Humane Methods of Slaughter Act
Actions Are Needed to Strengthen Enforcement Gao ID: GAO-10-203 February 19, 2010Concerns about the humane handling and slaughter of livestock have grown; for example, a 2009 video showed employees at a Vermont slaughter plant skinning and decapitating conscious 1-week old veal calves. The Humane Methods of Slaughter Act of 1978, as amended (HMSA) prohibits the inhumane treatment of livestock in connection with slaughter and requires that animals be rendered insensible to pain before being slaughtered. The U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS) is responsible for HMSA. GAO was asked to (1) evaluate FSIS's efforts to enforce HMSA, (2) identify the extent to which FSIS tracks recent trends in resources for HMSA enforcement, and (3) evaluate FSIS's efforts to develop a strategy to guide HMSA enforcement. Among other things, GAO received survey responses from inspectors at 235 plants and examined a sample of FSIS noncompliance reports and suspension data for fiscal years 2005 through 2009.
GAO's survey results and analysis of FSIS data suggest that inspectors have not taken consistent actions to enforce HMSA. Survey results indicate differences in the enforcement actions that inspectors would take when faced with a humane handling violation, such as when an animal was not rendered insensible through an acceptable stunning procedure by forcefully striking the animal on the forehead with a bolt gun or properly placing electrical shocks. Specifically, 23 percent of inspectors reported they would suspend operations for multiple unsuccessful stuns with a captive bolt gun whereas 27 percent reported that they would submit a noncompliance report. GAO's review of noncompliance reports also identified incidents in which inspectors did not suspend plant operations or take regulatory actions when they appeared warranted. The lack of consistency in enforcement may be due in part to the lack of clarity in current FSIS guidance and inadequate training. The guidance does not clearly indicate when certain enforcement actions should be taken for an egregious act--one that is cruel to animals or a condition that is ignored and leads to the harming of animals. A noted humane handling expert has stated that FSIS inspectors need clear directives to improve consistency of HMSA enforcement. According to GAO's survey, FSIS's training may be insufficient. For example, inspectors at half of the plants did not correctly answer basic facts about signs of sensibility. Some private sector companies use additional tools to assess humane handling and improve performance. FSIS cannot fully identify trends in its inspection funding and staffing for HMSA, in part because it cannot track HMSA inspection funds separately from the inspection funds spent on food safety activities. FSIS also does not have a current workforce planning strategy for allocating limited staff to inspection activities, including HMSA enforcement. FSIS has strategic, operational, and performance plans for its inspection activities but does not clearly outline goals, needed resources, time frames, or performance metrics and does not have a comprehensive strategy to guide HMSA enforcement.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-10-203, Humane Methods of Slaughter Act: Actions Are Needed to Strengthen Enforcement
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
February 2010:
Humane Methods of Slaughter Act:
Actions Are Needed to Strengthen Enforcement:
GAO-10-203:
GAO Highlights:
Highlights of GAO-10-203, a report to congressional requesters.
Why GAO Did This Study:
Concerns about the humane handling and slaughter of livestock have
grown; for example, a 2009 video showed employees at a Vermont
slaughter plant skinning and decapitating conscious 1-week old veal
calves. The Humane Methods of Slaughter Act of 1978, as amended (HMSA)
prohibits the inhumane treatment of livestock in connection with
slaughter and requires that animals be rendered insensible to pain
before being slaughtered. The U.S. Department of Agriculture‘s (USDA)
Food Safety and Inspection Service (FSIS) is responsible for HMSA.
GAO was asked to (1) evaluate FSIS‘s efforts to enforce HMSA, (2)
identify the extent to which FSIS tracks recent trends in resources
for HMSA enforcement, and (3) evaluate FSIS‘s efforts to develop a
strategy to guide HMSA enforcement. Among other things, GAO received
survey responses from inspectors at 235 plants and examined a sample
of FSIS noncompliance reports and suspension data for fiscal years
2005 through 2009.
What GAO Found:
GAO‘s survey results and analysis of FSIS data suggest that inspectors
have not taken consistent actions to enforce HMSA. Survey results
indicate differences in the enforcement actions that inspectors would
take when faced with a humane handling violation, such as when an
animal was not rendered insensible through an acceptable stunning
procedure by forcefully striking the animal on the forehead with a
bolt gun or properly placing electrical shocks. Specifically, as shown
below, 23 percent of inspectors reported they would suspend operations
for multiple unsuccessful stuns with a captive bolt gun whereas 27
percent reported that they would submit a noncompliance report. GAO‘s
review of noncompliance reports also identified incidents in which
inspectors did not suspend plant operations or take regulatory actions
when they appeared warranted. The lack of consistency in enforcement
may be due in part to the lack of clarity in current FSIS guidance and
inadequate training. The guidance does not clearly indicate when
certain enforcement actions should be taken for an egregious act”one
that is cruel to animals or a condition that is ignored and leads to
the harming of animals. A noted humane handling expert has stated that
FSIS inspectors need clear directives to improve consistency of HMSA
enforcement. According to GAO‘s survey, FSIS‘s training may be
insufficient. For example, inspectors at half of the plants did not
correctly answer basic facts about signs of sensibility. Some private
sector companies use additional tools to assess humane handling and
improve performance.
Figure: Percentage of Inspectors Identifying Enforcement Actions for
Stunning:
[Refer to PDF for image: 2 pie-charts]
Multiple unsuccessful captive bolt stuns:
Regulatory control action: 38%;
Noncompliance report only: 27%;
Suspension: 23%;
None of these: 7%;
Don‘t know: 5%.
Multiple misplaced electrical stuns:
Regulatory control action: 37%;
Noncompliance report only: 34%;
Suspension: 17%;
None of these: 7%;
Don‘t know: 4%.
Source: GAO analysis of survey results.
[End of figure]
FSIS cannot fully identify trends in its inspection funding and
staffing for HMSA, in part because it cannot track HMSA inspection
funds separately from the inspection funds spent on food safety
activities. FSIS also does not have a current workforce planning
strategy for allocating limited staff to inspection activities,
including HMSA enforcement. FSIS has strategic, operational, and
performance plans for its inspection activities but does not clearly
outline goals, needed resources, time frames, or performance metrics
and does not have a comprehensive strategy to guide HMSA enforcement.
What GAO Recommends:
GAO is making recommendations to strengthen HMSA enforcement by, for
example, establishing specific guidance on actions to take for HMSA
violations. In commenting on a draft of this report, USDA did not
state whether it agreed or disagreed with GAO‘s findings or
recommendations. However, it stated that it plans to use them in
improving efforts to enforce HMSA.
View [hyperlink, http://www.gao.gov/products/GAO-10-203] or key
components. To view survey results online click on [hyperlink,
http://www.gao.gov/products/GAO-10-244SP]. For more information,
contact Lisa Shames at (202) 512-3841 or shamesl@gao.gov.
[End of section]
Contents:
Letter:
Background:
Weaknesses Persist in FSIS's Enforcement, Training and Guidance, and
Data Management:
FSIS Cannot Fully Identify and Plan Resource Needs for HMSA
Enforcement:
FSIS Does Not Have a Comprehensive Strategy for Enforcing HMSA:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Location of Inspectors Observing HMSA Compliance at
Typical Mid-Sized Plant:
Appendix III: HMSA Suspensions for FSIS Districts:
Appendix IV: Comments from the U.S. Department of Agriculture:
Appendix V: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Total Specified in Annual Appropriations for FSIS
Inspections, Estimated Amount FSIS Dedicated for Humane Handling
Enforcement, and Estimated Percentage of FSIS Annual Inspection
Appropriation for Humane Handling, Fiscal Years 2005 through 2008:
Table 2: Minimum Number of FTEs Required by Congress for Humane
Handling Compared with the FTEs Reported by FSIS, Fiscal Years 2005
through 2009:
Table 3: Universe of Plants and Sample Description:
Figures:
Figure 1: States and Territories Covered by FSIS District Offices:
Figure 2: Stunning Methods Consistent with HMSA:
Figure 3: Key FSIS Inspection Personnel Involved in HMSA Enforcement:
Figure 4: Percentage of Inspectors Identifying Which Enforcement
Action They Would Take for Electrical Prodding:
Figure 5: Percentage of Inspectors Identifying Which Enforcement
Action They Would Take for Stunning:
Figure 6: Percentage of Inspectors Identifying Which Enforcement
Action They Would Take for Other Violations:
Figure 7: Percentage of Inspectors-in-Charge Identifying Suspension as
the Appropriate Enforcement Action, by Plant Size:
Figure 8: Number of Plant Suspensions Nationwide, Calendar Years 2005
through August 2009:
Figure 9: Inspectors Identified the Need for Additional Guidance
and/or Training in Seven Key Areas of Humane Handling Enforcement:
Figure 10: Percentage of Inspectors-in-Charge Reporting Video
Surveillance as Very or Moderately Useful in Five Plant Areas:
Figure 11: Location of Inspectors Observing Compliance with the HMSA
at a Typical Mid-Sized Plant:
Figure 12: Percentage of Suspensions by District, Calendar Year 2008:
Abbreviations:
DVMS: district veterinary medical specialist:
FSIS: Food Safety and Inspection Service:
FTE: full-time equivalent:
HMSA: Humane Methods of Slaughter Act of 1978:
USDA: U.S. Department of Agriculture:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
February 19, 2010:
The Honorable Darrell E. Issa:
Ranking Member:
Committee on Oversight and Government Reform:
House of Representatives:
The Honorable Dennis J. Kucinich:
Chairman:
Subcommittee on Domestic Policy:
Committee on Oversight and Government Reform:
House of Representatives:
Concerns about the humane handling and slaughter of livestock have
increased in recent years, particularly after a widely publicized
video in 2008 of actions at a slaughter plant in California. The 2008
video showed employees at the plant delivering electric shocks to
nonambulatory cows, spraying them with high-pressure water hoses, and
ramming them with a forklift to force them to rise for slaughter. The
U.S. Department of Agriculture (USDA) suspended operations at the
California plant, citing the egregious nature of its actions and its
failure to maintain and implement controls to prevent the inhumane
handling and slaughter of nonambulatory cows at the facility. More
recently, in October 2009, USDA received a video recording of
employees at a Vermont slaughter plant that shows employees skinning
and decapitating conscious veal calves, which are about 1-week old.
USDA and the state of Vermont suspended the operating licenses for
this plant, effectively shutting down operations, pending the results
of an ongoing investigation. Such actions may violate the Humane
Methods of Slaughter Act of 1978, as amended (HMSA). HMSA prohibits
the inhumane treatment of livestock in slaughter plants and generally
requires that animals be rendered insensible--typically referred to as
stunning--before proceeding with slaughter.
USDA's Food Safety and Inspection Service (FSIS) is responsible for
ensuring the safety of meat and other products in the United States,
as well as for enforcing HMSA. Since 2002, Congress has urged USDA to
fully enforce HMSA, directed it to enhance staffing for HMSA-related
inspections and enforcement, and designated funding to develop and
maintain a system for tracking the amount of time that inspectors
spend on HMSA enforcement.
We have previously reported on weaknesses in FSIS's management of
HMSA, particularly its reporting of violations and use of inconsistent
criteria for enforcement.[Footnote 1] In 2004, we recommended that
FSIS take several actions to improve HMSA oversight, including
providing informative data on HMSA violations and assessing whether
FSIS resources are sufficient to effectively enforce the act. In 2008,
USDA's Office of Inspector General reported that FSIS management
controls over preslaughter activities could be strengthened to
minimize the possibility of egregious humane handling events.[Footnote
2]
In this context, you asked us to (1) evaluate FSIS's efforts to
enforce HMSA, (2) identify the extent to which FSIS tracks recent
trends in FSIS inspection resources for enforcing HMSA, and (3)
evaluate FSIS's efforts to develop a strategy to guide HMSA
enforcement.
