Humane Handling Humane Handling GMPsGMPsA Regulatory PerspectiveA Regulatory Perspective

Craig Shultz, DVMCraig Shultz, DVMFood Safety and Inspection ServiceFood Safety and Inspection Service

CargillCargill--Taylor BeefTaylor BeefWyalusing, PAWyalusing, PA

Cargill Taylor BeefCargill Taylor Beef

Wyalusing

The Market CowThe Market Cow

Humane Handling Humane Handling GMPsGMPs

GMP = Good Management PracticeGMP = Good Management PracticeNonNon--food safety initiative addressing food safety initiative addressing improved compliance, product quality, etc.improved compliance, product quality, etc.Example Example –– Humane Handling AuditHumane Handling Audit

Identifies areas critical to compliance in Identifies areas critical to compliance in plantplant’’s animal handling systems animal handling systemA preemptive approach to regulatory humane A preemptive approach to regulatory humane handling compliance handling compliance

““Know the RulesKnow the Rules””ActsActs

MPIA, HSAMPIA, HSARegulationsRegulations

9CFR Part 3139CFR Part 313DirectivesDirectives

FSIS Directive 6900.1 Disabled LivestockFSIS Directive 6900.1 Disabled LivestockFSIS Directive 6900.2 Humane Handling and FSIS Directive 6900.2 Humane Handling and Slaughter of LivestockSlaughter of Livestock

NoticesNoticesFSIS Notice 12FSIS Notice 12--05 Humane Handling Documentation05 Humane Handling Documentation

Addressing Overall Compliance in Addressing Overall Compliance in SelfSelf--AssessmentAssessment

FacilitiesFacilitiesAnimal HandlingAnimal HandlingStunningStunningDisabled AnimalsDisabled Animals

Assessment parameters will be plant-specific based onfactors such as age and layout of facility, slaughter class, etc.The goal is to meet and preferably exceed regulatory requirements.

FacilitiesFacilities9 CFR 313.19 CFR 313.1(a) Livestock pens, driveways and ramps shall be maintained in good repair. They shall be free from sharp or protruding objectswhich may, in the opinion of the inspector, cause injury or pain to the animals. Loose boards, splintered or broken planking and unnecessary openings where the head, feet, or legs of an animal may be injured shall be repaired.(b) Floors of livestock pens, ramps, and driveways shall be constructed and maintained so as to provide good footing for livestock. Slip resistant or waffled floor surfaces, cleated ramps and the use of sand, as appropriate, during winter months are examples of acceptable construction and maintenance.(d) Livestock pens and driveways shall be so arranged that sharp corners and direction reversal of driven animals are minimized.

SelfSelf--Assessment of FacilitiesAssessment of Facilities

Program should address regulatory Program should address regulatory standard rather than local paradigmsstandard rather than local paradigmsRecognize a Recognize a ““dynamic processdynamic process”” that will that will change with age of facility, slaughter change with age of facility, slaughter population, changing environmental population, changing environmental conditions, etc.conditions, etc.

Animal HandlingAnimal Handling9 CFR 313.29 CFR 313.2(a) Driving of livestock from the unloading ramps to the holding pens and from theholding pens to the stunning area shall be done with a minimum of excitement anddiscomfort to the animals. Livestock shall not be forced to move faster than a normalwalking speed.(b) Electric prods, canvas slappers, or other implements employed to drive animalsshall be used as little as possible in order to minimize excitement and injury. Any use of such implements which, in the opinion of the inspector, is excessive, is prohibited.Electrical prods attached to AC house current shall be reduced by a transformer to the lowest effective voltage not to exceed 50 volts AC.(c) Pipes, sharp or pointed objects, and other items which, in the opinion of theinspector, would cause injury or unnecessary pain to the animal shall not be used todrive livestock.

Animal HandlingAnimal Handling

FSIS Directive 6900.2FSIS Directive 6900.2Once a vehicle carrying livestock enters an official slaughter establishment’s premises, the vehicle is considered to be a part of that establishment’s premises. The animals within that vehicle are to be handled in accordance with 313.2.

StunningStunning

FSIS Directive 6900.2FSIS Directive 6900.2Appropriate stunning methods are required for an establishment to be in compliance with the HMSA. When stunning is done correctly, animals feel no pain, are rendered instantly unconscious, and remain unconscious until slaughtered.

