Full Metal Jacket. The Good, the Bad, and the Ugly of Humane Handling
By?STEVE?SAYER
(The views and opinions expressed in this blog are strictly those of the author.)
SOME CATTLE TERMINOLOGY YOU SHOULD KNOW FOR THIS BLOG
If you’re not up-to-speed on the difference between bulls and steers, or cows and heifers, here’s some basic cattle terminology.
Bovine: An animal in the cattle group, which includes bison (NOT Buffalo!).
That’s it - except - for a small population of bison that’s identified as European bison (Bison bonasus) that live in isolated areas within the great country of Poland –? of all places.
American bison today are roughly 3/8 bison and 5/8 domestic cattle. Bison meat has a deeper red color than beef before cooking because there’s no marbling.
However - many others and I love those Bison burgers.
Cow: A cow is a female bovine that has had at the very least one (1) calf. Cows of course have udders.
Using everyday lingo - the cows are the seemingly happy “Moms” one sees on those glass milk bottles / cartons at your friendly neighborhood dairy.
Heifer: A heifer is a young female animal that has not had her first calf - yet.
Once a heifer has a calf, she automatically becomes - a cow.
Bull: A mature male bovine that is fertile and is used for breeding.
Aka - Stud.
Bulls exhibit more aggressive behavior and dominant overall - compared to steers.
The bulls are the 'Bull(s) on the Run' - Dads.
Steer: A steer is a male hoofed mammal that naturally belongs to the bovine family and has been castrated and is incapable of reproducing.
Castration is most commonly done before sexual maturity when the bull is but a young calf.?
Once steers (and sometimes heifers) reach the proper weight and fat cover, they can be processed.
On average these bovine mammals (steers) will weigh approximately 1200 -1300 pounds, though this weight will vary - anywhere from 1000 - 1500 pounds and rarely more or less.
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Four (4) Common Terms / References Cited by FSIS / USDA When Violations to the Humane Handling Act and FSIS / USDA Directive 6900.2 Revision 3 Occurs;
1.Notice of Intended Enforcement (NOIE) - A written notification that is made in accordance with 9 CFR 500.3(b) (Rules of Practice), based on an establishments failure to meet federal regulatory requirements with regards to livestock humane harvesting (slaughter) at an establishment.
A NOIE provides the 'opportunity' for an establishment to take immediate corrective action and future preventative actions without suspending inspection.
If appropriate action is not taken within three (3) business days, then a NOIE can turn into a suspension.
In 2020, suspensions accounted for 59.60% (59 of 99) enforcement actions and NOIEs accounted for 18.18% (18 of 99) enforcement actions. Additionally, 22.22% (22 of 99) of enforcement actions were classified as a reinstatement of suspension.
Follow-up actions for enforcement actions also include two primary options: abeyance or deferral.
Abeyances may be stated in one of three (3) ways – suspension held in abeyance, NOIE held in abeyance, or reinstatement of suspension held in abeyance – and ultimately - when the enforcement action has been lifted, the establishment may operate under agreed upon conditions, and that inspection may resume.
Deferrals can be a follow-up action to an NOIE, and a letter of deferral is issued from the applicable USDA district office when an establishment has proposed adequate corrective and preventative actions.
2. Notice of Suspension (NOS) - Withholding of the marks of inspection and the suspension of the assignment of inspectors at the Harvesting (Slaughter) establishment in accordance with 21 U.S.C. 603 and the previously mentioned Title 9 Code of Federal Regulations (CFR) Part 500.3 (b).?
3.Noncompliance record(s) (NRs) - FSIS / USDA inspection program personnel perform thousands of inspection tasks and procedures in meat and poultry establishments each day to determine whether or not these establishments are in compliance with germane regulatory requirements.
A?Noncompliance Report (NR)?is to be completed whenever inspection program personnel determines that an establishment has failed to meet one or more regulatory requirements,?explaining the nature of the regulatory action. They shall notify plant managers of problems (opportunities) via a written?Noncompliance Report (NR).?
