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), says 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.
Anthenill outlined the two major components that a robust approach should have, which 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 your daily, weekly, and monthly inspections of procedures, along with corrective actions for problems.
Section 1 – Written plan
It is recommended that it should contain the following items.
- Mission statement of goals
- Standard Operating Procedures (SOPs) for your plant
- Risk Assessment – In your facility, outline possible problems that can occur in your SOPs. Flow charts in the AVMA Humane Slaughter Guidelines 2016 edition are useful. Only a few sentences are needed to each area.
Section 2 – Internal compliance documents
- Training records – State training materials used, which should contain dates, employee names and signatures.
- Stunner maintenance records – Should have records for both the main stunners and stunners or firearms used for nonambulatory animals.
- Records of corrective actions – All responses to NRs, NOIEs and suspensions are recorded. Also, include corrective actions you made to improve a procedure.
- Pre-op inspections – This would be similar to food safety pre-op inspections that are done to insure equipment is clean.
- Records of internal audits – Includes internal audits using NAMI guidelines. If any part of the weekly NAMI audit fails, there should be a recorded correction action.
- Records of outside audits and video footage (FSIS/USDA access is determined on a case-by-case basis by plant management) – Some examples are customer audits, third-party remote video audits and archived video footage.
- Unloading trucks;
- Penning in stockyard (lairage);
- Animal driving practices and driving aid use;
- Handling and stunning non-ambulatory animals;
- Stunning – 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;
- 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. When a plant is completely remodeled or has new construction, it is recommended to write new SOPs.