United States Department of Agriculture
Food Safety and Inspection Service
Systematic Approach to
Humane Handling One Year Later
American Meat Institute Foundation
October 17, 2012
Kansas City
Larry A. Davis, DVM
Humane Handling Enforcement Coordinator
USDA-FSIS-Office of Field Operations
United States Department of Agriculture
Food Safety and Inspection Service
Systematic Approach to Humane
Handling
Introduced in the Federal Register Notice:
September 9, 2004 (Volume 69, Number
174) [Docket No. 04-013N] “Humane
Handling and Slaughter Requirements and
the Merits of a Systematic Approach to
Meet Such Requirements
 No regulatory requirement; no regulatory
requirement for a written “robust” plan

United States Department of Agriculture
Food Safety and Inspection Service
Federal Register Notice (Sept. 2004)
“Humane Handling and Slaughter Requirements and
the Merits of a Systematic Approach To Meet Such
Requirements”
Reasons for issuance: Congressional and
public interest concerning the humane
treatment of animals
 The number of humane handling noncompliance incidents documented by FSIS
had increased

United States Department of Agriculture
Food Safety and Inspection Service
Federal Register Notice (Sept. 2004)
“Humane Handling and Slaughter
Requirements and the Merits of a Systematic
Approach To Meet Such Requirements”
 Four parts to a systematic approach
 Initial
assessment
 Facility design and handling practices
 Periodic evaluations of handling and stunning
 Improvements made when determined necessary
United States Department of Agriculture
Food Safety and Inspection Service
Plants with “robust” written
Systematic Approach To Humane
Handling
Plant Size
Plant
Numbers
Robust
Systematic
Approach
(Written)
% Plants with
robust
approach
Large
61
58
95.00%
Small
154
77
50.00%
Very Small
568
61
10.70%
United States Department of Agriculture
Food Safety and Inspection Service
Number of Federally Inspected Livestock Slaughter Facilities by Plant Size** from
7/1/2011 to 06/30/2012, including: Head Slaughtered, Inhumane Handling
Suspensions, 04C02 Procedures, and HATS Time.
**Large- establishments with 500 or more employees, Small - establishments with
10 or more but fewer than 500 employees, and very small -establishments with
fewer than 10 employees.
Size
Livestock
Slaughter
Facilities
Livestock
Head
Slaughtered
Inhumane
Handling
Suspensions
Suspensions
/Livestock
Facilities
Percent
04C02 Non
Non
Compliant Compliant
Total
HATS in
Hours
HATS (hrs)
per 04C02
Performed
Total 04C02
Performed
Large
62
126,462,155
10
0.16
42,841
121
0.282%
114,760
2.68
Small
177
18,720,644
18
0.10
46,643
173
0.371%
104,602
2.24
Very Small
FY11Q4–
FY12Q3
Total
566
2,494,969
50
0.09
67,993
330
0.485%
81,010
1.19
805
147,677,768
78
0.10
157,477
624
0.396%
300,371
1.91
United States Department of Agriculture
Food Safety and Inspection Service
What is a Systematic Approach?
A systematic approach is a
comprehensive way of looking at and
thinking about how livestock enter and
move through an establishment
 A systematic approach focuses on treating
livestock in a way that prevents
excitement, discomfort, and accidental
injury the entire time livestock are held in
connection with slaughter

United States Department of Agriculture
Food Safety and Inspection Service
Why Implement a Systematic Approach?

A well-implemented and executed
systematic approach to humane handling
will help an establishment comply with
requirements of the Humane Methods of
Slaughter Act (HMSA), the Federal Meat
Inspection Act (FMIA), and the Federal
Regulations for the humane handling and
slaughter of livestock (9 CFR 313)
United States Department of Agriculture
Food Safety and Inspection Service
Why Implement a Systematic Approach?

An establishment has the responsibility for
treating livestock humanely beginning
when a transport vehicle carrying the
animals arrives to the facility and ends
when the animals are properly stunned.
United States Department of Agriculture
Food Safety and Inspection Service
What is a “robust” systematic approach?
Builds on the four criteria listed in the
Federal Register Notice by including a
“written plan” addressing facilities and
handling procedures
 The approach describes the procedures
used to maintain compliance

United States Department of Agriculture
Food Safety and Inspection Service
What is a “robust” systematic approach?
Evaluates periodically by performing and
recording the results of audits concerning
the establishment’s handling procedures
and facilities
 Responds to non-compliances or failures
in a “robust” way which includes the
documentation of the event and
associated corrective actions designed to
prevent the failure from happening again

United States Department of Agriculture
Food Safety and Inspection Service
What is a “robust” systematic approach?

Makes the “written” program and the
records generated available for FSIS
review
United States Department of Agriculture
Food Safety and Inspection Service
Why use a “robust” systematic
approach?
It is an additional measure of attention
provided to humane handling of livestock
 It demonstrates the establishment’s
awareness of humane handling issues and
will assist in improved results
 It demonstrates to FSIS, industry, outside
organizations, and the public that the
establishment is focused on humane
handling

United States Department of Agriculture
Food Safety and Inspection Service
Why use a “robust” systematic
approach?
Is evidence of humane practices for
potential customers that can be presented
on request
 Preparedness for third-party humane
handling audits

United States Department of Agriculture
Food Safety and Inspection Service
Regulatory Discretion


Option to implement lesser enforcement
level
Directive 6900.2 Rev. 2, Chap. VII, Part IV
A – no change: IIC is to immediately stop
inhumane slaughter and handling that is
“egregious” with appropriate regulatory control
action
 B – no change: IIC is to document the facts
that serve as the basis of the enforcement
action on a memorandum of interview (MOI)

United States Department of Agriculture
Food Safety and Inspection Service
Regulatory Discretion

Directive 6900.2 Rev. 2, Chap. VII, Part IV

C – recommend NOIE rather than NOS if
No recent Humane Handling enforcement actions
 Consistently meeting Humane Handling regulatory
requirements
 Operating under a written “robust” Systematic
Approach
 Robustness demonstrated through effective and
consistent implementation

United States Department of Agriculture
Food Safety and Inspection Service
The first edition of a “Guide for a
Systematic Approach to the Humane
Handling of Livestock” is being
developed by FSIS to encourage and
assist small and very small
establishments in writing a “robust”
systematic approach to humane
handling
United States Department of Agriculture
Food Safety and Inspection Service
Thank you!