Many adult cattle that enter slaughter market Many adult cattle that enter slaughter market channels in a disabled state become nonchannels in a disabled state become non--

ambulatory during delivery or after arrival at the ambulatory during delivery or after arrival at the slaughter facilityslaughter facility

TransportTransportLivestock MarketsLivestock MarketsPackinghousePackinghouse

Current US regulations state that all Current US regulations state that all nonnon--ambulatory disabled cattle are ambulatory disabled cattle are

to be condemned and disposed of in to be condemned and disposed of in accordance with 9 CFR 309.13accordance with 9 CFR 309.13

9CFR 309.2(b) defines non9CFR 309.2(b) defines non--ambulatory disabled livestock, ambulatory disabled livestock, including cattle as livestock that cannot rise from a including cattle as livestock that cannot rise from a

recumbent position or that cannot walk, including, but not recumbent position or that cannot walk, including, but not limited to, those with broken appendages, severed tendons limited to, those with broken appendages, severed tendons or ligaments, nerve paralysis, fractured vertebral column or or ligaments, nerve paralysis, fractured vertebral column or

metabolic conditions.metabolic conditions.

DownDown--Cow Humane HandlingCow Humane Handling

Additional inAdditional in--plant measures to minimize handling plant measures to minimize handling and discomfort of disabled cattleand discomfort of disabled cattle

Minimize handlingMinimize handlingProvide adequate comfort and protectionProvide adequate comfort and protectionTimely euthanasiaTimely euthanasia

Ambulatory Disabled CattleAmbulatory Disabled Cattle

LamenessesLamenesses Observed in Dairy Observed in Dairy Cattle at SlaughterCattle at Slaughter

TibialTibial Nerve ParalysisNerve Paralysis

PeronealPeroneal Nerve Nerve ParalysisParalysis

Handling Ambulatory Handling Ambulatory Disabled CattleDisabled Cattle

FSIS Daily Verification of InFSIS Daily Verification of In--Plant Plant Humane Handling:Humane Handling:

The Humane Handling ChecklistThe Humane Handling ChecklistMeasures for inclement Measures for inclement weatherweatherTruck unloadingTruck unloadingWater availabilityWater availabilityAnte mortem inspectionAnte mortem inspectionDisabled animalsDisabled animalsProd useProd useSlips & fallsSlips & fallsStunning efficacy Stunning efficacy Insensitivity on the Insensitivity on the bleeding railbleeding rail

Subsets of these Subsets of these tasks are performed tasks are performed daily by veterinarians daily by veterinarians and/or inspectors. and/or inspectors. Results are recorded Results are recorded in an electronic in an electronic database.database.FSIS Notice 12FSIS Notice 12--0505

Ante Mortem Findings in Ante Mortem Findings in Suspect Cattle Suspect Cattle

Est. 9400 Ante Mortem Suspects 1-1-05 to 2-28-05

20%

34%18%

8%

10%

10% Surgery

Lame

Metabolic/Inflam

Facial

Ocular

Misc.

921Suspect Cattle: 885 Holstein Cows, 10 Non-Holstein Dairy, 19 Beef, 7 Bulls

Reducing the Ambulatory Reducing the Ambulatory Disabled Cow ProblemDisabled Cow Problem

Producer quality assurance programs for Producer quality assurance programs for onon--farm humane handlingfarm humane handlingPreconditioning cull dairy cowsPreconditioning cull dairy cowsDirect marketing by larger herdsDirect marketing by larger herdsRegulatory controls on the transportation Regulatory controls on the transportation marketing, and slaughter of ambulatory marketing, and slaughter of ambulatory disabled cattledisabled cattle

New York State Cattle Health Assurance New York State Cattle Health Assurance Program Cattle Welfare ModuleProgram Cattle Welfare Module

A Certification Program requiring written SOPs A Certification Program requiring written SOPs addressing onaddressing on--farm cattle welfare:farm cattle welfare:

NonNon--ambulatory ambulatory CattleCattleEuthanasia Euthanasia Decision PlanDecision PlanEuthanasia Action Euthanasia Action PlanPlanLamenessLamenessHospital AnimalsHospital Animals

Newborn calvesNewborn calvesFacilitiesFacilitiesMovement and Movement and handlinghandlingRoutine/Elective Routine/Elective Surgical Surgical ProceduresProceduresTransport Transport Decision PlanDecision Plan

New York State Cattle Health New York State Cattle Health Assurance Program Animal Welfare Assurance Program Animal Welfare

ModuleModule

SOPs reviewed by NYSCHAPS SOPs reviewed by NYSCHAPS VeterinarianVeterinarianEmployees involved in animal care trained Employees involved in animal care trained and evaluatedand evaluatedSigned statement of commitment to animal Signed statement of commitment to animal welfare principleswelfare principles