To evaluate FSIS's efforts to enforce HMSA, we examined a sample of
FSIS noncompliance reports, suspension data, and district veterinary
medical specialist reports in all 15 of FSIS's district offices for
fiscal years 2005 through 2009. To assess the reliability of these
data, we examined the data for obvious errors in completeness and
accuracy, reviewed existing documentation about the systems that
produced the data, and questioned knowledgeable officials about the
data and systems. We determined that the data were sufficiently
reliable for the purposes of this report, with any limitations noted
in the text. From May 2009 through July 2009, we also surveyed
inspectors-in-charge--those responsible for reporting on humane
handling enforcement in the plants--from a random sample of inspectors-
in-charge at 257 livestock slaughter plants. We selected the sample of
257 plants, stratified by size, from a universe of 782 plants, and
then surveyed inspectors-in-charge at the sample plants. Our sample
allows us to make estimates about the observations and opinions of all
inspectors-in-charge at U.S. slaughter plants. We obtained an overall
survey response rate of 93 percent.[Footnote 3] This report does not
contain all of the results from our survey. The survey can be viewed
at GAO-10-244SP. We also met with key officials from FSIS's Office of
Field Operations who are responsible for implementing HMSA at the
headquarters level. To understand district officials' perspectives on
HMSA enforcement, we conducted semistructured interviews with each of
FSIS's 15 district veterinary medical specialists (DVMS) and 15
district managers. We also obtained the views of experts in humane
handling to understand key principles of humane handling techniques
and enforcement. In particular, we consulted with Dr. Temple Grandin,
a world-renowned expert on animal welfare, who provided her expert
opinion on particular humane handling incidents we identified as
possible HMSA violations.[Footnote 4] To identify the extent to which
FSIS tracks recent trends in inspection resources for enforcing HMSA,
we reviewed FSIS funding and staffing data for each district. We also
conducted semi-structured interviews with resource management analysts
in each of FSIS's 15 district offices and interviewed key officials in
the Resource Management and Planning Office within the Office of Field
Operations. To assess FSIS's efforts to develop a strategy to enforce
HMSA, we reviewed relevant FSIS strategies, including the most recent
FSIS Strategic Plan FY 2008 through FY 2013, the Office of Field
Operations' Workforce Plan, and other relevant planning documents. A
more detailed description of our objectives, scope, and methodology is
presented in appendix I.
We conducted this performance audit from October 2008 to February
2010, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Background:
In 2008, the most recently available data, more than 153 million
cattle, sheep, hogs, and other animals ultimately destined to provide
meat for human consumption were slaughtered at about 800 slaughter
plants throughout the United States that engage in interstate
commerce. Under federal law, meat-processing facilities that engage in
interstate commerce must have federal inspectors on site. FSIS
classifies plants according to size and the number of employees.
Specifically, large plants have 500 or more employees; small plants
have from 10 to 499 employees; and very small plants have fewer than
10 employees, or annual sales of less than $2.5 million. Under HMSA,
FSIS inspectors are to ensure that animals are humanely treated from
the moment they arrive at a plant until they are slaughtered. FSIS
deploys these inspectors from 15 district offices nationwide. Figure 1
shows the states and territories in each FSIS district.
Figure 1: States and Territories Covered by FSIS District Offices:
[Refer to PDF for image: U.S. map]
Alameda District:
California.
Albany District:
Connecticut;
Maine;
Massachusetts;
New Hampshire;
New York;
Rhode Island;
Vermont.
Atlanta District:
Florida;
Georgia;
Puerto Rico;
Virgin Islands.
Beltsville District:
Delaware;
District of Columbia;
Maryland;
Virginia;
West Virginia.
Chicago District:
Illinois;
Indiana;
Ohio.
Dallas District:
Texas.
Denver District:
Alaska;
American Samoa;
Arizona;
Colorado;
Guam;
Hawaii;
Idaho;
Nevada;
New Mexico;
Northern Mariana Islands;
Oregon;
Utah;
Washington.
Des Moines District:
Iowa;
Nebraska.
Jackson District:
Alabama;
Mississippi;
Tennessee.
Lawrence District:
Missouri;
Kansas.
Madison District:
Michigan;
Wisconsin.
Minneapolis District:
Minnesota;
Montana;
North Dakota;
South Dakota;
Wyoming.
Philadelphia District:
New Jersey;
Pennsylvania.
Raleigh District:
Kentucky;
North Carolina;
South Carolina.
Springdale District:
Arkansas;
Louisiana;
Oklahoma.
Sources: GAO analysis of FSIS data; Map Resources (map).
[End of figure]
After livestock arrive at a slaughter plant, plant employees monitor
their movements as they are unloaded from trucks to holding pens and
eventually led into the stunning chute. Plant employees typically
restrain an animal in the chute and stun it by using one of several
devices--carbon dioxide gas, an electrical current, a captive bolt
gun,[Footnote 5] or a gunshot--that, as required by HMSA regulations,
is rapid and effective in rendering the animal insensible. (See figure
2.) Under HMSA, animals must be rendered insensible--that is, unable
to feel pain--on the first stun before being shackled, hoisted on the
bleed rail, thrown, cast, or cut. According to the expert we
consulted, animals on the bleed rail that exhibit any of the following
signs are considered sensible and would therefore be need to be
restunned:
* natural blinking,
* lifting head straight up and keeping it up (righting reflex),
* rhythmic breathing, and:
* vocalizing.
Figure 2 shows stunning methods consistent with HMSA.
Figure 2: Stunning Methods Consistent with HMSA:
[Refer to PDF for image: 4 photographs]
Carbon dioxide gas;
Electrical current;
Captive bolt gun;
Gunshot.
Source: FSIS ’Humane Handling Basics.“
[End of figure]
Once the animals are considered stunned, they are shackled and hoisted
onto a processing line, where their throats are cut, and they are
fully bled before processing continues. HMSA exempts only ritual
slaughter, such as kosher and halal slaughter, from the HMSA
requirement that animals be rendered insensible on the first blow. See
appendix II for a more detailed description of the movement of
livestock through the plant.
FSIS has issued a variety of regulations and directives instructing
FSIS inspectors on how to enforce HMSA. Overall, the regulations
emphasize the minimization of "excitement and discomfort" to the
animals and require that they are effectively stunned before being
slaughtered. In 2003, FSIS guidance on humane handling enforcement
stated that inspectors were to determine whether a humane handling
incident does, or will immediately lead to, an injured animal or
inhumane treatment. The guidance also specified the types of actions
inspectors should take when these situations occur. Also in 2003, FSIS
began providing "humane interactive knowledge exchange" scenarios as
an educational tool to enhance inspectors' understanding of
appropriate enforcement actions. These eight written scenarios,
available on FSIS's Web site, provide examples of inhumane incidents
and suggest enforcement actions.
In 2005, the agency issued additional guidance specifying egregious
humane handling situations.[Footnote 6] This guidance defines
egregious as any act that is cruel to animals or a condition that is
ignored and leads to the harming of animals. The guidance provided the
following examples of egregious acts:
* making cuts on or skinning conscious animals,
* excessively beating or prodding ambulatory or nonambulatory disabled
animals,
* dragging conscious animals,
* driving animals off semitrailers over a drop-off without providing
adequate unloading facilities so that animals fall to the ground,
* running equipment over animals,
* stunning animals and then allowing them to regain consciousness,
* leaving disabled livestock exposed to adverse climate conditions
while awaiting disposition, or:
* otherwise intentionally causing unnecessary pain and suffering to
animals.
If inspectors determine that an egregious humane handling incident has
occurred, they may suspend inspection at the plant immediately,
effectively shutting down the plant's entire operation, and determine
corrective actions with plant management and the district office.
In 2008, after the reported inhumane handling incident in California,
which was at the Westland/Hallmark plant, FSIS expanded its guidance
to include two more examples of egregious actions for which inspectors
may suspend a plant: (1) multiple failed stuns, especially in the
absence of corrective actions, and (2) dismemberment of live animals.
According to FSIS guidance, when FSIS inspectors observe a violation
of HMSA or its implementing regulations and determine that animals are
being injured or treated inhumanely, they are to take both of the
following enforcement actions, which may restrict a facility's ability
to operate:
* Issue a noncompliance report. This report documents the humane
handling violation and the actions needed to correct the deficiency in
cases where the animal may be injured or harmed. Inspectors are also
directed to notify plant management when issuing a noncompliance
report.
* Issue a regulatory control action. Inspectors place a regulatory
control action or a reject tag on a piece of equipment or an area of
the plant that was involved in harming or inhumanely treating an
animal. This tag is used to alert plant management to the need to
quickly respond to violations that they can readily address. The tag
prohibits the use of a particular piece of equipment or area of the
facility until the equipment is made acceptable to the inspector.
When inspectors determine that an egregious humane handling incident
has occurred, in addition to issuing a noncompliance report and
regulatory control action, FSIS may also take the following actions:
* Suspend plant operations. An on-site FSIS supervisor--known as an
inspector-in-charge--can initiate an action to suspend plant
operations when an inspector observes egregious abuse to the animals.
The inspector must document the facts that serve as the basis of the
suspension action in a written memorandum of interview and promptly
provide that information electronically to district officials.
Ultimately, district officials assess the facts supporting the
suspension, take any final action, and notify officials in
headquarters.
* Withdraw the plant's grant of inspection. If the plant fails to
respond to FSIS's concerns about repeated and/or serious violations,
the district offices may decide to withdraw all inspectors. Without
FSIS inspectors on site, the plant's products cannot enter interstate
or foreign commerce. The FSIS Administrator may file a complaint to
withdraw the plant's grant of inspection and if the grant of
inspection is withdrawn, the plant must then reapply for and be
awarded a grant of inspection before it may resume operations.
FSIS employs inspectors at plants and in FSIS districts to help
enforce HMSA and its food safety inspections. In the plant, FSIS
employs inspectors-in-charge, online and offline inspectors, and
relief inspectors. Inspectors-in-charge are the chief inspectors in
the plant and may or may not be veterinarians. These inspectors are
responsible for reporting humane handling activities for each shift,
as well as carrying out food safety responsibilities, and making
enforcement decisions in consultation with district officials when
necessary. Online inspectors are typically assigned specific duties on
the slaughter line, such as inspecting carcasses and animal heads;
however, they may also perform some humane handling inspection duties
as well. Offline inspectors conduct a variety of inspection activities
throughout the plant and may also perform some humane handling
inspection activities. FSIS also employs permanent relief inspectors,
who step in for plant inspectors who are absent for a period of time,
and may also observe humane handling. The plant inspectors and the
inspectors-in-charge are supervised by frontline supervisors, who
oversee multiple plants. Each plant has at least one FSIS veterinarian
who is responsible for examining livestock prior to slaughter and
performing humane handling activities. Some plants may require two
veterinarians, depending on the volume of animals slaughtered at the
plant and the number of operating shifts. Figure 3 provides an
overview of FSIS personnel involved in the enforcement of HMSA.
Figure 3: Key FSIS Inspection Personnel Involved in HMSA Enforcement:
[Refer to PDF for image: illustration]
Top level:
* Office of the FSIS Administrator:
Second level, reporting to the Office of the FSIS Administrator:
* Office of Program Evaluation, Enforcement and Review;
* Office of Field Operations;
* Office of Policy, Program and Employee Development.
Third level, reporting to Office of Field Operations:
* Office of Regulatory Operations.
Fourth level, reporting to Office of Regulatory Operations:
* District office[A];
- District manager;
- Deputy district manager;
- District veterinary medical specialist;
- Resource management analyst.
Fifth level, reporting to District offices:
* Frontline supervisor.
Sixth level, reporting to Frontline supervisor:
* Patrol veterinarian[B];
* Large plant[C];
- Inspector-in-charge;
- Veterinarian;
- Online/offline inspectors;
- Relief inspectors.
Seventh level, reporting to Patrol veterinarian:
* Small plant[C];
- Inspector-in-charge;
- Veterinarian;
- Online/offline inspectors;
- Relief inspectors;
* Very small plant[C];
- Inspector-in-charge;
- Relief inspectors.
Source: GAO analysis of FSIS data.
[A] FSIS has a total of 15 district offices.
[B] Patrol veterinarians typically perform veterinarian duties at
small and very small plants that do not have veterinarians.
[C] Three plants are shown for illustrative purposes only. A frontline
supervisor may supervise more than one plant. According to FSIS
documents, a very small plant has fewer than 10 employees; a small
plant has 10 to 499 employees; and a large plant has 500 or more
employees.
[End of figure]
Although FSIS does not require inspectors to observe the entire
handling and slaughter process during a shift, it requires inspectors-
in-charge to record the amount of time that the FSIS inspectors
collectively devoted to observing humane handling during one shift.
The inspectors-in-charge enter this information into a data tracking
system known as the Humane Activities Tracking System.
At the district level, the DVMS in each of FSIS's 15 districts serves
as the liaison between the district office and headquarters on all
humane handling matters. These employees are directed to visit each
plant within their district over a 12-to 18-month period and review
the humane handling practices at each plant. DVMSs may also coordinate
the verification of humane handling activities and educate plant
inspectors on relevant humane handling information in directives,
notices, and other information from headquarters through the district
office to inspectors in the field.
Industry groups and animal welfare organizations have recently
recommended actions to improve HMSA enforcement. As an expert witness,
in 2008 testimony, Dr. Grandin proposed that FSIS guidance on humane
handling be clearer--especially in determining when humane handling
incidents at slaughter plants should be considered egregious
violations of the HMSA.[Footnote 7] She has also suggested that FSIS
adopt a numerical scoring system--which has been adopted by the
American Meat Institute--to determine how well animals were being
stunned and handled at the plants. The system has different standards
for different species of animal and can be adjusted to fit plants that
slaughter fewer animals. Overall, the system seeks to reduce the
subjective nature of inspections by using objective measures to help
slaughter plants improve their humane handling performance. In
addition, the Humane Society of the United States has proposed a
variety of reforms to strengthen HMSA enforcement, including requiring
FSIS inspectors to observe the entire humane handling and slaughter
process during a shift.
