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| Humane Interactive Knowledge Exchange (HIKE) Scenario
03-08: Egregious Electrical Stunning |
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The Humane Methods of Livestock Slaughter Act of 1978 [7 USC 1901 - 1906] states that the handling and slaughtering of livestock are to be carried out only by humane methods. The Federal Meat Inspection Act [21 USC 601 et seq.] authorizes Federal Meat Inspectors to inspect, verify compliance, and enforce humane methods of handling and slaughtering of livestock so as to prevent needless suffering of animals. FSIS personnel verify that an establishment is meeting these requirements by performing procedure 04C02 daily and recording the results on the procedure schedule for each inspection shift. They also should record the time spent verifying human handling and slaughter activities in the Humane-handling Activities Tracking System (HATS).
The following references should be used when studying this HIKE:
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You are the IIC at a very small plant that slaughters and processes multiple species of animals.
You have already entered procedure code 04C02 on the daily PBIS schedule as an unscheduled
task. After the ante mortem inspection of roaster pigs and the humane handling verification per
9 CFR 313.2 (time is recorded in HATS Category IV), you decide to observe the establishment implementing
their electrical stunning of the roaster pigs for compliance with 9 CFR 313.30 (time is recorded
in HATS Category VIII).
When you arrive at the stunning area, you observe that this establishment uses head-only electrical
stunning. A few pigs are brought into the stun area, then the employee “corners” a moving pig
and stuns it by placing the electrodes (tongs) of the “V” shaped electric stunner
at the base of the ears in close proximity to the eyes. You determine that the stunning apparatus
was correctly applied to the animal, and that the animal was rendered unconscious. The stun operator
proceeds to stun two more pigs with the same results. At this time, the last pig stunned is shackled,
hoisted, bled, and hung on the rail; you note that this pig is being bled in less than 30 seconds
after being stunned. The first two pigs are then shackled, hoisted, bled and hung on the rail.
Since this is a very small establishment, the stunning and bleeding operations are being performed
in the same general area. You observe the bleeding pigs to verify that the pigs remain unconscious
until bleeding is complete per 9 CFR 313.30 (time is recorded in HATS Category IX). You observe
that the two pigs that were stunned first are showing the following signs of consciousness:
- Righting reflexes (back arching or raising of head)
- Vocalizing (squealing of one pig)
Establishment personnel and management are unaware of the conscious pigs, and therefore, no corrective
action is taken. Since the establishment is not taking appropriate actions to prevent inhumane
slaughter of the animal(s), you as the IIC need to establish what noncompliances have occurred,
and what actions, if any, you should take at this time.
At this point, to ensure that all provisions of the Humane Methods of Slaughter Act and the humane
handling regulations are met, you determine with which regulation the establishment has failed
to comply. You determine that noncompliance exists with respect to 9 CFR 313.30 (a) (4),
which states: “The stunned animal shall remain in a state of surgical anesthesia through
shackling, sticking and bleeding.”
Therefore, you immediately direct establishment supervision to re-stun the pigs. Then, as described
in FSIS Notice 16-08, you take a regulatory control action, based on 9 CFR 500.2 (a) (4), and
reject the stunning area utilizing a U.S. Rejected Tag. The stunning area is rejected because
9 CFR 313.50 (c) provides that, if the cause of inhumane treatment is the result of improper stunning,
then the stunning area will be rejected. Moreover, because the facts in this particular situation
constitute an egregious noncompliance, you verbally notify plant management that inspection, on
the slaughter floor, has been suspended in accordance with 9 CFR 500.3(b). You also contact the
DVMS and Deputy District Manager (DDM) to alert them of the suspension but allow animals that
had already been killed to be processed. You document the facts that served as the basis for the
egregious noncompliance on a Memorandum of Interview (MOI) and promptly provide that information
electronically to your District Office.
Electrical stunning of animals, and then allowing them to regain consciousness, are actions that
cause unnecessary pain and suffering, and any such action is an egregious act. Because of the
egregious nature of the noncompliance, you suspend the assignment of inspection personnel, and
the District Office documents this suspension of the assignment of inspectors for slaughter per
9 CFR 500.3 (b), Rules of Practice.
Establishment management offers as an immediate corrective action that it will switch from electric
stunning to a mechanical captive bolt gun. They also indicate at this time that they believe that
the stun-to-stick interval may have been too long but elect to use a captive bolt gun.
