The Humane Methods of Slaughter Act of 1978 (7 USC 1901) and the regulations that enforce it (9 CFR 313) contain the requirements for humane handling and stunning of livestock at slaughter establishments in the United States. Key parts include 1.) all animals must be rendered immediately insensible with a single stun and 2.) no egregious acts of abuse. The law and regulations contain three general categories: stunning, handling and facilities.
When an alleged humane handling violation occurs, FSIS will issue a suspension (notice of suspension, reinstatement of suspension) or a notice of intended enforcement (NOIE). A suspension will halt inspection services until the FSIS district office deems the issues have been appropriately addressed. An NOIE is a warning indicating there is basis to suspend inspection, but the establishment has the opportunity to take immediate corrective action and resume production under inspection. With NOIEs, appropriate corrective action must be taken within three business days, or they can turn into suspensions. These enforcement action letters are posted to the FSIS website. Since 2014, the Animal Welfare Lab at the University of Wisconsin – River Falls has assessed these letters to understand the root causes of these events and identify opportunities for improvement.
In 2024, there were 63 humane handling enforcement actions posted to the FSIS website. Most involved cattle (45%, 28/63), followed by swine (38%, 2463), sheep (14%, 9/63), and goats (3%, 2/63). It is not surprising that 83% of enforcement actions involved cattle and swine because they comprise approximately 98% of the red-meat slaughter volume in the United States.
Seventy percent (44/63) of humane handling enforcement actions issued in 2024 involved stunning, 11% (7/63) involved handling, and there were no facility-related enforcement actions. Examples of handling-related enforcement actions include forcing animals to jump 4 ft between levels inside a trailer, dragging lame animals by the ear, using an electric prod on sensitive areas (e.g., face), throwing animals into holding pens, and mechanical gates pushing sitting or nonambulatory animals. An additional 19% (12/63) of enforcement actions were categorized as ‘multiple’ – where two distinct reasons contributed to the incident. In 2024, all 12 ‘multiple’ enforcement actions involved stunning and handling. These also included any events where a cut or attempted cut to the throat of a conscious animal occurred (excluding ritual slaughter).
A Stunning Issue
In total, 89% (56/63) of enforcement actions included stunning, when all stunning and ‘multiple’ enforcement actions were considered. Most of those enforcement actions involved mechanical stunning (77%, 43/56), followed by electrical stunning (18%, 10/56). Five percent (3/56) of the stunning-related enforcement actions involved making a cut to the throat of a conscious animal either without stunning or after a failed stun attempt. There were no humane handling enforcement actions that involved ritual slaughter. Of the 43 enforcement actions that were related to mechanical stunning, a captive bolt was used for the first stun attempt in 70% (30/43) of events, a firearm was used in 28% (12/43), and the type of stunning device was not described for one incident. For all stunning-related incidents, it took between two and five stuns to render the animal insensible, three stuns being the most common (23%, 14/56).
The reason for stun failure was not clearly described in the enforcement action letter for 61% (34/56) of stunning-related incidents. For the 39% of stunning-related enforcement actions where the reason for stun failure was clearly described, 25% (14/56) were related to placement issues, 9% (5/56) were related to restraint, 3% (2/56) were related to equipment, and 2% (1/56) were related to excessive time between stunning and sticking.
Starting point: Focusing on training
All humane handling enforcement actions issued in 2024 involved stunning (89%) and/or handling (11%). There are multiple ways to ensure effective stunning: using equipment that is appropriate for the type of animal, correct stun placement, and proper restraint. Training can be implemented to prevent nearly all humane handling enforcement actions. It is important to recognize that many violations of the Humane Methods of Slaughter Act can go from bad to worse, depending on the decisions of animal handlers and stunner operators. Training for these individuals should emphasize the importance of calm and careful thinking as they are presented with challenging and uncomfortable situations.
Karly N. Anderson, PhD, is a scientist and trainer with the Humane Handling Institute at the University of Wisconsin – River Falls. She leads research on improving pre-slaughter stunning and on-farm euthanasia for a variety of species, including cattle, swine, bison and yak. She also trains slaughter plant personnel on stun placement and captive bolt maintenance.