Weaknesses Persist in FSIS's Enforcement, Training and Guidance, and
Data Management:
According to our survey results and analysis of FSIS data, inspectors
have not taken consistent actions to enforce HMSA once they have
identified a violation. These inconsistencies may be due, in part, to
weaknesses in FSIS's guidance and training for key inspection staff.
While FSIS expects its inspectors to use their professional judgment
based on the guidance in deciding enforcement actions, industry and
others are using other tools to assist their efforts to improve humane
handling performance. Furthermore, although FSIS has taken steps to
correct data weaknesses in HMSA reporting that we noted in 2004, it
has not used these data to analyze HMSA enforcement across districts
and plants to identify inconsistent enforcement. For these reasons,
FSIS cannot ensure that it is preventing the abuse of livestock at
slaughter plants or that it is meeting its responsibility to fully
enforce HMSA.
GAO Survey Results and FSIS Data Indicate Inconsistent Enforcement:
According to FSIS officials, inspectors are to use their judgment in
deciding whether to suspend a plant's operations or take the less
stringent enforcement action (that is, issue a noncompliance report
and a regulatory control action) when a humane handling violation
occurs. For example, FSIS guidance is unclear on what constitutes
excessive electrical prodding, such as the number of times an animal
can be prodded before the inspector should consider the prodding to be
excessive and therefore egregious. According to FSIS's guidance, if
the inspector determines that the action was egregious, the inspector
may also choose to suspend plant operations but is not required to do
so.
U.S. meat industry representatives have expressed concerns in
interviews about the inconsistency of HMSA enforcement across
districts. For example, according to American Meat Institute
officials, the inconsistency in HMSA enforcement is the single most
critical issue for the industry; furthermore, one official noted that
a number of the differences in interpretation of HMSA compliance are
related to determining whether or not an animal is sensible after
stunning. In addition, the expert we consulted testified in April 2008
that FSIS inspectors need better training and clear directives to
improve consistency of HMSA enforcement.[Footnote 8]
Our survey results indicate differences in the enforcement actions
that inspectors reported they would take when faced with a humane
handling violation. In our survey, we asked inspectors their views on
electrically prodding over 50 out of 100 animals. Figure 4 shows the
inspectors' responses to questions concerning electrical prodding.
Under FSIS's guidance, inspectors are directed to issue a
noncompliance report and take a regulatory control action in cases of
excessive electrical prodding, but suspension is not required.
However, the expert we consulted told us that she considers these
cases to be egregious humane handling violations that should result in
suspensions. In addition, according to an FSIS training scenario,
electrical prods are never to be used on the anus, eyes, or other
sensitive parts of the animal.
Figure 4: Percentage of Inspectors Identifying Which Enforcement
Action They Would Take for Electrical Prodding:
[Refer to PDF for image: 2 pie-charts]
Electrically prodding most animals:
Regulatory control action: 40%;
Noncompliance report only: 22%;
Suspension: 9%;
None of these: 23%;
Don‘t know: 6%.
Electrically prodding in the rectal area:
Regulatory control action: 35%;
Noncompliance report only: 23%;
Suspension: 32%;
None of these: 7%;
Don‘t know: 3%.
Source: GAO analysis of survey results.
Notes: This figure is based on the following survey question: "Do you
believe that each of the following factors alone generally indicates
that an establishment's action should result in a (1) suspension, (2)
regulatory control action, (3) noncompliance report, or (4) none of
these?" These factors included electrically prodding over 50 of 100
animals within acceptable voltage and electrically prodding one animal
deliberately in the rectal area.
Percentages may not total 100 percent due to rounding.
[End of figure]
As figure 4 shows, 49 percent of the inspectors surveyed reported that
they would either take a regulatory control action, such as placing a
reject tag on a piece of equipment or suspending a plant's operations
for electrical prodding of most animals, and 29 percent reported that
they would take none of these actions or did not know what action to
take for electrical prodding most animals. Furthermore, 67 percent of
the inspectors surveyed reported that they would either take a
regulatory control action or suspend operations for electrical
prodding in the rectal area, and 10 percent reported that they would
take none of these actions or did not know what action to take for
electrical prodding in the rectal area. FSIS regulations prohibit
electrical prodding that the inspector considers to be excessive.
[Footnote 9] FSIS guidance also states that excessive beating or
prodding of ambulatory or nonambulatory disabled animals is egregious
abuse--and may therefore warrant suspension of plant operations. From
inspectors' compliance reports, we identified several specific
incidents in which inspectors did not either take a regulatory control
action or suspend plant operations. For example:
* In 2008, in the Denver district, the FSIS inspector reported
observing a plant employee excessively using an electrical prod as his
primary method to move the cattle--using the prod approximately 55
times to move about 46 head of cattle into the stun box. Cattle
vocalized at least 15 times, which the inspector believed indicated a
high level of stress. The FSIS inspector stated that this incident
constituted excessive use of the electrical prod. As stated in FSIS
guidance, excessive use of an electrical prod is an egregious
violation that calls for the issuance of both a noncompliance report
and a regulatory control action and for which an inspector may suspend
plant operations. In this instance, the inspector stated that he had
issued a noncompliance report. The inspector did not state that he
took a regulatory control action and did not suspend operations at the
plant, as the guidance allows. In the opinion of the expert we
consulted, this was an egregious instance that should have resulted in
a suspension.
* In 2007, in the Minneapolis district, an FSIS inspector reported
observing plant employees using the electrical prods excessively to
move hogs into the stunning chute. The animals became excited, jumping
on top of one another, and vocalizing excessively. From the
noncompliance report, it is unclear what, if any, regulatory actions
were taken. According to FSIS regulations, electrical prods are to be
used as little as possible in order to minimize excitement and injury;
any use of such implements that an inspector considers excessive is
prohibited.
* In 2008, in the Dallas district, the FSIS inspector reported that a
plant employee used an electrical prod to repeatedly shock cows in the
face and neck in an effort to turn them around in an overcrowded area.
The inspector deemed the use of the electrical prod excessive, but the
report does not indicate whether any regulatory control action was
taken.
With regard to stunning, our survey results and review of
noncompliance records also show inconsistent enforcement actions when
humane handling violations occurred. As figure 5 shows, 23 percent of
inspectors reported they would suspend operations, while 38 percent
would issue a regulatory control action for multiple unsuccessful
captive bolt gun stuns. Similarly, 17 percent reported they would
suspend operations for multiple misplaced electrical stuns, and 37
percent would issue a regulatory control action. According to FSIS
guidance, egregious abuses that could result in a plant suspension
include stunning animals and allowing them to regain consciousness and
multiple attempts to stun an animal, especially in the absence of
immediate corrective measures. However, it is unclear when a
suspension is warranted, even if the acts are deemed to be egregious.
FSIS's guidance simply states that an inspector-in-charge may
immediately suspend the plant if there is an egregious humane handling
violation--however, there is no clear directive to do so in guidance.
In the opinion of the expert we consulted, if over 10 percent of the
animals require a second shot or if over 5 percent of pigs had
experienced an improperly placed electrical stun,[Footnote 10] plant
operations should be suspended. FSIS agreed that these incidents are
troubling, and possibly egregious, but did not comment further. Figure
5 shows our survey results on stunning.
Figure 5: Percentage of Inspectors Identifying Which Enforcement
Action They Would Take for Stunning:
[Refer to PDF for image: 2 pie-charts]
Multiple unsuccessful captive bolt stuns:
Regulatory control action: 38%;
Noncompliance report only: 27%;
Suspension: 23%;
None of these: 7%;
Don‘t know: 5%.
Multiple misplaced electrical stuns:
Regulatory control action: 37%;
Noncompliance report only: 34%;
Suspension: 17%;
None of these: 7%;
Don‘t know: 4%.
Source: GAO analysis of survey results.
Notes: This figure is based on survey question 11: "Do you believe
that each of the following factors alone generally indicates that an
establishment's action should result in a (1) suspension, (2)
regulatory control action, (3) noncompliance report, or (4) none of
these?"
Percentages may not total 100 percent due to rounding.
[End of figure]
We also identified several incidents in FSIS's noncompliance reports
in which inspectors did not suspend plant operations or take a
regulatory control action. For example,
* In 2009, in the Raleigh district, a plant employee stunned a bull
twice in the head with a captive bolt, but the bull remained sensible.
Instead of restunning the animal with the captive bolt gun, the
employee then drove a steel instrument used to sharpen knives into the
open hole in the bull's head in an attempt to make the animal
insensible. The bull rose to its feet and vocalized in apparent pain
until it was eventually rendered insensible with a bullet to the head.
FSIS regulations do not recognize this steel instrument as an
acceptable stunning method.[Footnote 11] However the inspector placed
a reject tag on the stun box and cited the incident as egregious in
the noncompliance report but did not suspend operations. In the
opinion of the expert we consulted, this incident was an example of an
egregious HMSA violation that should have resulted in a suspension.
* In 2008, in the Denver district, the inspector reported that the
first attempt to stun a bull with a captive bolt stunner appeared to
misfire, resulting in smoke and the smell of powder and no response by
the bull.[Footnote 12] A second stunning attempt appeared to render
the bull unconscious in the stun box. However, it was followed by a
third stunning attempt while the bull was still in the stun box. The
employee then allowed the bull to roll out into the pit for shackling.
The bull appeared unconscious but still was breathing rhythmically,
indicating that the animal was still sensible. The employee then
entered the pit and stunned the bull again and started conversing with
another employee. The bull once again started breathing rhythmically
while being shackled, a sign that the bull still had not been rendered
insensible to pain as the law requires. In response, the DVMS asked
the employee to stun the bull again, and this stun rendered the bull
unconscious and no longer breathing rhythmically. According to the
report, the plant received a noncompliance report, but no regulatory
control action was taken, as called for by guidance. In the opinion of
our expert consultant, a regulatory control action should have been
taken in this case because of multiple stuns that left the animal
breathing rhythmically.
We also identified several other types of humane handling violations
for which inspectors took inconsistent enforcement actions. For
example, according to FSIS's regulations, animals are not to be moved
from one area to another faster than a normal walking speed, with
minimum excitement and discomfort. A faster speed could result in
animals being driven over each other. Furthermore, animals in a
holding pen are to have access to water and, if held longer than 24
hours, access to food. According to the expert we consulted,
deliberately driving animals over the top of other others and failing
to provide water for animals held over a weekend are egregious humane
handling violations and, in her opinion, these actions should result
in plant suspensions. However, as figure 6 shows, although most
inspectors would take an enforcement action, including a regulatory
control action, for these violations, 40 percent of inspectors
surveyed would suspend plant operations for driving animals over each
other, and 55 percent would suspend plant operations for failing to
provide water over a weekend.
Figure 6: Percentage of Inspectors Identifying Which Enforcement
Action They Would Take for Other Violations:
[Refer to PDF for image: 2 pie-charts]
Driving animals on top of others:
Regulatory control action: 50%;
Noncompliance report only: 9%;
Suspension: 40%;
None of these: 1%;
Don‘t know: 1%.
No water over a weekend:
Regulatory control action: 36%;
Noncompliance report only: 9%;
Suspension: 55%;
None of these: 1%;
Don‘t know: 1%.
Source: GAO analysis of survey results.
Notes: This figure is based on survey question 11: "Do you believe
that each of the following factors alone generally indicates that an
establishment's action should result in a (1) suspension, (2)
regulatory control action, (3) noncompliance report, or (4) none of
these?"
Percentages may not total 100 due to rounding.
[End of figure]
The lack of consistency in enforcement actions is highlighted by
inspectors' responses to our question about when they would suspend
plant operations. According to our survey results, less than one-third
of the inspectors-in-charge in the very small and small plants
reported that they would be likely to suspend plant operations for
multiple incorrect placements of electrical stunners and electrical
prodding of most animals. Inspectors-in-charge at large plants with
more frequently reported plant suspensions had more stringent views on
enforcement actions than those at very small plants. For example,
inspectors-in-charge at large plants more frequently reported
suspensions as the enforcement actions that should be taken compared
with inspectors-in-charge at very small plants. Figure 7 illustrates
three humane handling scenarios in which significant differences were
observed between large and very small plants. For example, large
plants were more likely than very small plants to suspend plant
operations for multiple incorrect electrical stuns, driving animals
over the top of others, and electrically prodding most animals.
Figure 7: Percentage of Inspectors-in-Charge Identifying Suspension as
the Appropriate Enforcement Action, by Plant Size:
[Refer to PDF for image: vertical bar graph]
Multiple misplaced electrical stuns:
Very small plants: 15%;
Small plants: 19%;
Large plants: 32%;
Driving animals over the top of others;
Very small plants: 37%;
Small plants: 42%;
Large plants: 57%.
