Please comment here! http://www.regulations.gov/ I typed in this – Docket No. FSIS-2013-0003 and it pops right up. I don’t mind if you use any part of what I wrote – just please comment. http://www.gpo.gov/…/pkg/FR-2013-10-29/html/2013-25373.htm
Humane Handling must be regulated by ‘law’ – not a guideline!
Discretion must be severely limited and defined where ever possible, for the welfare of the animals.
My comments are based on what most industries would perceive as standard operating procedures.
As a holder of a Certificate in Quality Management, I believe that Documentation and audits are a MUST when it comes to Humane handling of Animals – especially in the slaughter system where they can suffer immensely.
All slaughter facilities must be required to have documented procedures on Humane Handling. It should not be arbitrary or by discretion.
Humane Handling of Livestock must include any and all commercial entities that transport, hold, sell or broker livestock.
Audits performed by FSIS on Humane Handling must be mandated at regular intervals.
Third party audits must be performed once a year.
A non USDA entity or third party, must be enlisted to report noncompliance or abuses.
FSIS and IPP personnel must be protected from ‘retaliation’ for reporting noncompliances/abuse.
FSIS MUST require PRIOR notification of rest stops to enforce the 28 hour transportation rule and mandate audits to insure it is enforced.
IPP personnel must not perform the offloading ante mortem inspection of any Equines, including mules and donkeys, unless they hold a veterinarians license.
Disabled animals or animals unable to move must be immediately euthanized. Disabled animals are not to be attempted to be forced to move or moved by force while still conscious.
Moderately disabled animals, must be allowed to unload at their own pace and segregated for further evaluation.
The training of IPP and stunning operators must be regulated, documented and audited by FSIS personnel.
Air Pressure monitoring devices must include an audible alarm when the pressure is below the minimum established operating pressure.
Firearm training must be mandated, with periodic updates, records maintained, and audited by FSIS personnel.
Electrical stunning devices must be equipped with an audible alarm for the minimum operating voltage.
Ritual slaughter knifes must have a documented maintenance – replacement procedure and audited by FSIS personnel.
Those who perform ritual slaughter must complete training, document the training, and audited by FSIS personnel.
Carbon Dioxide concentrations must be monitored with an audible alarm for minimum time and minimum concentration.
All alarms and measuring devices must be calibrated at regular intervals detailed in a calibration document and audited by FSIS personnel.
Any changes to equipment or facilities must documented and approved by FSIS prior to implementation or as soon as reasonable possible in the event of an emergency and may require updates to the facility HACCP.
Any Egregious inhumane treatment violation that does not immediately suspend operations, must be followed by a reduced sampling plan to insure compliance. If the same Egregious inhumane treatment noncompliance is discovered any time within a given day, operations must be suspended until an irreversable corrective action is implemented.
An Egregious inhumane treatment violation must include animals received that are in obvious discomfort, pain, and or fever, that never should have been transported for processing.
An Egregious inhumane treatment violation must include animals In the last trimester of pregnancy.
An Egregious inhumane treatment violation must include animals that were mutilated, restrained, or recently ‘altered’ to enable transporting.
An Egregious inhumane treatment violation must include any electrical stunning device applied to the anus, vulva, ears or face of any animals
A system of prosecuting Egregious Inhumane Treatment violators must include prosecution by regular law enforcement agencies.
Regular law enforcement agencies must be educated and trained on Inhumane Handling.
An emergency notification system must be established for any individual to report Inhumane handling and for owners of animals to report lost, missing, stolen, adulterated animals to prevent them from being processed.
A corrective action and positive recall system must be documented and audited by FSIS and subsequently a third party on periodic intervals.
Any increase in number of animals processed from the original application, must be approved by FSIS through re-qualification and a revised HACCP analysis.