Establishment management documents these corrective measures and submits them to you and the District
Office for consideration. The DVMS and the DDMs review and discuss the proposed corrective measures
with you and the Front Line Supervisor (FLS) and decide that the actions do not sufficiently address
the cause or further planned actions. The District Office responds to plant management by stating
that not only should the electrical stunning apparatus be evaluated, but also consideration should
be given to the stun-to-stick interval if the establishment decides to return to using electrical
stunning. In addition the district office discusses the September 9, 2004 Federal Register on
“Humane Handling and Slaughter Requirements and the Merits of a Systematic Approach to Meet Such
Requirements” with plant management. The plant subsequently provides an additional response that
includes specifics on training plant personnel, validation of its stun-to-stick interval, and
a discussion that demonstrates that it is implementing and monitoring the systematic approach.
The establishment is informed by the District Office that the suspension of the assignment of
inspectors for slaughter operations will be held in abeyance in accordance with 9 CFR 500.5 (e).
The District Office discusses with you and the FLS the verification plan that will be used by
appropriate inspection program personnel during the abeyance period. You provide plant management
with a copy of the suspension held in abeyance letter, remove the US Reject tag from the stunning
area, and allow slaughter operations to resume.
Hogs are now being stunned using a captive bolt stunner, and you proceed to verify that the animals
are being rendered unconscious with a single stunning blow. You determine that the hogs are stunned
to an immediate state of unconsciousness and stay unconscious throughout the shackling, hanging,
sticking, and bleeding procedure.
Hogs are now being stunned using a captive bolt stunner, and you proceed to verify that the animals
are being rendered unconscious with a single stunning blow. You determine that the hogs are stunned
to an immediate state of unconsciousness and stay unconscious throughout the shackling, hanging,
sticking, and bleeding procedure.
Conclusion
Regulations on the humane slaughter of livestock require that stunning operators be skilled and
attentive in stunning livestock. It is plant management’s responsibility to train the employees
in the effective use of stunning devices and to monitor employee performance and that the stunning
equipment is functioning properly. The effectiveness of the establishment’s corrective actions
as implemented, both immediate and long term, will be verified by inspection program personnel
including the DVMS through a verification plan.
Note: Based on the verification of humane slaughter regulations [9 CFR 313.2, 9 CFR 313.30, and
9 CFR 313.30 (a) (4)], your time should be recorded in three different HATS categories: HATS Category
IV, HATS Category VIII, and HATS Category IX. Time recorded under HATS Category IX would include
the time spent checking for consciousness and the time spent taking the enforcement action (suspension),
paperwork issues, etc. (Click on the link to see FSIS Notice 16-08 under “Note” on page 10);
http://www.fsis.usda.gov/OPPDE/rdad/
FSISNotices/16-08.pdf.
You do not need to enter an additional 04C02 procedure because the notice of suspension serves
as the administrative record of this non-compliance.
Appendix
Questions & Answers
Q: What is the correct voltage and amperage for electric stunning?
A: The regulatory requirement is the lowest effective voltage. The regulation
9 CFR 313.30(a) (3) states that the “quality of shock shall be such as to produce
immediate insensibility”. The scientific research has shown that a minimum of 1.25 amps at 250
to 300 volts must pass through the hog’s brain to induce instantaneous unconsciousness. The amperage
requirement also depends upon the size and condition of the animal, e.g.; higher amperage and
voltage is required when stunning large sows.
Q: How long should the electrodes be held on the head (current flow)?
A: 9 CFR 313.30(a) (1) states” the current will
accomplish the desired result quickly and effectively, with a minimum of excitement and discomfort.”
The B&D stunner has a setting from 1-15 seconds; three second is the recommended time.
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Access the HIKE Scenario home page and review previously posted HIKE's from:
http://www.fsis.usda.gov/FSIS_Employees/HIKE/index.asp
HIKE is a service of the FSIS Policy Development Division and DVMS to foster awareness and regulatory
compliance for welfare of livestock. It is important that everyone understands that HIKE and the
information herein is intended for the use of all field employees and to be shared with plant
management.
If questions pertaining to any of the scenarios, or answers provided on HIKE are not resolved
through discussions within the work-group or with the supervisor, they should be submitted to
Hike@fsis.usda.gov.
Last Modified:
June 26, 2008
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