Electrically prodding most animals;
Very small plants: 7%;
Small plants: 11%;
Large plants: 22%.
Source: GAO analysis of survey results.
Notes: Inspectors-in-charge at large plants more frequently reported
suspensions than inspectors-in-charge at very small plants for 6 out
of the 14 humane handling scenarios presented in our survey. Estimates
by plant size have a margin of error of less than 15 percentage points.
This figure is based on survey question 11: "Do you believe that each
of the following factors alone generally indicates that an
establishment's action should result in a (1) suspension, (2)
regulatory control action, (3) noncompliance report, or (4) none of
these?"
[End of figure]
We found similar indications of inconsistent enforcement across
districts. According to our analysis of FSIS data, from calendar years
2005 through 2007, 10 districts of 15 FSIS districts--responsible for
overseeing 44 percent of all animals slaughtered nationwide--
suspended 35 plants for HMSA violations. The remaining 5 districts--
responsible for overseeing 56 percent of all livestock slaughtered
nationwide--did not suspend any plants.[Footnote 13] For example, the
Des Moines and the Chicago districts, which oversee the first and
second highest volume of livestock slaughtered nationwide,
respectively, were among the 5 districts that had never issued a
suspension until February 2008, according to our analysis.
Before 2008, these five districts issued noncompliance reports,
sometimes with regulatory control actions, such as a reject tag on a
piece of equipment, rather than suspending an entire plant's
operations. For example, in 2007, in the Lawrence district, a hog was
observed walking around the stunning chute grunting and bleeding from
the mouth and forehead. The animal had been stunned improperly, and
plant personnel stated that both stun guns were not working and were
being repaired. Because the plant did not have an operable stun
device, the animal suffered for at least 10 minutes while the plant
repaired the gun. The FSIS inspector applied a reject tag to the
stunning box; stunning operations in the area were halted until the
plant had taken corrective actions, but the record did not state the
amount of time that stunning was stopped. According to FSIS's
guidance, however, stunning animals and then allowing them to regain
consciousness is considered egregious.
Suspensions increased overall following the February 2008
Westland/Hallmark incident in California. For calendar years 2007 and
2008, more than three-quarters of all suspensions were for stun-
related violations for all districts. In the 10 districts that
suspended operations for calendar years 2005 and 2006, over 40 percent
of those suspensions were for stunning violations. (See appendix III
for detailed information on the number of HMSA enforcement actions
over the period we reviewed.) Furthermore, following that incident,
FSIS directed the inspectors to increase the amount of time they
devoted to humane handling by 50 to 100 percent for March through May
2008. FSIS found that, when the amount of time spent on humane
handling was increased, the number of noncompliance reports increased
as well.
The Westland/Hallmark incident highlighted the problems that could
occur when inspection staff inconsistently apply their discretion in
determining which enforcement actions to take for humane handling
violations. According to the USDA Inspector General's 2008 report that
followed the Westland/Hallmark incident, between December 2004 and
February 2008, FSIS inspectors did not write any noncompliance reports
or suspend operations for humane handling violations at the Westland/
Hallmark plant. Nevertheless, FSIS personnel acknowledged that at
least two incidents of humane handling violations had occurred at the
Westland/Hallmark plant during this period, both of which involved
active abuse of animals. Instead of taking an enforcement action, the
inspectors verbally instructed plant personnel to discontinue the
action or practice in question. The report also stated that Westland/
Hallmark had an unusual lack of noncompliance reports and that
inspectors did not believe they should write a noncompliance report if
an observed violation was immediately resolved.
Finally, our analysis of FSIS enforcement data for calendar years 2005
through August 2009 shows that suspensions were not consistently used
to enforce HMSA. Figure 8 shows the total number of suspensions over
the period and reveals that suspensions spiked from a low of 9 in
calendar year 2005 to a high of 98 in 2008--a nearly 11--fold increase
overall--and, as of August 2009, FSIS had suspended operations at 50
plants. Based on our review of the suspension records, it appears that
this spike followed the February 2008 Westland/Hallmark incident.
Also, more than three-quarters of these suspensions resulted from
failure to render at least one animal insensible on the first stun.
From calendar year 2005 through 2008, the number of noncompliance
reports issued for humane handling decreased overall, while the number
of animals slaughtered increased from about 128 million in 2004 to
about 153 million in 2008.
Figure 8: Number of Plant Suspensions Nationwide, Calendar Years 2005
through August 2009:
[Refer to PDF for image: vertical bar graph]
Calendar year: 2005;
Number of suspensions: 9.
Calendar year: 2006;
Number of suspensions: 14.
Calendar year: 2007;
Number of suspensions: 12.
Calendar year: 2008;
Number of suspensions: 97.
Calendar year: 2009[A];
Number of suspensions: 49.
Source: GAO analysis of FSIS data.
[A] Calendar year 2009 data are as of August 2009.
[End of figure]
While we cannot determine the extent to which HMSA violations were
overlooked from FSIS data and inspection reports, we attempted to
determine whether a much higher rate of enforcement actions were taken
on the days that DVMSs conducted their audits for humane handling.
However, according to FSIS officials, the records of DVMS audit visits
are incomplete, and we were therefore unable to conduct a complete
analysis. As a result, we could not fully determine how often DVMSs
conducted humane handling audit visits nor whether there is a higher
rate of enforcement actions on the days that DVMSs conducted their
audits for humane handling. Furthermore, our survey found that 85 to
95 percent of inspectors-in-charge who had taken some type of
enforcement action reported that their immediate supervisor, the DVMS,
and other district management personnel were moderately or very
supportive of their actions.
Weaknesses in Guidance and Training May Contribute to Inconsistent
Enforcement:
We found that incomplete guidance and inadequate training may
contribute to the inconsistent enforcement of HMSA. Specifically,
according to our survey results, inspectors at the plants we surveyed
would like more guidance and training in seven key areas, as figure 9
shows.
Figure 9: Inspectors Identified the Need for Additional Guidance and/
or Training in Seven Key Areas of Humane Handling Enforcement:
[Refer to PDF for image: vertical bar graph]
Animal sensibility: 45%;
Sensible animal on bleed rail: 44%;
Double stunning: 53%;
Beating: 50%;
Electrical prodding: 58%;
Electrical stunning failure: 51%;
Slip and falls: 51%.
Source: GAO analysis of survey results.
Note: This figure is based on survey question 12: "Would additional
guidance and/or training be helpful in the following areas? (1)
determining when an animal is sensible or returning to sensibility;
(2) determining what, if any, action to take for a sensible animal on
the rail; (3) determining what, if any, action to take for double
stunning; (4) determining when the use of a driving instrument or tool
becomes beating; (5) determining whether a specific incidence of
electric prodding requires a suspension, regulatory control action, or
noncompliance report; (6) determining whether electrical stunning of
an animal fails to render and maintain insensibility; and (7)
assessing situations involving slipping and falling."
[End of figure]
Furthermore, an estimated 457 inspectors-in-charge, or those at more
than half the plants surveyed, reported that additional FSIS guidance
or training is needed on whether a specific incident of electrical
prodding requires an enforcement action. In addition, of the 80
inspectors who provided detailed responses to our survey, 15 noted the
need for additional guidance, including clarification on what actions
constitute egregious actions. Similarly, 25 of the 80 inspectors who
provided written comments identified a need for additional training in
several key areas.
With respect to guidance, in 2004, we had recommended that FSIS
establish additional clear, specific, and consistent criteria for
district offices to use when considering whether to take enforcement
actions because of repeat violations.[Footnote 14] FSIS agreed with
this recommendation and delegated to the districts the responsibility
for determining how many repeat violations should result in a
suspension. However, incidents such as those at the Bushway Packing
plant in Vermont suggest that this delegation was not successful. To
date, FSIS has not issued additional guidance.
Operations at this Vermont plant were suspended three times in May,
June, and July 2009 for egregious humane handling violations. Two of
the suspensions were for dragging nonambulatory conscious veal calves
that were about 1-week old. According to a document describing the
third incident, an employee threw a calf from the second tier of a
truck to the first so that the calf landed on its head and side. FSIS
has not issued any guidance to the district offices on how many
suspensions should result in a request for a withdrawal of a grant of
inspection. If specific guidance had been available on when to request
a withdrawal of grant of inspection, the district office might have
decided to request such a withdrawal before the October 2009 incident.
If FSIS ultimately withdrew the grant, it would have required the
plant to reapply for, and be awarded, a grant of inspection license
before it could resume operations.
Regarding training, FSIS relies primarily on "on-the-job" training by
DVMSs--who are directed to visit each plant within their district over
a 12-to 18-month period. In addition, supervisory veterinarians and
inspectors-in-charge provide on-the-job training. FSIS officials we
spoke with said that the on-the-job training needs to be integrated
into a formal training program and that efforts are under way to do
so. FSIS also provides some humane handling training electronically.
For example, in February 2009, all inspectors assigned to slaughter
plants were required to complete a mandatory 1-hour basic humane
handling course online, which the agency can track centrally. FSIS
officials also stated that, since 2005, incoming inspectors have been
required to complete some humane handling training during orientation.
According to FSIS officials we spoke with, the agency has asked the
districts to begin entering data on the completion of other humane
handling courses so that this information can also be tracked
centrally.
Our survey results suggest, however, that even inspectors-in-charge
who had to complete mandatory humane handling training in February
2009 may not have been sufficiently trained. For example, an estimated
449, or 57 percent, of the inspectors-in-charge at the plants we
surveyed from May through July 2009, reported incorrect answers on at
least one of six possible signs of sensibility.[Footnote 15]
Specifically, an estimated 133, or 18 percent, of the inspectors-in-
charge, failed to identify rhythmic breathing as a sign of
sensibility. In addition, in 2004, we had reported that inspectors did
not have the knowledge they needed to take enforcement actions when
appropriate.[Footnote 16] At that time, most of the deputy district
managers, and about one-half of the DVMSs, noted that an overall lack
of knowledge among inspectors about how they should respond to an
observed noncompliance had been a problem in enforcing the HMSA.
Several outside observers have also commented on the need for better
FSIS training.[Footnote 17] Specifically:
* In November 2008, USDA's Office of Inspector General found that FSIS
does not have a formal, structured developmental program and system in
place to ensure that all of its inspection and supervisory staff
receive both formal and on-the-job training to demonstrate that they
possess the competencies essential for FSIS's mission-critical
functions. The Inspector General recommended a structured training and
development program that includes continuing education to provide the
organizational control needed to demonstrate the competency of the
inspection workforce. The Inspector General also stated that the
workforce needs to be certified annually.
* In 2009, the National Academies' Institute of Medicine recommended
testing and improved training, with special emphasis on the quality
and consistency of noncompliance reports for food safety issues.
[Footnote 18] The institute noted that the decision to issue a
noncompliance report is subjective and inspectors' experience levels
and training differ. Supervisory review by inspectors-in-charge may
likewise be variable or subject to bias and, therefore, unreliable.
* In 2009, representatives of the three major industry associations--
the American Meat Institute, the American Association of Meat
Processors, and the National Meat Association--told us that more
training on humane handling is needed for FSIS inspectors.
Specifically, the American Meat Institute identified insensibility as
a critical issue in enforcement and noted that additional training on
the signs of insensibility, such as blinking and the righting reflex,
would be helpful.
* In 2009, the Humane Society of the United States recommended that
FSIS inspectors receive adequate in-person, on-the-ground training so
they can properly assess the conditions and treatment of animals.
FSIS officials stated that it launched a voluntary HMSA training
program for plant employees at small slaughter plants in 2009. These
plants represent the highest humane handling risk, according to FSIS
officials, because plant management may not have sufficient resources
to fully train plant employees on HMSA practices.
FSIS Has Only Recently Begun to Consider Using Additional Tools to
Evaluate HMSA Performance:
In recent years, the meat industry has adopted numerical scoring and
video surveillance to improve plants' humane handling performance
overall. According to FSIS officials, the agency does not require the
use of such objective measures or scoring to aid judgment for
enforcement purposes because situations are highly variable, and
inspectors and higher-level officials are to use their judgment in
conjunction with FSIS guidance. However, in December 2009, FSIS
provided DVMSs with guidance on what it characterized as, an objective
system to facilitate determinations of the problems that plants in
their districts need to address.[Footnote 19] Several of the DVMSs we
interviewed acknowledged that they have been using a form of numerical
scoring on their own to assist their efforts in evaluating HSMA
enforcement at the plants.
The numerical scoring system was developed in 1996 by Dr. Grandin to
determine how well animals were being stunned and handled at the
plants. The system has different standards for different species of
animal and can be adjusted to fit plants that slaughter fewer animals.
This system seeks to reduce the subjective nature of inspections and
uses the scoring system to help identify areas in need of improvement.