Cornell/Taylor/NCBACornell/Taylor/NCBACow Feeding StudyCow Feeding Study

65 head of Holstein cows from auctions65 head of Holstein cows from auctionsPreg. checked and eliminated bred Preg. checked and eliminated bred cowscows2 pens at Cornell beef T&R center2 pens at Cornell beef T&R centerHalf implanted with RevalorHalf implanted with RevalorFed High grain with Fed High grain with MelengesterolMelengesterolAcetateAcetateTested for antibiotic residues and Tested for antibiotic residues and JohnesJohnesOne pen fed Optaflexx (Ractopamine) One pen fed Optaflexx (Ractopamine) last 28 dayslast 28 days

Adding value through feedingAdding value through feeding(after culling from the milking herd)(after culling from the milking herd)

Gain significant weightGain significant weightIncrease dressing percentIncrease dressing percentReplenish muscle tissueReplenish muscle tissueMake yellow fat whiteMake yellow fat whiteMarket timingMarket timingSolving lameness problems (get off concrete)Solving lameness problems (get off concrete)Reduce antibiotic residuesReduce antibiotic residuesUtilize Utilize ““freefree”” feeds feeds ------ refusal feedsrefusal feeds

Unseen Cow DefectsUnseen Cow Defects

Johnes DiseaseJohnes DiseaseBased on tests of fecal samplesBased on tests of fecal samples

24 cows culled24 cows culled1 mortality1 mortality

16 (29.1%) diagnosed positive for Johnes16 (29.1%) diagnosed positive for Johnes

Antibiotic PositiveAntibiotic PositiveBased on Urine Sample Based on Urine Sample

5 (9.4%) initially positive5 (9.4%) initially positive0 positive at slaughter0 positive at slaughter

Direct Marketing by ProducersDirect Marketing by Producers

Has the potential to reduce transit time and Has the potential to reduce transit time and commingling at cattle marketscommingling at cattle marketsRecognition of producers consistently delivering Recognition of producers consistently delivering high quality cattle (= $?)high quality cattle (= $?)Problems:Problems:

Chargeback for condemned cattle Chargeback for condemned cattle –– can be costly can be costly with a BLV herd.with a BLV herd.Discounting of cattle suspected and residue tested Discounting of cattle suspected and residue tested (FAST positives with (FAST positives with ceftiofurceftiofur, , subtolerancesubtolerancetetracycline, etc. is a problem).tetracycline, etc. is a problem).

Regulatory Controls on the Regulatory Controls on the Movement of Disabled CattleMovement of Disabled Cattle

From a field regulatory standpoint, From a field regulatory standpoint, consistent application is a challenge.consistent application is a challenge.When, where, and by whom would When, where, and by whom would transport decisions be made?transport decisions be made?Ambulatory disabled cattle do not have a Ambulatory disabled cattle do not have a high condemnation rate. Therefore, a high condemnation rate. Therefore, a significant loss of usable protein to the significant loss of usable protein to the edible channel would occur.edible channel would occur.

Producer Quality AssuranceProducer Quality Assurance

The End Product: Measurable and The End Product: Measurable and Meaningful ProgressMeaningful Progress

Improved cattle movementImproved cattle movementImproved facilities that better address the needs Improved facilities that better address the needs of the slaughter populationof the slaughter populationReduction in prod useReduction in prod useReduction in number of fallen cows in the Reduction in number of fallen cows in the serpentineserpentineImproved equipment maintenance proceduresImproved equipment maintenance proceduresIncreased awareness Increased awareness –– employees, producers employees, producers and transporters and transporters -- outreachoutreach

Process Failure VortexProcess Failure Vortex

Poor Communication

Local Paradigms

Aggressive Approach

Failure to address written standard

Non-compliance

Inability or Unwillingness to comply

Industry Industry –– FSIS DialogFSIS Dialog

Scheduled periodic discussions of inScheduled periodic discussions of in--plant plant humane handlinghumane handling

Can be included periodically in weekly HACCP Can be included periodically in weekly HACCP meetingsmeetingsShould include HH auditors and animal handling Should include HH auditors and animal handling supervisorssupervisors

Audits and findingsAudits and findingsFacilities improvementsFacilities improvementsIncident reportsIncident reportsNonNon--compliances/corrective actions/preventive compliances/corrective actions/preventive measures measures

VerifiableComplianceFSIS Industry

Knowledge ofStandards

Active Monitoring

Documentation

Dialog

Commitment to Principles of Animal Welfare

Consistent Application of Regulations, Directives, and Notices

Effective InEffective In--Plant EnvironmentPlant Environment

HATS Monitoring

PrioritizationPrioritization

Animal Handling

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