Wham! Bam! Slam #$! You're Closed!

1st WORD OF THE DAY FOR 2023

EGREGIOUS

EXAMPLE

The quickest / swiftest / easiest way for a USDA / FSIS harvesting (slaughter) establishment to be shut down by regulatory action(s) in 2023 remains indelibly - the egregious treatment of feed animals and birds under USDA inspection.

Hands down.

And - rightly so.

USDA / FSIS Inspection for feed animals and birds begins at the plant level - certainly not upstream at the dairies and farms - - - just yet ... .

Sixty-six (66) USDA / FSIS establishments were suspended from December 22, 2021 to December 19, 2022 by FSIS / USDA for violating the broad and expansive (The) Humane Handling Act of 1978.

Some of those USDA inspected establishments were suspended multiple times by FSIS / USDA during 2022 according to FSIS / USDA website for all to bear witness and hopefully / ultimately - learn - from.

Selected USDA establishments who choose to perform religious slaughtering - are protected in part, by the mighty 1st Amendment of the US constitution - specifically - Freedom of Religion - unless they violate the Humane Handling Act of 1978 like other selected harvesting establishments have in the past.

Of which, after some rather harrowing experiences in the capacity of a consultant / auditor - I no longer consult nor perform internal audits involving religious slaughter.

No thanks / No gracias / Nej tak.

Religious slaughter to selected others and myself is "In-Humane In-Action in 2023"

- but ya' gotta amend the 1st amendment of the United States constitution that was ratified back in 1879 AD to get it done -

of which selected and prudent EU countries who have already outlawed religious slaughter for the exact reason I just hyped / typed directly above in the 20th and 21st centuries.

This blog is exercising my inherent 1st Amendment rights as a tax paying, law abiding, and natural born citizen (freedom of speech, petition, and press) - just like legal religious slaughtering lay claim every harvesting day - though I do not generate near the money they do.

Westland / Hallmark Meat Company - a former vertically integrated USDA beef harvesting establishment back in '08 / '09 was closed with serious regulatory charges (9 CFR Parts 416s and 417s) besides 9 CFR 313 violations - though ultimately a Class 2 recall decision by FSIS mind you - was issued following video's evincing dragging / transporting / poking with battery operated prods - disabled cows with extended rusty steel forks - fully equipped with 1/2-inch thick links making long rusty chains tied via a propane powered forklift within the confines of a - not OK corral - that was ultimately broadcasted world-wide by CNN, Fox News and the BBC.

Within several days of the videos released by The Washington Post, two (2) former employees of that former USDA plant had their Bevis and Butt-Head Butts thrown in the 'ol Riverside County Jail for their flagrant mis-treatment of disabled bovines - resulting with the harvesting plant having to forfeit their Grant of Inspection.

Sick.

Humane handling is serious business here in the US of A.

The Hallmark / Westland Meat Company's red meat USA record recall of 143 Million pounds of fresh / frozen meat, went back two (2) full orbits around our star - where some of the 143 Million pounds recalled / recovered beef was thrown down to - Hades delight - into an active volcano in the state Hawaii - which such actions are now outlawed.

BOTTOM LINE: One must never - ever pull on the Feds regulatory cape like you would never spit against an off shore ocean wind - and - you don't ever mistreat feed animals and birds.

Period.

For both regulatory - and - moral reasons.

1ST Case Study among?2022s 66 Harvesting plants regarding Suspensions / Humane Handling.

Followed by Suspension Held in Abeyance

Finding / Basis for Action

On Tuesday, December 7, 2022, the FSIS Consumer Safety Inspector (CSI) documented in a Noncompliance Record (NR) the following event at (USDA) Est. M (Meat) 21700:

"At approximately 10:00 am while IPP was observing stunning of a steer.

An establishment employee attempted to stun the animal with a 22 mag Ruger rifle, while the animal was loaded into a small stock trailer standing facing the back end of the trailer. The establishment stun operator aimed the firearm at the steer’s head to apply the first stun attempt.

The animal remained standing and did not vocalize.

The stun operator immediately aimed the firearm again and delivered a second ineffective stun attempt. The steer continued to remain standing and moving around inside the trailer.

The stun operator aimed the firearm again and applied a third ineffective stun attempt. The steer remained standing and moved around in circles, then stopped, and immediately a fourth effective stun attempt was applied, and the animal dropped down to the trailer floor. IPP verified the animal was not displaying any signs of consciousness or sensibility.

IPP verbally informed the establishment butcher that a humane handling non-compliance record would be issued and US Reject tag #B39950167 was applied to the trailer’s door. IPP notified her supervisor and then (USDA) Denver District office was contacted through supervisory channels.

Upon review of the dressed head four penetrating stun holes were observed.