For example, in a large plant, if more than 5 out of 100 animals were
not rendered insensible on the first stun, the plant would fail the
evaluation. Other standards include the percentage rates for slips and
falls and the number of animals moved by an electrical prod. Once the
plant is aware of the weaknesses, it can consider its options to
improve its humane handling performance, such as repairing equipment
and floors to provide better footing for the animals and targeting
employee training in those specific areas.
The numerical scoring system has been adopted by industry and animal
welfare organizations, as well as one federal agency. At the federal
level, according to agency officials, USDA's Agricultural Marketing
Service uses this system to rate slaughter plants to determine whether
to approve or deny them to provide meat to the National School Lunch
Program. In addition, the American Meat Institute and independent
audit firms employed by restaurant chains, such as Burger King and
McDonald's, have adopted this numerical scoring system to evaluate
humane handling at their associated slaughter plants. According to
industry experts, a publicized humane handling incident at their
plants would potentially damage their business interests. Recently,
the Canadian Food Inspection Agency proposed adoption of numerical
scoring for federally inspected plants in Canada.
FSIS officials have stated that while the numerical scoring system may
be useful in helping plants determine their humane handling
performance; it should not be used to assess compliance with HMSA.
Because the numerical scoring system allows for a certain percentage
of stunning failures, using it would be inconsistent with the HMSA
requirement that all animals must be rendered insensible on the first
blow. However, as we noted earlier, this requirement has not been met
consistently by slaughter plants because of human error, equipment
failures, and animal movement, leaving FSIS to exercise its discretion
in determining which violations require enforcement action.
Video surveillance is another tool being increasingly used by
slaughter plants. Specifically, slaughter plants can hire specialized
video technology companies to record plant operations and audit plant
performance through remote video surveillance and the use of the
American Meat Institute numerical scoring system to assess humane
handling performance at the plant. These video technology companies
can also provide slaughter plant management with continuous feedback
and customized progress reports documenting humane handling
performance at their plants. According to the testimony of one video
surveillance company, this technology helps plant management provide
positive reinforcement to the workers who are performing well and
helps identify workers who may need further training.
In November 2008, the Office of the Inspector General recommended that
FSIS determine whether FSIS-controlled, in-plant video monitoring
would be beneficial in preventing and detecting animal abuses.
However, FSIS officials responded that FSIS-controlled video cameras
would not provide the definitive data needed to support enforcement of
humane handling requirements, as compared with the direct, ongoing and
random verification of humane handling practices at the plants.
[Footnote 20] According to the Humane Society of the United States,
while video surveillance might serve as a supplemental tool, it does
not negate the need for real-time inspectors' observations. According
to our survey results, between 52 to 66 percent of inspectors-in-
charge at large plants reported that video surveillance would be
moderately or very useful in each of the five plant areas. Figure 10
illustrates our survey results on the usefulness of video surveillance
for all plants. FSIS officials recently told us that they are
exploring potential uses of video surveillance, but the agency had not
released any official policy change, as of November 2009.
Figure 10: Percentage of Inspectors-in-Charge Reporting Video
Surveillance as Very or Moderately Useful in Five Plant Areas:
[Refer to PDF for image: multiple vertical bar graph]
Truck unloading area:
Very small plants: 40%;
Small plants: 47%;
Large plants: 66%;
Pens:
Very small plants: 32%;
Small plants: 41%;
Large plants: 57%.
Alleyway/chute to stun box
Very small plants: 33%;
Small plants: 45%;
Large plants: 64%.
Stun box and restrainer:
Very small plants: 29%;
Small plants: 43%;
Large plants: 63%.
Bleed rail:
Very small plants: 21%;
Small plants: 33%;
Large plants: 52%.
Source: GAO analysis of survey results.
Notes: This figure is based on survey question 31: "If FSIS were to
issue regulations addressing the use of video surveillance, how useful
would it be for you to have access to video of each of the following
areas at this establishment (1) stun box and restrainer; (2) the bleed
rail; (4) pens; (5) alleyway/chute to the stun box; and (6) area where
the trucks are unloaded?"
Estimates by plant size have a margin of error of less than 9
percentage points.
[End of figure]
In addition, of 96 inspectors who provided written comments on the
usefulness of video surveillance in our survey, most frequently
reported that video surveillance would facilitate more inspections in
different plant locations and provide a true picture of animal
handling while plant staff do not know that the inspector is watching.
Since video surveillance can provide continuous footage of ongoing
activities in the plant, it may provide evidence regarding alleged
violations when inspectors do not directly observe humane handling.
For example, according to 39 percent of inspectors-in-charge at large
plants, plant staff improved their handling behavior upon the
inspectors' arrival. Furthermore, 25 percent of inspectors-in-charge
at the large plants in our survey reported that plant staff often, or
always, alert each other about inspectors' movements between areas by
radio or whistle, for example.
FSIS Has Not Fully Analyzed Humane Handling Data to Consistently
Enforce HMSA:
Although FSIS collects humane handling data, we found that it is not
fully analyzing and using these data to help ensure more consistent
HMSA enforcement. For example, we found substantial differences in the
range of time devoted to humane handling for large plants that
slaughter market swine when we compared the amount of time devoted to
humane handling activities for plants of similar size and species in
an effort to determine if there were any inconsistencies among
districts. Specifically, out of the six slaughter plants that kill
between 700,000 to 900,000 market swine, the average time that a plant
would devote to humane handling ranged from 1.8 to 9.7 hours per shift
in 2008. For the nine plants that slaughter between 2 and 3 million
market swine, we found that the average amount of time per shift
ranged from 2.7 to 5.2 hours per shift in 2008.
In January 2004, we also reported that FSIS was not adequately
analyzing the narrative found in noncompliance reports. As of November
2009, FSIS headquarters officials told us that they had not begun an
effort to analyze the narratives in noncompliance reports. Instead,
they told us, they rely on district officials to monitor whether plant
inspectors have taken consistent enforcement action for each incident.
Headquarters officials also stated that they only review the
percentage of humane handling activities that are recorded as
noncompliant in an FSIS database, known as the Performance-Based
Inspection System. However, without analyzing the narrative, FSIS
cannot readily provide the reasons for the noncompliance reports--for
example, whether these reports were issued for one or two failed
stuns, which is not uncommon, rather than three or four failed stuns,
which might be considered an egregious violation. Thus, FSIS cannot
easily analyze noncompliance reports across the districts to identify
trends or patterns in plant violations or potential enforcement
inconsistencies across districts.
Also in 2004, we reported that FSIS was not tracking humane handling
activities. In response to the tracking issue, FSIS created the Humane
Activities Tracking System, a database that inspectors use to record
the amount of time they devote to humane handling activities in each
plant. Inspectors are directed to record the total amount of time
devoted to humane handling activities for each plant shift in 15-
minute increments. According to our survey results, inspectors have
differing views on the accuracy of the amount of time recorded in the
tracking system. Specifically, 19 percent reported that the time
recorded in this system was slightly or not at all accurate. However,
45 percent of the inspectors reported that the time was very accurate,
and 36 percent reported that the time was moderately accurate.
Furthermore, of the 93 inspectors who provided written responses
detailing inspectors' views of the reasons for the tracking database's
inaccuracies, 56 pointed out that breaking out activities into 15-
minute increments limited their ability to record their actual time
spent, and 29 stated that humane handling activities are concurrent
with other inspection activities. In addition, 14 responses noted that
supervisors or district offices had placed either a minimum or maximum
on the amount of time that could be charged to humane handling. Also,
several of the DVMSs we interviewed reported that the Humane
Activities Tracking System does not readily produce the types of
reports that are needed to oversee and manage humane handling
activities in their districts. For example, they reported that the
system lacked the capability to readily produce comparative analyses
of similar plants to help identify trends or anomalies across
districts.
FSIS began analyzing data across districts from the Humane Activities
Tracking System in 2008--4 years after it developed the system. Also
in 2008, FSIS established the Data Analysis Integration Group in
headquarters, with staff in the regional field offices to support
district offices' data needs. The group began reporting quarterly on
HMSA enforcement, including the amount of time inspectors have devoted
to HMSA, the number of plants suspended, and the number of
noncompliance reports issued in 2009, although FSIS has not analyzed
the narrative in the noncompliance reports.
FSIS Cannot Fully Identify and Plan Resource Needs for HMSA
Enforcement:
FSIS cannot fully identify trends in its inspection resources--
specifically, funding and staffing--for HMSA enforcement, in part
because it cannot track humane handling inspection funds separately
from the inspection funds spent on other food safety activities.
Furthermore, FSIS does not have a current workforce planning strategy
to guide its efforts to allocate staff to inspection activities,
including humane handling.
FSIS Does Not Track HMSA Enforcement and Other Inspection Funds
Separately:
According to FSIS officials, funds for humane handling come primarily
from two sources: (1) FSIS's general inspection account and (2) the
account used to support the Humane Activities Tracking System. The
general inspection account supports all FSIS inspection activities,
both food safety and other activities, including humane handling
enforcement. Because the same inspectors may carry out these tasks
concurrently, FSIS cannot track humane handling funds separately,
according to FSIS officials.
According to FSIS officials, for the most part, inspectors are to
devote 80 percent of their time to food safety inspection activities
and 20 percent of their time to humane handling inspection and other
activities. However, our analysis of resources shows that this is not
the case. As table 1 shows, we estimated that the percentage of funds
dedicated to HMSA enforcement has been above 1 percent of FSIS's total
annual inspection appropriation, although it rose slightly in 2008,
the year in which suspensions spiked following the 2008
Westland/Hallmark incident in California. While FSIS does not track
humane handling inspection activities separately, FSIS's budget office
estimates the funds needed to carry out these activities. Using FSIS's
budget estimate for HMSA enforcement for fiscal years 2005 through
2008, we estimated the percentage of FSIS's total annual appropriation
for its federal food safety inspection account that would have gone to
HMSA enforcement.[Footnote 21]
Table 1: Total Specified in Annual Appropriations for FSIS
Inspections, Estimated Amount FSIS Dedicated for Humane Handling
Enforcement, and Estimated Percentage of FSIS Annual Inspection
Appropriation for Humane Handling, Fiscal Years 2005 through 2008:
Dollars in millions:
Fiscal year: 2005;
Total amount specified for FSIS inspection in the agency annual
appropriation[A]: $742.3;
Estimated amount of FSIS funds dedicated to humane handling
enforcement: $9.1;
Percentage of FSIS annual appropriation for inspection devoted to
humane handling: 1.23%.
Fiscal year: 2006;
Total amount specified for FSIS inspection in the agency annual
appropriation[A]: $753.3;
Estimated amount of FSIS funds dedicated to humane handling
enforcement: $10.9;
Percentage of FSIS annual appropriation for inspection devoted to
humane handling: 1.45%.
Fiscal year: 2007;
Total amount specified for FSIS inspection in the agency annual
appropriation[A]: [A];
Estimated amount of FSIS funds dedicated to humane handling
enforcement: $10.0;
Percentage of FSIS annual appropriation for inspection devoted to
humane handling: [B].
Fiscal year: 2008;
Total amount specified for FSIS inspection in the agency annual
appropriation[A]: $829.8;
Estimated amount of FSIS funds dedicated to humane handling
enforcement: $12.1;
Percentage of FSIS annual appropriation for inspection devoted to
humane handling: 1.46%.
Sources: GAO's analysis of the Budget of the United States and FSIS
data.
[A] The FSIS inspection fund includes other activities, such as
livestock slaughter, poultry slaughter, processing inspection, egg
inspection, import inspection, in-commerce compliance, district office
activities, and food safety enforcement activities. Congress did not
designate an amount from FSIS's general appropriation for federal food
safety inspection in fiscal year 2007.
[B] Because Congress did not specify an amount for federal food safety
inspection in fiscal year 2007, no percentage of total inspection
activities devoted to humane handling was calculated. Appropriation
amounts come from federal food safety inspection activities specified
in FSIS annual appropriations and do not consider rescissions or
supplemental appropriations.
[End of table]
In contrast to FSIS's inability to track humane handling in its
general inspection fund, FSIS officials noted, the DVMSs--whose
primary responsibility is humane handling activities--have a special
activity code that enables FSIS to track their portion of expenses,
including salaries and travel; however, these expenses represent only
a small portion of the total amount FSIS spends on humane handling
inspection activities.
Although FSIS does not track funds spent on humane handling inspection
activities separately from other inspection activities, it does track
the funds specifically dedicated to supporting the Humane Activities
Tracking System. For fiscal years 2005 through 2009, Congress
designated a total of nearly $13 million specifically for the Humane
Activities Tracking System, and FSIS has spent roughly that amount on
the system, according to our review of FSIS budget data. For fiscal
year 2005 and for fiscal year 2006, FSIS was required to spend the
funding designated for the Humane Activities Tracking System within 2
years of the appropriation. However, beginning with fiscal year 2008,
Congress folded the funding for the Humane Activities Tracking System
into a larger FSIS information technology initiative, and the funding
is available to FSIS until it is expended. As of November 2009, FSIS
had not completed integrating the Humane Activities Tracking System
into the information technology initiative, and FSIS officials could
not provide an estimate of when the agency expected to do so.