When inspection program personnel document a noncompliance, the establishment must comply with regulatory requirements - or fight it (triple - check those relevant regulations 417.2(c)(14) ... under box 6 - as cited below).?
4. USDA / FSIS Directive 6900.2 Humane Handling and Slaughter of Livestock - Revision 3? - is used for additional references by USDA / FSIS when applicable.
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Receiving Live Cattle - Stunning Operation - and the Bleeding Operation is where many Humane Handling "opportunities" materializes.
Once cattle trailers enters onto the establishments property and livestock are herded out - those live cattle become the property and responsibility of the USDA beef harvesting establishment that has bought them.
Having fresh *feed, cow (salt) licks, and potable water in troughs - with enough space to lay down are a priority / required - and - a good resting / quiet time from all of the dramatics of bumpy / loud double-decked 18-wheel trailer rides - that brings stress to the bovines on the wide open interstate highways - despite the season at hand.
*USDA requires that feed is made available if the livestock are held longer in the corrals than 24 hours.
*However, Agency policy regulation is that feed must be of appropriate for the age and species of animal being fed. For example, feeding hay to bob veal calves held more than 24 hours - would not meet USDA regulatory requirement for access to feed.
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The Knock Box (stunning operation)?is?the Hot Spot where Harvesting Establishment’s get slapped by the USDA with the most cited humane handling non-compliance records (NR’s): percentage wise.
It’s Ground Zero.
This is where USDA, video cameras, consultants, and auditors all stream-in union to: like bees drawn to honey.
This is when prudent harvesting plants have experienced employees who have the cool, calm and collective abilities - and demeanor to make split-second intuitive decisions.
The Knockers ... always a special and unique person regardless of gender.
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This second blog represents a continuation of a planned series on the humane handling of livestock that involves USDA / FSIS establishments whose operations were shut down via a (Notice of Suspension (NOS)) - or - issued a Notice of Suspension (NOS) - for Humane Handling violations that are posted on the USDA / FSIS website.
For those of you that missed the first blog of this series, you can view it on my LinkedIn page - dated Jan. 03, 2023 as pictured below.
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THE BAD AND UGLY...
2nd Review Among?2022 / 2023 Harvesting (Slaughter) Establishments regarding Suspensions / Notice of Enforcements (NOIE)
Followed by Suspension - Held in Abeyance
USDA / FSIS' Verbatim Findings / Basis for Action:
"On Tuesday, January 23, 2023, the FSIS Consumer Safety Inspector (CSI) documented in a Noncompliance Record (NR) the following event at USDA Est. M838:
While observing stunning operations at approximately 1320, the CSI observed establishment personnel load a steer into the stunning area. An establishment employee utilized a .22 caliber long rifle to apply a stun attempt to the steer; the steer remained standing after the stun attempt.
The establishment employee then applied a second stun attempt with the same firearm, after which the steer continued to stand and began tossing its head side to side and rearing back in the stunning area.
The establishment employee then utilized a .22 magnum firearm to apply a third stun attempt. The steer remained standing and the CSI noted bleeding from the steer’s nose as well as the steer vocalizing loudly.
The establishment employee applied a fourth stun attempt with the .22 magnum; the steer remained standing and was vocalizing, but not tossing its head.
Another establishment employee reloaded the .22 caliber long rifle and applied a fifth stun attempt to the steer; this resulted in the animal being rendered insensible. The steer remained insensible through the subsequent bleeding process.
On post-mortem examination, the CSI observed a cluster of four penetrating holes in the skull in a tight cluster just rostral of the cranial vault and a fifth penetrating hole in the skull approximately 11?2” above the cluster that penetrated the cranial vault.
The establishment does not operate under a robust systematic approach to humane handling. A review of PHIS did not identify any previous noncompliance’s with a similar root cause.”
