified, counted, and weighed, and the number was reported on FSIS form 9061-2, poultry condemnation certificate.

If a consistently large amount of DOA was observed by the FSIS, the non-compliance was documented in a weekly MOI. If the non-compliance is egregious (any act or conditions that results in severe harm to animals), an NR is issued and the operator has to put in place immediate correctives actions. The repetitive linked NR can be escalated to the FLS and the D.O. for enforcement actions. An LOC can be issued by the D.O. when GCP and DOA in poultry establishment are found to be non-compliant. If the situation stays non-compliant without any correctives actions, the grant (licence to operate) of the establishment can be revoked. No such situation was observed in poultry establishments audited.

The auditors were informed during the interview that the humane handling at the farm and during the transport is under the jurisdiction of the animal and plant health inspection services (APHIS).

3.1.3 Stunning

The auditors were informed that there is no regulation requiring that poultry be stunned prior to bleeding in US establishments. However, CFR 381.65(b) states that poultry shall be slaughtered in accordance with good commercial practices in a manner that will result in thorough bleeding of the carcasses and assure that breathing has stopped prior to scalding. Regulatory actions for noncompliance with 9 CFR 381.65(b) include noncompliance records and potentially stopping the poultry line with a regulatory control action by inspection personnel.

The audit team observed the verification of the effectiveness of the stunning as part of the operator animal welfare program. In one of the slaughterhouse visited, halal slaughter was preceded by electrical stunning. The operator GCP program included training, clear instructions regarding when a corrective action has to be implemented and monitoring records with a prescribed frequency. The FSIS inspection personnel verified the effectiveness of stunning in the poultry GCP task. As a part of this task, the inspection personnel must ensure that stunning equipment is functioning properly.

In the case of non-compliance related to stunning, the FSIS stops the line, adds the non-compliance to MOI, but an NR is not issued because it is not mandatory as per the regulations. If the establishment is mistreating the birds, but the birds are still be fully bled and are not breathing when they enter the scalder, the PHV, IIC, or designee is to discuss the mistreatment with the establishment management, document the discussion and any planned actions on the part of the establishment in a memorandum of interview (MOI); and provide copies of the MOI to the establishment, the DVMS, and the inspection file. The DVMS is to review the MOI and determine whether the establishment's mistreatment requires notification of the appropriate state officials. Verification of appropriate stunning is not included in the U.S. regulations; however, as per 9 CFR 381.65(b), FSIS must verify that poultry has stopped breathing prior to scalding. The auditors were informed by FSIS inspection personnel that if the stunning is not proper, there would be more cadavers (As per FSIS directive 6100.3, cadavers are poultry that die from causes other than slaughter or are not physiologically dead because of ineffective slaughter before they enter the scald vat and drown) observed at the evisceration floor, which would be an indicator to go to the ante-mortem and look to see if the birds are entering the scalder tank alive, in which case, an NR would be issued.

3.1.4 Bruising

At 3 poultry establishments audited, the operator implemented animal welfare program which contains monitoring of bruising (legs-wings) with maximum limits. These GCP programs are verified by the FSIS via their poultry GCP verification task. If there is minor non-compliance not rising to the level of non-compliance, it is discussed with the operator in weekly meeting and documented in the MOI. In observed repeated minor non-compliances or a major non-compliance rise to the level of a regulatory non-compliance, it must be documented in a NR. The FSIS verification of bruising is carried out in accordance with FSIS directive 6100.3 and 9 CFR 381.89.

3.2 Ante-mortem inspection, humane handling and animal welfare (beef and pork)

The audit demonstrated that the FSIS verification of the animal welfare at the ante-mortem is completed via the humane activities tracking system (HATS). The HATS include 9 categories of daily tasks listed in the PHIS task calendar. These tasks are performed by FSIS inspector with appropriate training. The task results are recorded in the PHIS. The operator has to implement the humane handling animal welfare program as per the FSIS Compliance Guide for systemic approach to the humane handling of livestock. The operator can choose between the systemic approach and the robust systemic approach. In contrast to systemic approach, the robust systemic approach includes additional features such as written procedures, written reports and training program. These documents are available to FSIS for review. All beef and pork slaughter plants audited had a robust systemic approach program. The HATS activity doesn't include verification of truck condition or investigation conducted by FSIS in case of DOAs. The truck condition maintenance is part of the operator systemic approach because once a vehicle has entered an official slaughter establishment's premises, it is considered to be part of that establishment's premises as reported in the FSIS directive 6900.1.

The cadavers of swine that die at the barn or during transport (DOAs) are not required to be seen by FSIS. The operator can dispose of obvious condemnable conditions (for example, moribund) at ante-mortem without the FSIS' presence and oversight, whereas in beef, the cadaver is verified by FSIS veterinarian. According to the APHIS bovine spongiform encephalopathy (BSE) plan, cattle 30 months or older condemned at ante-mortem inspection, and cattle of any age condemned for nervous signs or rabies are sampled by FSIS employee or designated off-site sample collection facilities.

All establishments have a US detain pen where the ante-mortem inspection of suspect animals was performed by a veterinarian and observations were recorded in the ante-mortem form. Identification of suspect animals was completed either by affixing a metallic tag in the ear (before the stunning) or in the tongue (after stunning). These tags with a unique number were kept locked as accountable items by the FSIS in the ante-mortem area. No loss of identification of suspect animal between the ante-mortem and the post-mortem station was observed during the audit.

The audit team observed that non-ambulatory and crippled animals were segregated and moved in U.S. suspect pen or in the slow pig's pen (hogs with stress syndrome). As per 9 CFR 313.2, dragging is not permitted. In the 3 establishments audited, non-ambulatory hogs (hogs not willing or able to walk) were physically moved without being stunned first with a bobcat and loaders to a pre-slaughter assembly area and kept there until moved again and stunned, bled and shackled. The equipment used for this purpose was a bobcat, some with retractable floor or a cage. The use of a bobcat to move the hogs with stress syndrome were observed to have contributed to an increase of distinct signs of stress such as laboured breathing, patching skin discoloration, generalized trembling/muscle tremors, and vocalisation. As per MIR 62(1), No food animal shall be handled in a manner that subjects the animal to avoidable distress or avoidable pain 

In the beef slaughter establishments, non-ambulatory cattle were stunned on site without being moved, which was consistent with 9 CFR 313.2. The beef slaughterhouse with halal ritual slaughter stunned the animals before the slaughter. The FSIS verification of effectiveness of stunning was done via the HATS activities on a daily basis and was observed during the audit.