FSIS Does Not Have a Long-term Plan for Addressing HMSA Staffing:
Although FSIS cannot directly account for the funding designated for
humane handling activities, Congress in recent years has required FSIS
to devote a minimum amount of full-time equivalent (FTE) staff to
humane handling.[Footnote 22] Accordingly, FSIS estimates the total
number of FTEs devoted to humane handling and reports this information
to Congress every year. FSIS develops this estimate using Humane
Activities Tracking System data on time spent on humane handling
inspection activities and average inspector and veterinarian salaries.
Table 2 shows that FSIS has reported exceeding Congress's minimum FTE
requirements for humane handling enforcement, according to FSIS's
calculation.
Table 2: Minimum Number of FTEs Required by Congress for Humane
Handling Compared with the FTEs Reported by FSIS, Fiscal Years 2005
through 2009:
Fiscal year: 2005;
Minimum congressionally required FTEs for humane handling: 63;
FTEs reported by FSIS: 110.
Fiscal year: 2006;
Minimum congressionally required FTEs for humane handling: 63;
FTEs reported by FSIS: 124.
Fiscal year: 2007;
Minimum congressionally required FTEs for humane handling: [A];
FTEs reported by FSIS: 121.
Fiscal year: 2008;
Minimum congressionally required FTEs for humane handling: 83;
FTEs reported by FSIS: 157.
Fiscal year: 2009;
Minimum congressionally required FTEs for humane handling: 120;
FTEs reported by FSIS: 157.
Sources: GAO's analysis of appropriation acts and FSIS data.
[A] Congress did not specify any FTEs for humane handling enforcement
in fiscal year 2007.
[End of table]
For fiscal year 2010, FSIS officials told us, they planned to use $2
million of their inspection funds to enhance oversight of humane
handling enforcement by hiring 24 inspectors, including both public
health veterinarians and inspectors. FSIS officials planned to
strategically place these additional inspectors at locations where
they are most needed to support humane handling enforcement in
addition to their other food safety responsibilities. FSIS officials
stated that the agency determined staffing needs on the basis of such
factors as the highest number of animals condemned on postmortem, the
number of animals inspected and passed for human consumption, and the
amount of time spent conducting humane handling inspection activities.
In addition, FSIS officials stated that the agency intends to
establish a headquarters-based humane handling coordinator position.
This coordinator will be primarily responsible for consistently
overseeing humane handling activities.
While FSIS has increased its hiring, it has not done so in the context
of an updated strategic workforce plan. Such a plan would help FSIS
align its workforce with its mission and ensure that the agency has
the right people in the right place performing the right work to
achieve the agency's goals. In February 2009, we reported that the
FSIS veterinarian workforce had decreased by nearly 10 percent since
fiscal year 2003 and that the agency had not been fully staffed over
the past decade.[Footnote 23] We reported that, as of fiscal year
2008, FSIS had a 15 percent shortage of veterinarians and the majority
of these veterinarians work for slaughter plants. The FSIS 2007
strategic workforce plan--the most recently available--identifies
specific actions to help the agency address some of the gaps in
recruiting and retaining these mission-critical occupations over time.
However, it does not address specific workforce needs for HMSA
enforcement activities.
FSIS officials stated that workforce planning occurs at the district
level and is determined using regulations that govern the number of
inspectors required at each slaughter plant. According to district
officials, they have discretion in deciding where to deploy relief
inspectors. Therefore, they can deploy these inspectors at plants that
they believe may require more HMSA oversight. However, more than one-
third of the inspectors, who provided written comments in our survey,
noted the need for additional staff or the lack of time to perform
humane handling activities. Furthermore, inspectors at 80 percent of
large plants stated that covering for others' responsibilities because
of leave or vacancies has reduced the time spent on humane handling
activities in those plants. While FSIS officials may need flexibility
at the district level to allocate inspection resources, without an
updated strategic workforce plan, the agency cannot effectively
determine inspection needs across districts and adjust the inspection
workforce to reflect changes in the industry and in FSIS resources.
Although the strategic workforce plan indicates that the agency
performs this assessment annually, FSIS officials acknowledged that
the agency has not updated its strategic workforce plan since 2007. We
recommended in January 2004 that FSIS periodically reassess whether
the level of inspection resources is sufficient to effectively enforce
HMSA. As of November 2009, FSIS officials had told us that they were
in the process of developing a workforce strategy but could not
provide an estimated completion date.
FSIS Does Not Have a Comprehensive Strategy for Enforcing HMSA:
Our body of work on results-oriented management calls for
organizations to identify clearly defined goals that are aligned to
available resources, develop time frames for achieving these goals,
and develop performance metrics for measuring progress in meeting
their goals.
We have recommended that all agencies adopt strategies that include
these key elements. By implementing results-oriented management
principles, agencies demonstrate their efforts to resolve long-
standing management problems that undermine program efficiency and
effectiveness, provide greater accountability for results, and enhance
congressional decision making by providing more objective information
on program performance.[Footnote 24]
Although FSIS has strategic, operational, and performance plans for
its inspection activities, these plans do not specifically address
HMSA enforcement. That is, they do not clearly outline the agency's
goals for enforcing HMSA, identify expected resource needs, specify
time frames, or lay out performance metrics. Specifically, FSIS
Strategic Plan FY 2008 through FY 2013 provides an overview of the
agency's major strategic goals and the means to achieve those goals.
However, this plan does not clearly articulate or list goals related
to HMSA enforcement. Instead, the plan generally addresses agency
goals, such as improving data collection and analysis, maintaining
information technology infrastructure to support agency programs, and
enhancing inspection and enforcement systems overall to protect public
health.
FSIS Office of Field Operations officials agreed that the plan does
not specifically address humane handling, but they explained, the
operational plans and policy performance plans contain the details
concerning humane handling performance. However, as we indicate below,
we did not find that these two plans provide a comprehensive strategy
for HMSA enforcement:
* Office of Field Operations' Operational Plan identifies specific
FSIS projects or initiatives and aligns them with the appropriate
strategic goal identified in the FSIS Strategic Plan for FY 2008
through FY 2013. It also specifies the estimated dates for completion
and recent information on the status of the project or initiative.
According to our analysis of the July 2009 version of the operational
plan, the most recent version available, humane handling activities
fall under FSIS's first strategic goal--enhance inspection and
enforcement systems and operations to protect public health. While the
plan identifies tasks related to humane handling inspection
activities, it does not identify any humane handling program goals
linked to these tasks or explain how these tasks can be completed. For
example, one of the plan's listed tasks is conducting humane handling
information outreach, but the plan neither indicates how this task
aligns with HMSA enforcement-related goals, nor does it specify
resources needed. The plan also does not set priorities for proposed
activities or identify milestones that could be used to measure
progress or make improvements. Additionally, the document does not
match the activities with resources needed to accomplish those tasks.
According to FSIS officials, the Office of Field Operations'
operational plan is an evolving document that is continually updated
throughout the course of the year.
* Office of Policy and Program Development Strategic Plan Fiscal Years
2008-2013 identifies policy goals that support the overall FSIS
Strategic Plan. However, this plan does not clearly articulate or list
goals related to HMSA enforcement.
Furthermore, FSIS does not have a set of performance measures for
assessing the overall performance of humane handling enforcement
across the districts. For example, FSIS is unable to determine whether
the districts have improved their ability to enforce humane handling
or may be weak in their enforcement. Although FSIS officials stated
that the agency collects information such as the number of
noncompliance reports, the number of egregious humane handling
violations, and the number of humane handling activities performed on
a routine basis by the DVMS, there is no indication of how these
activities demonstrate improved enforcement of HMSA. Collecting and
analyzing this type of information could be useful in identifying gaps
or anomalies in performance and then developing a strategy to address
them.
Conclusions:
It is difficult to know whether the reported incidents of egregious
animal handling at the slaughter plants in California and Vermont are
isolated cases or indicative of a more widespread problem. Either way,
it is evident from our survey results and our analysis of HMSA
enforcement data that inspectors did not consistently identify and
take enforcement action for humane handling violations for the period
we reviewed. Furthermore, our survey results suggest that inspectors
are not consistently applying their discretion as to which actions to
take when egregious humane handling incidents occur, or when they are
repeated, in part because the guidance is unclear. That is, the
guidance states that inspectors-in-charge "may" suspend plant
operations. Consequently, plants cited for the same type of humane
handling incident may be subject to different enforcement actions. In
January 2004, we recommended that FSIS establish additional clear,
specific, and consistent criteria for enforcement actions to take when
faced with repeat violations. FSIS responded by delegating this
responsibility to the districts. However, incidents such as those at
the Vermont plant suggest that this delegation has not been effective.
While FSIS has stated that inspectors require discretion in
enforcement, that discretion needs to be informed by an agency policy
that ensures a consistent level of enforcement within plants and
across districts. Without consistent enforcement actions, FSIS does
not clearly signal its commitment to fully enforce HMSA. In addition,
to improve plants' humane handling performance, the Agricultural
Marketing Service, DVMSs, and others have adopted objective industry
tools, such as numerical scoring, to help identify weaknesses.
However, inspectors-in-charge, who are responsible for assessing daily
HMSA performance at the plants, are not directed to use such scoring
tools.
Effective oversight of HMSA enforcement also requires FSIS to use
available data to effectively manage the program, including allocating
resources. FSIS has only recently begun to do so. Until 2009, FSIS did
not routinely track and evaluate HMSA enforcement data--by geographic
location, species, plant size, and history of compliance across
districts. Although these analyses will be useful, FSIS has yet to
analyze the narratives of humane handling incidents found in
noncompliance reports, which would also help the agency identify
weaknesses and trends in enforcement and develop appropriate
strategies. Furthermore, we reiterate our January 2004 recommendation,
which FSIS has not yet acted on, to periodically reassess whether its
estimates still accurately reflect the resources necessary to
effectively enforce the act. Finally, because FSIS does not have a
comprehensive strategy for enforcing HMSA that aligns the agency's
available resources with its mission and goals, and that identifies
time frames for achieving these goals and performance metrics for
meeting its goals, it is not well positioned to improve its ability to
enforce HMSA.
Recommendations for Executive Action:
We are making the following four recommendations to the Secretary of
Agriculture to strengthen the agency's oversight of humane handling
and slaughter methods at federally inspected facilities.
To ensure that FSIS strengthens its enforcement of the Humane Methods
of Slaughter Act of 1978, as amended, we recommend that the Secretary
of Agriculture direct the Administrator of FSIS to take the following
three actions:
* establish clear and specific criteria for when inspectors-in-charge
should suspend plant operations for an egregious HMSA violation and
when they should take enforcement actions because of repeat violations;
* identify some type of objective tool, such as a numerical scoring
mechanism, and instruct all inspectors-in-charge at plants to use this
measure to assist them in evaluating the plants' HMSA performance and
determining what, if any, enforcement actions are warranted; and:
* strengthen the analysis of humane handling data by analyzing the
narrative in noncompliance reports to identify areas that need
improvement.
To ensure that FSIS can demonstrate how efficiently and effectively it
is enforcing HMSA, we recommend that the Secretary of Agriculture
direct the Administrator of FSIS to develop an integrated strategy
that clearly defines goals, identifies resources needed, and
establishes time frames and performance metrics specifically for
enforcing HMSA.
Agency Comments and Our Evaluation:
We provided USDA with a draft of this report for review and comment.
USDA did not state whether it agreed or disagreed with our findings
and recommendations. However, it stated that it plans to use both our
findings and recommendations to help improve efforts to ensure that
establishments comply with HMSA and humane handling regulations. USDA
also recognized the need to improve the inspectors' ability to
identify trends in humane handling violations and work with academia,
industry, and others to identify practices that will achieve more
consistent HMSA enforcement.
USDA commented that the report contained some misstatements of fact
that present a false picture of FSIS's humane handling verification
and enforcement program and policies. We believe that we have fairly
described FSIS policy and guidance on HMSA enforcement. In response to
updated information that FSIS provided, we made appropriate revisions
to clarify certain points. For example, we revised our report by
deleting the portion of our analysis related to suspension data that
occurred on the days that DVMSs conducted humane handling audits
because on the basis of new information provided we believe that FSIS
records of DVMS audit visits are incomplete.
USDA also questioned whether the results of our survey of FSIS
inspectors provide evidence of systemic inconsistencies in
enforcement. We believe they do, and would encourage USDA to consider
the views of inspectors at the plants who are responsible for daily
HMSA enforcement. Our survey results are based on strict adherence to
GAO standards and methodology to ensure the most accurate results
possible. Furthermore, our efforts were fully coordinated with FSIS
before we distributed the survey. Specifically, we vetted all of the
questions with FSIS management in advance to ensure that these
questions elicit responses that would reveal whether or not inspectors-
in-charge understand how to fully enforce HMSA. In addition, we
conducted numerous pre-tests of the survey with inspectors to ensure
that we would receive the most accurate responses possible. We also
coordinated with several humane handling experts who serve as FSIS
consultants on training and enforcement issues to ensure that our
questions would elicit the most accurate responses.