This establishment has not implemented a Robust Systematic Approach to Humane Handling.”?

Summary

The decision to suspend the assignment of inspectors at your establishment is based on this noncompliance with 9 CFR 313.16(a)(l) and 313.16(b)(1)(iii).

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 enforcement letter from FSIS / USDA}

These should include:

??A written description of the incident.

??The root cause of the incident

??Your immediate corrective actions.

??Your specific corrective actions to prevent reoccurrence of the noncompliance.

??Any training or retraining of employees you plan to provide, including materials you’re planning to use.

2

?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

1400 Independence Avenue, SW

Room 1329, South Building

Washington, D.C. 20250

Tel: 202-708-9506

[email protected]

PRECLUDING SUCH ACTIONS

What could have / may have precluded this suspension was a written "Systematic Robust Humane Handling Program" that is not required of a USDA harvesting establishment to have in place - unless - a harvesting establishment is an approved supplier of the remarkable National School Lunch Program (NSLP) - for frozen / fresh beef.

It is mandatory with the NSLP - that a fully equipped with all the bells and whistles humane handling program based on Professional Animal Auditor Certification Organization (PACCO) recommended standards - with PAACO trained / accredited AMS / USDA Inspectors performing them tough audits.

You fail a NSLP humane handling audit?

You're outta here - very similar to existing USDA / FSIS criterions to get cited, suspended and reinstated - after corrective actions and preventive measures are emailed to Washington DC and approved in writing.

SOLUTION(S) TO THIS NON-COMPLIANCE

Aaah, yes.

Easier than it might seem.

Do what selected pre-approved USDA harvesting plants already do - follow the Pied Pipers straight to the Robust Systematic Humane Handling lead like the mandatory and progressive National School Lunch Program (NSLP) requires and - become pro-active instead of re-active.

The vast majority of USDA harvesting plants nationwide do a fantastic job regarding humane handling in the USA - including harvesting plants that are suspended because of say - a Heckle and Jeckle un-foreseen act by a greenhorn pen worker.

They get it.

And it clearly shows whenever they're audited.

The ground work advancements of the wide and expansive world of humane handling in 2023 can be contributed years ago to American Meat Institute (AMI) - turn - NAMI; the Professional Animal Auditor Certification Organization (PAACO), and Dr.Temple Grandin who is credited as the author of PAACO's sterling and historical "Animal Handling Guidelines and Audit Guide," among countless others - some retired and some still working.

However, selected USDA inspected harvesting plants who do not have in place - in 2023 - a systematic robust humane handling program are looking for double - trouble / rubble in River City.

The time has arrived that large, small and very small plants who harvest feed animals and birds have at least one employee accredited by a qualified entity - like PAACO - to help ensure 100% compliance is met regarding humane handling - OR - have on an affordable retainer - a qualified / experienced humane handling consultant that shall $ave a company from being locked down.

Humane handling like HACCP, is all about double signed and dated paperwork, plenty of employee training and an owner who is truly committed to humane handling.

Many times selected small and very small harvesting plants are not fully aware of what is expected of them regarding humane handling. Trust me.

The actual cost of writing a systematic robust humane handling program and on going employee training is cheap. Others and myself have written such robust programs for many small and very small plants and the money saved for not being cited - far, far outweighs the initial cost of a qualified humane handling consultant, while protecting your brands and business reputation.

ENDING NOTE

As this periodical humane handling series continues, I'll elaborate more on the myriad rules that govern the humane handling of feed animals and birds in the USA that was taught to me by others - via workshops (like Dr. Lynn Delmore) and on-hands experience (like Erika Voogd), and as an auditor and consultant in humane handling.

Many people do not want to know the details of harvesting animals and birds - they just want their steak medium rare with white rose potatoes, butter, sour cream, chopped chives, salt and pepper and then move on.

So be it.

However, for those that are curious (and that number seems to be increasing) or are actually doing the hard and dirty work, this continuing series is for you.

A small change but a huge leap for my 2023 LinkedIn blogging shall be that all blogs in 2023 shall be in English followed on another day in Spanish - or - vice versa.

It is much cleaner and easier for me posting separately than together.

After all - the vast majority of workers employed at USDA establishment are respected and hard-working Latinos of both genders who are thirsty for growth and advancements.

Hopefully this new 2023 series can assist anyone to understand food safety / quality, company cultures, OSHA safety, importance of human resources, and the humane handling of feed animals and birds better than before.

And that's what it's all about in 2023 - helping / contributing to make things better than they were in 2022.

I can honestly say, and the very few that know me - know this to be true - that the only reason I became a PAACO auditor was to help ensure that all of God’s animals and birds are handled humanely prior to being euthanized.

For me, it’s their inherent right.

.