Summary (By USDA / FSIS)
"The decision to suspend the assignment of inspectors at your establishment is based on this noncompliance with 9 CFR 313.16(a)(l) " { - which is cited directly below }.
{continued ... } Summary (By USDA / FSIS)
"This is an inhumane noncompliance, whereby a bovine was unsuccessfully stunned multiple times with ineffective corrective actions.
The suspension of the assignment of inspectors will remain in effect until such time as you provide the Denver District Office adequate written corrective actions and preventative measures to ensure that livestock at your establishment are handled and slaughtered humanely, and in accordance with the FMIA, the HMSA, and 9 CFR 313 regulations."
{continued ... } Summary (By USDA / FSIS)
"These should include:
KW Properties LLC, Est. M838 Notice of Suspension planning to use.
??Any monitoring procedures, including any documentation records.
In accordance with Title 9 CFR 500.5(a)(5), you may appeal this action by contacting:
Paul Wolseley
Executive Associate for Regulatory Operations Office of Field Operations
Food Safety and Inspection Service United States Department of Agriculture
In accordance with 9 CFR Part 500.5 (d), you may request a hearing concerning this action by contacting:
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As mentioned, there has been eight (8) USDA / FSIS inspected establishment's nationwide that have been suspended or placed on NOIE for the calendar year of 2023 involving a melting pot of humane handling scenarios.
Of those eight (8) USDA establishments cited by USDA thus far in 2023 - five (5) of the (8) eight humane handling violations involved - - - the knocking stage. Six (6) of the eight (8) USDA harvesting establishments that were suspended in 2023 - did not have a robust humane handling program in place.
The remaining two (2) establishments were placed on NOIE because they had in place a - - - robust humane handling program.
SHORT LOOK AT PISTOLS
Handguns / pistols are short barreled firearms. For the purposes of euthanasia, accuracy is improved when handguns are limited to close-range shooting within one meter / 3.3 feet or less of the intended target.
However, hollow point bullets are designed to expand and fragment on impact with their targets, which reduces depth of penetration.
The 0.22 caliber handgun is not recommended for routine euthanasia of cattle regardless of the type of bullet used, because of the inability to consistently achieve desirable muzzle energies with standard commercial loads.
Muzzle velocity and energy of a bullet are generally higher when fired from a rifle.
A longer barrel allows the propellant - gunpowder - to burn more completely which maximizes velocity of the bullet as it leaves the muzzle. The shorter barrel of a handgun results in reduced muzzle velocity since much of the pressure propelling the bullet through the barrel is dissipated into the air prior to complete burning of the gunpowder.
Ultimately, the damage potential of a firearm and bullet / shotshell combination is determined by multiple factors including age, thickness of the skin and skull as well as characteristics of the projectile.
SHORT LOOK AT RIFLES
Rifles are long-barreled firearms that are usually fired from the shoulder.
Unlike the barrel of a shotgun, which has a smooth bore for shot shells, the bore of a rifle barrel contains a series of helical grooves (called rifling - as pictured below) - that causes the bullet to spin as it travels through the barrel.
General recommendations on rifle selection for use in euthanasia of cattle suggest use of a 0.22 magnum, or higher caliber.
Shotguns loaded with buckshot / birdshot are appropriate for euthanasia of cattle when used from a distance of 1 meter / 3.3 yards. Although all shotguns are lethal at close range, the preferred gauges for euthanasia of mature cattle are 20, 16 or 12.
The lead shot (small pellets) BBs in birdshot exit the barrel as compact bolus - or mass with ballistic characteristics on impact with the skull at close range that are similar to those of a solid lead bullet. Penetration of the skull is assured with massive destruction of brain tissue from the dispersion of birdshot into the brain that results in immediate loss of consciousness and rapid death.
A shotgun loaded with birdshot is less effective when shooting from a distance because the BBs in a shotshell will begin to scatter once they exit the barrel which reduces muzzle energy as distance from the barrel increases and the shot pattern (BBs spread out) expands.