USDA also provided technical comments, which we have incorporated into
this report as appropriate. USDA's written comments and our responses
are presented in appendix IV.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to appropriate congressional committees; the Secretary of Agriculture;
the Director, Office of Management and Budget; and other interested
parties. The report also will be available at no charge on the GAO Web
site at [hyperlink, http://www.gao.gov].
If you or your staff members have any questions about this report,
please contact me at (202) 512-3841 or shamesl@gao.gov. Contact points
for our Offices of Congressional Relations and Public Affairs may be
found on the last page of this report. Key contributors to this report
are listed in appendix V.
Signed by:
Lisa Shames:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
This report examines (1) U.S. Department of Agriculture Food Safety
and Inspection Service's (FSIS) efforts to enforce the Humane Methods
of Slaughter Act of 1978, as amended (HMSA); (2) the extent to which
FSIS tracks recent trends in FSIS inspection resources for enforcing
HMSA; and (3) FSIS's efforts to develop a strategy to guide HMSA
enforcement.
To evaluate FSIS's efforts to enforce HMSA, we interviewed officials
and collected documents from FSIS's Office of Field Operations; Office
of Policy and Program Development; Office of Program Evaluation,
Enforcement and Review; and the 15 district offices. We examined a
nonprobability sample of FSIS noncompliance reports to provide
illustrative examples of humane handling violations. In doing so, we
searched for the words "prod" and "stun" in 533 noncompliance reports
for 2007 and 589 noncompliance reports for 2008. Of these 1,122
reports, 272 reports included either the word "stun" or "prod" in
reference to a violation. We then selected several of the reports that
described violations appearing to be egregious and provided these
reports to the expert we consulted for her assessment. This expert
determined that the violations described in some of these reports were
not sufficiently clear or detailed to determine whether they
represented egregious violations, while others were clearly egregious
in her judgment.
We also reviewed FSIS suspension data, data from the humane handling
tracking system and district veterinary medical specialist reports in
all 15 of FSIS's district offices for fiscal years 2005 through 2009.
To assess the reliability of these data, we examined them for obvious
errors in completeness and accuracy, reviewed existing documentation
about the systems that produced the data, and questioned knowledgeable
officials about the data and systems. We determined that the data were
sufficiently reliable for the purposes of our review, with any
limitations noted in the text. We also reviewed the HMSA enforcement
reports produced by FSIS's Office of Data Analysis and Integration
Group, as well as meeting minutes from the monthly district veterinary
medical conferences. To understand FSIS policy and guidance on humane
slaughter enforcement, we reviewed relevant regulations and FSIS
instructions. From May 2009 through July 2009, we also surveyed
inspectors-in-charge--those responsible for reporting on humane
handling enforcement in the plants--from a random sample of inspectors
at 257 livestock slaughter plants that were stratified by size--very
small, small, and large. We adopted FSIS definition for small, very
small, and large plants. We obtained an overall survey response rate
of 93 percent.[Footnote 25]
Table 3 shows the population and sample size distribution of slaughter
plants by large, small and very small plant size. Each of the
inspectors-in-charge had a nonzero probability of being included, and
that probability could be computed for any inspector-in-charge. Each
inspector-in-charge was subsequently weighted in the analysis to
account statistically for all the members of the population, including
those who were not selected.
Table 3: Universe of Plants and Sample Description:
Plant size: Large;
Number of plants in universe: 63;
Number of plants in sample: 63;
Number of plants with inspectors-in-charge responding: 56;
Percentage response rate: 89%.
Plant size: Small;
Number of plants in universe: 188;
Number of plants in sample: 85;
Number of plants with inspectors-in-charge responding: 75;
Percentage response rate: 89%.
Plant size: Very small;
Number of plants in universe: 531;
Number of plants in sample: 109;
Number of plants with inspectors-in-charge responding: 104;
Percentage response rate: 95%.
Plant size: Total;
Number of plants in universe: 782;
Number of plants in sample: 257;
Number of plants with inspectors-in-charge responding: 235;
Percentage response rate: 93%.
Source: GAO analysis of survey data.
[End of table]
We analyzed all responses, including the written responses that we
received from the survey by conducting a content analysis and
categorizing the responses accordingly. The results of our survey are
presented in a special publication titled Humane Methods of Slaughter
Act: USDA Inspectors' Views on Enforcement that can be viewed at GAO-
10-244SP.
We met with key officials from FSIS's Office of Field Operations who
are responsible for implementing HMSA at the headquarters level. To
understand district officials' perspectives on HMSA enforcement, we
conducted semistructured interviews with each of FSIS's 15 district
veterinary medical specialists (DVMS), 15 district managers, and 15
resource management analysts. We also performed a content analysis on
all semistructured interviews to determine the districts' perspective
on training, guidance, and resources available for humane handling
enforcement. To understand the perspective of animal welfare groups
and the meat industry, we met with representatives from the Humane
Society of the United States, the Animal Welfare Institute, the
American Meat Institute, the National Meat Association, and the
American Association of Meat Processors. We reviewed these
organizations' proposed reforms for HMSA enforcement. We also attended
the 2009 American Meat Institute Humane Handling Conference in Kansas
City, Missouri. To gain a better understanding of how the industry
evaluates HMSA performance, we attended the Professional Animal
Auditor Certification Organization training for meat plants in
Denison, Iowa, in November 2008 and visited pork and beef slaughter
plants that use a numerical scoring system. We also consulted animal
handling expert Dr. Temple Grandin, who is a world-renowned expert on
animal welfare who has served as a consultant to industry and FSIS,
written extensively on modern methods of livestock handling, and
designed slaughter facilities that have helped improve animal welfare
in the United States and in other countries. Dr. Grandin provided her
expert opinion on select humane handling incidents that we identified
as possible HMSA violations. In addition to Dr. Grandin, we also spoke
with animal welfare and food safety consultants to understand key
principles of humane handling techniques and enforcement. We also met
with representatives of the U.S. Department of Agriculture's
Agricultural Marketing Service to understand how the agency uses
numerical scoring to evaluate humane handling at the plants that
provide meat to the National School Lunch Program. In order to
understand FSIS training efforts, we attended an FSIS training seminar
for small and very small plants held in Dallas, Texas, in February
2009, and met with FSIS officials at the agency's Center for Learning
in Washington, D.C., as well as with FSIS consultants who provide
training in HMSA enforcement.
To identify the extent to which FSIS tracks recent trends in
inspection resources for enforcing HMSA, we reviewed FSIS funding and
staffing data for each district. We also conducted semistructured
interviews with resource management analysts in each of FSIS's 15
district offices and interviewed key officials in the Resource
Management and Planning Office within the Office of Field Operations.
We performed a content analysis on all semistructured interviews to
determine each districts' perspective on inspection resources
available for humane handling enforcement. In order to understand how
FSIS reports its annual full-time equivalent staff for humane handling
to Congress, we collected funding and other relevant data and met with
key officials in FSIS's Office of Field Operations and Office of
Management and Office of the General Counsel, as well as the U.S.
Department of Agriculture's Office of Budget and Program Analysis.
To assess FSIS's efforts to develop a strategy to enforce HMSA, we
reviewed relevant FSIS strategies, including the FSIS Strategic Plan
FY 2008 through FY 2013, and the FSIS 2007 Strategic Workforce Plan.
We also reviewed the July 2009 version of the Office of Field
Operations' Operational Plan and the Office of Policy and Program
Development Strategic Plan Fiscal Years 2008-2013. Furthermore, we
reviewed humane handling performance data from the Office of Policy
and Program Development. We met with representatives of the FSIS
Office of Management on human capital issues and officials from the
Office of Personnel Management in Washington, D.C. To identify the key
elements of a strategic plan, we reviewed the Government Performance
and Results Act of 1993, as well as past GAO reports.
We conducted this performance audit for our work from October 2008 to
February 2010, in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit
objectives.
[End of section]
Appendix II: Location of Inspectors Observing HMSA Compliance at
Typical Mid-Sized Plant:
Figure 11 illustrates the areas in a typical, mid-sized plant from
which inspectors can observe HMSA compliance, although inspectors are
not always present in all areas.
Figure 11: Location of Inspectors Observing Compliance with the HMSA
at a Typical Mid-Sized Plant:
[Refer to PDF for image: illustration]
Steps 1-6:
IIC (inspector-in-charge) or FSIS floating inspector monitors the
entire process from the trucks through processing and can move back
and forth along the line.
(1) Antemortem inspection: Veterinarian inspector examines animal
health in the stockyard areas and in the holding pens.
(2) Curved holding chute. Walkways allow the workers and inspectors to
navigate freely through the chute areas.
(3) Round forcing pen with two revolving crowd gates.
(4) Stunning platform.
(5) Animals are hoisted, slaughtered and bled.
(6) Postmortem inspection: FSIS inspectors perform inspections on all
carcasses as they are further processed.
Sources: GAO graphic based on GAO analysis of information provided by
FSIS and Dr. Temple Grandin, a humane handling expert. Photographs in
this figure are used by permission of Dr. Temple Grandin.
[End of figure]
[End of section]
Appendix III: HMSA Suspensions for FSIS Districts:
Figure 12 provides an overview of the percentage of plant suspensions
for HMSA enforcement that occurred in each district for calendar year
2008. The percentages were determined based on the total number of
plants in each districts and the number of reported suspensions. As
the figure illustrates, the Jackson district had the highest
percentage of suspensions.
Figure 12: Percentage of Suspensions by District, Calendar Year 2008:
[Refer to PDF for image: line graph]
District: Alameda, CA;
Percentage of plants suspended: 6.4.
District: Denver, CO;
Percentage of plants suspended: 6.7.
District: Minneapolis, MN;
Percentage of plants suspended: 15.6.
District: Des Moines, IA;
Percentage of plants suspended: 29.6.
District: Lawrence, KS;
Percentage of plants suspended: 9.
District: Springdale, AR;
Percentage of plants suspended: 11.1.
District: Dallas, TX;
Percentage of plants suspended: 22.2.
District: Madison, WI;
Percentage of plants suspended: 10.2.
District: Chicago, IL;
Percentage of plants suspended: 3.5.
District: Philadelphia, PA;
Percentage of plants suspended: 0.9.
District: Albany, NY;
Percentage of plants suspended: 3.6.
District: Beltsville, MD;
Percentage of plants suspended: 2.1.
District: Raleigh, NC;
Percentage of plants suspended: 30.
District: Atlanta, GA;
Percentage of plants suspended: 2.4.
District: Jackson, MS;
Percentage of plants suspended: 55.1.
Source: GAO analysis of FSIS data.
[End of figure]
[End of section]
Appendix IV: Comments from the U.S. Department of Agriculture:
Note: GAO comments supplementing those in the report text appear at
the end of this appendix.
USDA:
United States Department of Agriculture:
Office of the Secretary:
Washington, D.C. 20250:
January 22, 2010:
Lisa Shames:
Director, Natural Resources and Environment:
United States Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Shames:
USDA appreciates the opportunity to comment on the GAO draft report,
"Humane Methods of Slaughter Act: Actions are Needed to Strengthen
Enforcement." We will be providing responses to the audit
recommendations within 60 days of the publication of the report, as is
required by 31 U.S.C. 720.
USDA's Food Safety and Inspection Service (FSIS) enforces the Humane
Methods of Livestock Slaughter Act (HMSA), authorizing the agency to
regulate the handling of livestock prior to slaughter, as well as the
method of slaughter, at establishments. I want to be clear that this
mandate is a high priority for FSIS. Ensuring that livestock are
handled and slaughtered humanely is a responsibility FSIS is committed
to, along with our mission to protect public health. When Congress
passed the HMSA, it found that humane slaughter prevented needless
suffering, resulted in safer and better working conditions for
employees at slaughter establishments, and provided benefits to
producer and consumers through better products and improved flow of
livestock and livestock products. FSIS inspectors are in plants every
day, working to ensure that Congressional intent to require humane
slaughter at every slaughter plant is a priority and is carried out
effectively.
FSIS has worked with the Government Accountability Office (GAO) during
this audit to provide an accurate picture of how the agency enforces
the HMSA. We appreciate this collaboration, and we plan to use both
GAO's findings and recommendations as we improve our efforts to ensure
that establishments comply with this law and our humane handling
regulations. For example, FSIS recognizes the need to improve our
inspectors' ability to identify trends in humane handling violations.
The agency also needs to work with academia, industry, the nonprofit
sector, and animal health experts to identify practices that will
achieve more consistent enforcement of the HMSA.
