|Dr. Temple Grandin|
Many people have asked: “What exactly is a robust systematic approach for humane slaughter?” Lucy Anthenill, DVM, an inspector for the US Dept. of Agriculture’s Food Safety and Inspection Service (FSIS), gave a presentation at the 2016 North American Meat Institute’s Animal Care and Handling Conference on the items she looks for when assessing a plant for humane compliance. There are two basic requirements: 1) a robust systematic approach is similar to a hazard analysis and critical control point (HACCP) plan and; 2) the FSIS should have access to the records.
FSIS regulations and directives do not specify the plan must be written, but Anthenill and most plant managers would agree that a written plan is definitely preferred. Anthenill has visited plants where nobody could find the records for the robust systematic approach. This shows a lack of commitment and proves the plan is definitely not robust. People in the plant must actually be using the materials to make the system robust. Each plant should have its own customized system, which is written to follow the actual procedures done in their plant. Copying wording verbatim from the FSIS/USDA website is not recommended. The website does contain much useful information and it can be accessed by typing the following title into Google, “FSIS Compliance Guide to a Systematic Approach to Humane Handling of Livestock 2013.” Other useful sources of information are www.grandin.com and the AVMA Humane Slaughter Guidelines 2016 edition.
Anthenill outlined the components that a robust approach should have. I have put it into an outline that will make it easier for people who are developing a program for the first time. A robust systematic approach should have two major components that can be kept in separate binders for paper documents or separate sections of an online document. The two sections are your overall written plan and the second section would be your daily, weekly, and monthly inspections of procedures, along with corrective actions for problems.
Section 1: Written plan for robust systematic approach
It is recommended that it should contain the following items:
Mission statement of goals (USDA/FSIS access) – Write out a few sentences about overall goals.
Standard Operating Procedures (SOPs) for your plant (FSIS/USDA access) – An SOP should be written for the following areas using plain and simple language and each SOP may be a few sentences or a short paragraph.
- Unloading trucks;
- Penning in stockyard (lairage);
- Animal driving practices and driving aid use;
- Handling and stunning non-ambulatory animals;
- Stunning – If you routinely shoot animals twice, state the procedure here. Describe all stunning instruments both the main stunners and stunners that are used in the yards. Describe procedures to insure that all signs of brain activity are absent before starting invasive dressing procedures;
- Methods and location of people to determine that the animal is unconscious and insensible;
- Emergency plan for storms, power failures and other problems; What will you do if you have animals in route? Where will you direct them?;
- Living document – When a plant improves a procedure, there should be a record of it. To make this easier for small plants, you could keep a folder of improvements. Some examples might be rubber mat flooring in stun box, a new procedure for handling non-ambulatory animals or an additional gate. When a plant is completely remodeled or has new construction, it is recommended to write new SOPs.
Risk Assessment (FSIS/USDA access) – In your facility, outline possible problems that can occur in each one of the above areas. Flow charts in the AVMA Humane Slaughter Guidelines 2016 edition are useful. State specific problems in your facility such as how you will prevent falls when the animals go around a sharp corner. In a wet area where cartridges can get wet, how will you keep them dry? Only a few sentences are needed in each area.
Section 2: Internal compliance documents
FSIS/USDA will have access to internal compliance documents. These documents include:Training records (FSIS/USDA access) – These records should include the state training materials that were used, in addition to dates, employee names and signatures.