Shotgun slugs (pictured below) are also very lethal, in fact may be excessive firepower for use in close-range situations. Slugs are the preferred ammunition for circumstances that may require shooting from a distance.
A possible advantage of euthanasia using a shotgun is that within close range (1 meter / 3.3 yards) when properly directed, birdshot has sufficient energy to penetrate the skull, but is less likely to exit the skull.
In the case of a free bullet from a high caliber firearm or a shotgun slug there is always the possibility of the bullet or slug exiting the skull creating a serious human health risk for the operator / by-standers.
For safety reasons it is important that the muzzle of a shotgun (or any other firearm) never be held directly against the animal’s head.
Discharge of the firearm results in the development of enormous pressure within the barrel that can result in explosion of the barrel and potential for injury of the operator and by-standers if the muzzle end is obstructed or blocked.
It is important that anytime firearms that are used, whether shooting from close range or a distance, the shooter is able to clearly visualize a safe backstop for bullets that miss or pass through their targets.
SUMMARY OF THE 'GOOD'
FSIS only?recommends?that federally inspected harvesting establishments voluntarily employ / develop a?'robust systematic approach'?that encompasses a detailed written program with associated record-keeping, continuous improvements, and training records.
The contents of 2020s?FSIS Directive 6900.2 Humane Handling and Slaughter of Livestock - Revision 3?- seemingly?entices harvesting establishments to go with a?robust systematic approach?for a number of pragmatic reasoning(s).
One reason being that in the event a humane handling or harvesting noncompliance results with egregious inhumane treatment, the USDA CSI can recommend (if certain pre-determined regulatory conditions exist and are met) an issuance of a Notice of Intended Enforcement (NOIE) rather than a Notice of Suspension (NOS).
Such an option (NOIE) - can potentially save establishments from expensive downtime and negative publicity; including fodder for the many rogue animal right groups.
A methodically written?robust systematic approach?has shown to both clarify and verify (if written and executed correctly) an establishment’s regulatory humane handling efforts while contemporaneously creating important and vital historical data for any needed future (regulatory, legality and customer driven 3rd?party audits) references.
Others and I know that FSIS’ voluntary?robust systematic approach?is NOT a "Silver Bullet" for all of the potential humane handling and harvesting mishaps that can happen, just as HACCP systems have not precluded adulterated products from entering into commerce.
However, others and I do know all too well that a?robust systematic approach?provides the best - ways and means - of maintaining, correcting, directing and promoting continuous improvements to the myriad requirements that’s enforced by FSIS in 2023.
International humane handling specialist / consultant Erika Voogd, wrote an?excellent technical article ?for Meatingplace.com centering on FSIS’ voluntary?robust systematic approach.?
With some exceptions, can and will the reasons why - ( expense$, time, low daily harvesting volume, resources, documented corral meetings, maintenance / upkeep of written programs / record-keeping, on-going training, etc. ) - those establishments that have elected not to have a?robust systematic approach?in place remain a sustainable and a smart business choice?
Can such establishments absorb the $teep cost$ associated with a NOS?
Is there a clock ticking some ... where?
Hello!
Finally, it is impossible and not fair to 'wildly speculate' respected USDA establishment M838 in this example - based on the limited information offered within the USDA NOS.
However - a robust humane handling program could / might have resulted with a NOIE rather than NOS being cited and establishment M838 could / may have finished harvesting cattle that day when the egregious treatment violations were cited.
More Good ...
It was mentioned within the USDA NOS letter in our example - that this establishment M838 -
The Bad - Turned good ...
The USDA NOS did not mention -
So - the next time you order your choice graded Angus filet mignon topped with sautéed mushrooms with - say - a hot baked potato that's fully equipped with butter, sour cream and plenty of chopped chives - at your favorite steakhouse - you shall have a better idea and appreciation of the many trials and tribulations of what it really takes to deliver USDA stamped and approved sizzling and enticing steak that is laid out before your friends and family to devour, enjoy, while offering thanks to above.
