|You are the IIC at a large cull cow slaughter and processing establishment. The establishment approaches you and inquires about the possibility of routinely double stunning (i.e., using two shots or blows to stun) cattle as part of its slaughter process. The establishment states that it wants to ensure that animals will not regain consciousness after the initial stun, and that there is a minimum of excitement and discomfort. The plant refers to the second stun as a "security knock."
|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:
The establishment's systematic approach is documented in a plan that it has developed. One aspect of the plan is for establishment management to randomly select 4 times during each day to observe 5 animals being stunned and record the stunning results.
(The establishment could choose other options for the frequency and number of animals selected for verification procedures.) In addition, the establishment has experienced and well-trained captive-bolt stunner operators and it documents its ongoing training practices.
You decide to consider this request and contact the District Veterinary Medical Specialist (DVMS) to discuss the double stunning procedure in the context of the establishments plan. The DVMS advises you that the Humane Methods of Livestock Slaughter Act (7 USC 1901-1906) and the Agencys humane handling regulations (9 CFR 313.15) require that livestock be rendered unconscious by a single stunning blow, but that there is no regulation that prohibits an establishment from delivering a second stunning blow to an animal that was effectively rendered unconscious due the first stunning blow.
Therefore, a double knock procedure can meet regulatory requirements so long as the establishment effectively implements its program. Thus, the establishment needs to ensure that its personnel will verify that the double stunning of cattle is humane.
The establishment decides to implement the following plan:
- All operators of stunning equipment will be trained on how to properly use the equipment to effectively stun the animals and will need to demonstrate competency in placing and firing the captive-bolt stunner.
- The operators will need to demonstrate that they are able to recognize when an animal has not been adequately stunned, and that they must immediately respond by re-stunning with a single additional blow to render the animal unconscious.
- The establishment will maintain its existing verification checks to ensure immediate unconsciousness from the first stun.
- The establishments existing maintenance program for the captive-bolt stunners will remain in effect, but be routinely assessed for continued effectiveness.
You also inform the establishment that you will continue to verify that the establishment is meeting the intent of the Acts and regulatory requirements. Your verification of 9 CFR 313.15(a)(1) needs to consider whether the establishment employing a double knock (stun) procedure has a basis for knowing that the first knock rendered the animal immediately unconscious. The establishment's means of ensuring that the knock is effective may include, but are not limited to, verification of the effectiveness of its training of its employees who perform the knock, equipment maintenance schedules and equipment modifications, and establishment audits. The establishment could also render the animals unconscious with the initial stun in order for FSIS inspection to verify, on a random basis, that the establishment is consistently rendering animals unconscious with a single stunning blow.
The use of these types of procedures would be considered by FSIS to be consistent with a systematic approach to humane handling and slaughter. Because the establishment is using a systematic approach, you verify execution of the establishment's procedures by direct observation of the establishments routine stunning methods and its effectiveness.
If your observation raises a significant question about the effectiveness of the first knock, however, you may request that the establishment deliver one stunning blow to the animal in order to evaluate the results of the stun, but this request should rarely, if ever, be necessary.
- This HIKE scenario only addresses the routine stunning of cattle using a double stun technique. Other species (e.g., swine) may effectively be stunned using this technique as well. Also, establishments may choose to routinely double-stun certain slaughter classes (e.g., cows and bulls) and not others (e.g., fat cattle). If an establishment does use this methodology, FSIS will expect the establishments training and documentation to describe which animals are routinely double-stunned and which are not.
- This HIKE scenario does not address stunning failure in establishments that routinely use a single-stun method. Another HIKE will address stunning failure in establishments that have ineffective initial stuns and must re-stun to render the animal unconscious.