NEXT LINKEDIN HUMANE HANDLING BLOG #3 -
"A HOG GETS LOOSE ON THE HARVESTING FLOOR - - - AFTER A STUN GUN APPLICATION TO THE HEAD IS DISCOVERED DURING AN EMPLOYEE BREAK TIME - BY A ROAMING AND CLEVER USDA INSPECTOR ... ."
INCLUDED WITHIN BLOG 3, I'LL TOUCH ON THE PSYCHOLOGICAL RAMIFICATIONS OF THE KNOCKERS WHILE EUTHANIZING FEED ANIMALS AS A LIVING.
I'VE MET AND WORKED WITH (AS A CONSULTANT / AUDITOR) MY SHARE OF KNOCKERS EAST/WEST OF THE GREAT MISSISSIPPI RIVER - WHO PLAY A HUGE/VITAL ROLE REGARDING HARVESTING LINE SPEED$ / FLOW - BOTH DOWNSTREAM IN ACTUAL HARVESTING - AND - BACK UPSTREAM TO THE "FINAL GREEN LINE," AS THE CORRALS AND LIVESTOCK ARE GETTING PREPARED IN THE BACKGROUND - WHILE CONTEMPORANEOUSLY - EVERYONE IS LOOKING OVER HER/HIS SHOULDERS (KNOCKERS) - INCLUDING 24/7/365 CAMERAS - AND - FEDERAL INSPECTORS.
As she/he (knocker) sidles up slowly/quietly - nearly motionless from behind the bovines head and carefully performs her/his on-target knockout shot on the imaginary X with a stun gun in the kill box. Thank goodness for training and on-going training for the knockers.
Job rotations concerning knocking is a must - based on the hundreds of livestock that must make that first shot effective every harvesting day - often six (6) days a week.
HARVESTING'S TRUE HOT SPOT IS THE KILL BOX.
WORKING WITH LIVE ANIMALS IS NOT NEARLY AS EASY AS IT MAY SEEM.
IT NEVER IS.
CREDIT TOO, THE HARD WORKING FARMERS AT THE GET-GO WHO RAISE CATTLE FOR A LIVING.
IN MORE WAYS THAN JUST ONE.
XTRA XTRA XTRA!
COMPLETE TRANSPARENCY REGARDING THE LEGAL / MORALE EUTHANIZING OF GOATS, BISON, HOGS, CATTLE, LAMB - EVEN ALLIGATOR'S - IS A MUST.
TRADE SECRET?
PLEASE.
GOT VIDEO'S?
SHARE and USE THEM.
USE VIDEOS IN YOUR TRAINING FROM UNLOADING, CORRALLING, KNOCKING AND BLEEDING.
IT'S 2023.
SINCE WHEN IS HUMANE HANDLING, SCIENCE-BASED SAFETY INTERVENTIONS OF FOODS / BEVERAGES, OR OSHA - TRADE SECRETS?
COMPLETE TRANSPARENCY IS THE LAST THING PETA AND HSUS WOULD WANT TO SEE HAPPEN.
WHY?
BECAUSE TRANSPARENCY REMOVES ALL OF THE GUESSING / SUSPENSIONS / EXAGGERATING / AND PT BARNUM'S STORIES BEHIND THE NEBULOUS VEIL - ONCE AND FOR ALL.
WAKE UP.
WHAT IS THERE TO HIDE - - -?
WORD OF THE DAY
transparency
Being transparent is not a weakness but actually strength at the core level.?
Sharing ideas and information shall allow companies to get a new perspective, new opinions and better insight.
Problems shall be solved faster and more efficiently if - one learns to be open and honest.
Next Trend Realty LLC./wwwHar.com/Chester-Swanson/agent_cbswan
1 年Thanks for Sharing.