Actions that FSIS will take in response to this report will build on
the considerable work already being done by FSIS to improve our
performance in verifying humane handling at slaughter establishments.
For example, as highlighted in the GAO report, FSIS will soon fill a
humane handling coordinator position. This senior employee will
provide oversight of inspectors' enforcement and strengthen our
comprehensive strategy for enforcing HMSA, areas that GAO highlights
in this report as needing improvement. In February 2009, FSIS
inspection program personnel assigned to livestock slaughter
establishments were required to complete refresher training on the
Agency's humane handling policies. This training included information
on how to determine insensibility, documenting noncompliance, and
suspending inspection for egregious situations. This training is in
addition to the classroom instruction provided to entry level
employees. FSIS is planning further workforce training activities
related to humane handling for fiscal year 2010.
Recent enforcement also demonstrates the Agency's strong commitment to
enforcing the HMSA. In 2008, FSIS issued a total of 178 suspensions to
federally inspected establishments, 54 percent (97 suspensions) of
which were for humane handling violations witnessed by inspection
personnel. Of these 97 inhumane handling suspensions, 75 were initial
suspensions and 22 were repeat suspensions. In 2009, FSIS issued a
total of 164 suspensions to federally inspected establishments, 53
percent (87 suspensions) of which were for humane handling violations
witnessed by inspection personnel. Of these 87 inhumane handling
suspensions, 71 were initial suspensions and 16 were repeat
suspensions. As noted by GAO in this report, both of these figures
show a significant increase in humane handling enforcement (pages 21
and 22) since the events at Hallmark/Westland. [See comment 1]
While GAO has provided the agency with useful information on how we
might improve our oversight of humane handling and slaughter, this
report also contains numerous substantive misstatements of fact that
we believe warrant your further attention. We believe that these
inaccuracies present a false picture of FSIS humane handling
verification and enforcement programs and policies. In order to
appropriately and accurately identify areas where improvements are
needed in FSIS's oversight of humane handling, we ask that our general
and specific comments below be published in the report. [See comment 2]
General Comments on Themes in the Report Findings:
These are FSIS's comments on themes in findings from the report,
presented roughly in the order the findings first appear. In some
cases, misstatements corrected in FSIS' specific comments are
referenced.
Suspension of Inspection and District Veterinary Medical Specialist
(DVMS) visits:
In the initial summary of findings, on page 22 of the report and
elsewhere, GAO states that 61% of suspensions of inspection related to
humane handling "occurred during DVMSs humane handling audit visits,"
implying that FSIS verification of humane handling is deficient since
DVMSs are directing the majority of suspensions, while spending so
little time in individual establishments themselves. This is
incorrect. Of the 97 suspensions related to humane handling violations
in CY 2008, 84.5% (82 suspensions) were initiated by in-plant
veterinarians or inspection personnel. Only 15.5% (15 suspensions)
occurred during DVMS visits. [See comment 3]
Withdrawal and Suspension of Inspection and the Incident at Bushway
Packing:
The description on page 9 of the process to "withdraw the plant's
grant of inspection" is incorrect. A District office may not simply
decide to withdraw a grant of inspection by withdrawing inspection
program personnel. Although the district manager recommends the filing
of a complaint for withdrawal, per the regulations in 9 CFR 500.6, if
an establishment handles or slaughters livestock inhumanely, only the
FSIS Administrator may file a complaint to withdraw a grant of Federal
inspection in accordance with the Uniform Rules of Practice, 7 CFR
Subtitle A, part 1, subpart H. This correction is included in our
specific comments, but it also informs our following comment on GAO's
discussion of events at Bushway Packing on page 24 of the audit
report. [See comment 4]
On page 24, GAO criticizes FSIS for not issuing "any guidance to the
district offices on how many suspensions should result in a withdrawal
of inspectors" and claims that had the Agency done so, the November
2009 incident of inhumane handling at Bushway might have been
prevented. FSIS does not agree that a fixed number of suspensions
should necessitate a request for withdrawal of the grant of
inspection. The decision to suspend inspection, as well as to request
a withdrawal of the grant of inspection, is based on numerous
qualitative factors and can be made only by weighing all of the
evidence for a specific case. But even if there were such a threshold
for requesting withdrawal, given the legal requirements cited above,
it is not certain that a withdrawal of Bushway's grant of inspection
would have occurred prior to November 2009. [See comment 5]
Also on page 24, on page 40, and elsewhere in the report, GAO
references the Bushway situation in concluding that FSIS's delegation
of humane handling enforcement procedures to district offices "has not
been effective." However, as stated above, suspensions for humane
handling effected by Districts significantly increased during 2008 and
2009; they were in fact approximately twice the number of suspensions
effected for other food safety related reasons.
Adoption of a Scoring System:
On page 11, pages 27-29, and elsewhere in the document, GAO criticizes
FSIS for not adopting a numerical scoring system for verification of
compliance with humane handling requirements. FSIS has, in fact,
provided a scoring tool to its DVMSs, the "Humane Handling and
Slaughter Verification Tool," which was included in FSIS Directive
6910.1, Revision 1, published on December 7, 2009. FSIS has already
conducted DVMS training on the scoring tool in August 2009. FSIS
provided a draft of the tool to GAO during the audit.
The scores in the tool concern various indicators of humane handling,
including stunning efficacy, and are based on industry standards. It
is correct, as GAO points out on page 28 of the report, that the
scoring is not regulatory in nature. Rather, the scores are used as
guidance by the DVMS for discussions with the establishment. FSIS does
not use the scoring alone for enforcement because the scoring, which
allows for stunning failures, is inconsistent with the HMSA
requirements for rendering livestock insensible to pain prior to
slaughter "with a single blow or gunshot" (7 USC 1902(a)). Although it
is true that establishments sometimes fail to stun livestock
effectively with a single blow, FSIS does not enforce requirements
less stringent than those mandated by the HMSA. Instead, FSIS uses its
discretion to enforce in different ways, depending on the severity of
and factors surrounding the stunning violation. In the case of an
observed stunning failure, FSIS inspection program personnel are, at a
minimum, to issue a noncompliance record (FSIS Directive 6900.2,
Revision 2, Parts IV (C) and VI (A) and (B)). [See comment 6]
Strengthen the analysis of humane handling data:
FSIS will be significantly strengthening its analysis of humane
handling data later this year. In an effort to dramatically improve
its data collection and analysis, FSIS will launch the Public Health
Information System (PHIS) later this year. PHIS will enhance FSIS's
data infrastructure through integration of all data streams, including
data collected in the Humane Activities Tracking System (HATS), a
system that FSIS currently uses to document humane handling
verification activities. PHIS will allow us to provide ongoing, real-
time assessment, analysis and surveillance of public health, food
defense, and humane handling data. Once PHIS is implemented, FSIS will
have a critical tool to carry out more effective oversight of humane
handling at livestock slaughter establishments. [See comment 7]
GAO Survey of FSIS Inspection Program Personnel:
GAO draws many of its audit findings from the results of its survey of
FSIS inspection program personnel. FSIS has acknowledged
inconsistencies in enforcement of the humane handling requirements and
plans to examine the GAO survey results as it continues to improve its
humane handling verification and enforcement training and policies.
But, for a number of reasons, FSIS questions whether the survey
results provide evidence of systemic inconsistencies in enforcement,
as suggested by the report. [See comment 8]
Owing to the language of the HMSA and the nature of livestock
slaughter operations, verification and enforcement of humane handling
requirements are activities that require qualitative judgments. The
HMSA does not establish quantitative standards for humane handling and
every livestock slaughter operation is different - in size,
construction, layout, and staffing Some of the survey questions
however, as well as some of GAO's conclusions based on the survey
results, seem to presuppose and depend on a necessary correlation
between frequencies of events and specific regulatory responses. [See
comment 8]
For example, questions 11 and 12 ask inspection program personnel to
state what specific regulatory action they would take (suspension,
regulatory control action, noncompliance record only) in response to
specific frequencies of events, e.g. "Electrically prodding between 26
to 50 of 100 animals within acceptable voltage." Because inspection
program personnel answered these types of questions differently, GAO
concludes that 11MSA enforcement is inconsistent. FSIS counters,
though, that because there are no quantitative statutory requirements
for humane handling and because each livestock slaughter establishment
is unique, the responses show only that inspection program personnel
were answering in the context of their experiences with specific
establishments and livestock slaughter scenarios. Depending on the
situation, any of the three regulatory responses often could be
correct. Additionally, FSIS had not previously provided the potential
frequencies of noncompliance found in the survey to in-plant
personnel. This fact also likely contributed to the highly variable
results. [See comment 9]
Finally, in regard to the GAO survey, it is important to note that the
results show that there is overwhelming consistency among inspection
program personnel responses concerning certain humane handling
situations that require action. The questionnaire shows that
significant percentages of employees consider action necessary in
response to these problem situations. We see this as a starting point
for using the GAO survey results in our efforts to improve HMSA
verification and enforcement. [See comment 9]
Specific Comments:
Although some of our specific comments correct simple misstatements of
fact, many address what FSIS sees as substantive misstatements of FSIS
programs and policies. We believe that these misstatements, when taken
together, create an inaccurate picture of FSIS humane handling
verification and enforcement.
* Page 6 ” The report states that "HMSA exempts only ritual slaughter,
such as kosher and halal slaughter, from the HMSA requirements." This
is incorrect. Under 7 U.S.C. 1902(b), kosher and halal slaughter are
defined as "humane," not exempted from the requirements of the Act.
[See comment 10]
* Page 8 ” The report states that when inspection program personnel
observe a violation of the HMSA they are both to issue a noncompliance
record (NR) and a regulatory control action. This is incorrect. FSIS
Directive 6900.2, Rev 1, section VI (A) (3) directs inspection program
personnel to take a regulatory control action only if "an
establishment fails to adequately respond to an NR or fails to take
its immediate and further preventive actions..." [See comment 11]
* Page 8, bottom -- The sentence above the last bullet incorrectly
describes the regulatory response to an egregious incident of humane
handling. When the inspectors-in-charge (IIC) determines that an
egregious incident has occurred, he or she applies the regulations at
9 CFR 500.3(b) in accordance with the instructions in FSIS Notice 21-
09: "the IIC is to take an appropriate regulatory control action to
prevent continued egregious inhumane handling and orally notify plant
management of an immediate suspension action." [See comment 4]
* Page 9, bullet ” The description of the process for withdrawing a
grant of inspection is incorrect and misleading. A District office may
not simply "decide" to withdraw a grant of inspection by withdrawing
inspection program personnel. Although the district manager recommends
the filing of a complaint for withdrawal, per the regulations in 9 CFR
500.6, if an establishment handles or slaughters livestock inhumanely,
only "The FSIS Administrator may file a complaint to withdraw a grant
of Federal inspection in accordance with the Uniform Rules of
Practice, 7 CFR Subtitle A, part I, subpart H." [See comment 4]
* Page 9 ” In the second sentence, GAO states that IICs "may or may
not be vets." IICs typically are veterinarians, i.e, in all but the
smallest slaughter facilities. Additionally, FSIS does not "certify"
livestock prior to slaughter, as stated in the third to last sentence.
[See comment 12]
* Page 10 -- The chart references a "patrol veterinarian", which is
only applicable to multi-IPPS (in-plant performance system)
assignments. The term is not applicable, as shown, to large plants or
most small plants. [See comment 13]
* Page 12 ” In the incomplete paragraph at the top of the page, GAO
states that FSIS has not used "data to analyze HMSA enforcement across
districts and plants to identify inconsistent enforcement." FSIS
disagrees. In FY09, FSIS issued four quarterly reports on HMSA
enforcement, analyzing FY09 data across Districts. These have been
made available to and discussed with the District Offices during the
monthly DVMS calls. [See comment 14]
* Page 15 -- In the second to last sentence. GAO states that in regard
to suspension of inspection in response to egregious inhumane
handling, "there is no directive to do so in guidance." This is
misleading. FSIS Notice 21-09, which has the same force as an FSIS
Directive and provides specific examples of egregious inhumane
handling, states: [See comment 15]
However, if the observed inhumane treatment is of an egregious nature,
the regulations at 9 CFR 500.3(b) apply. The regulations state, `FSIS
also may impose a suspension without providing the establishment prior
notification because the establishment is handling or slaughtering
animals inhumanely.' Therefore, the IIC is to take an appropriate
regulatory control action to prevent continued egregious inhumane
handling and orally notify plant management of an immediate suspension
action. Next, the IIC is to immediately notify the District Office
(DO) and the DVMS for prompt documentation of the suspension action.
The TIC is also to document the facts that serve as the basis of the
suspension action on a memorandum of interview (M01) (see Attachment
1) and promptly provide that information electronically to the DO and
the DVMS for their use in documenting the Notice of Suspension. The DO
and the DMVS will make an official assessment of the facts supporting
the suspension, take any final action with respect to it, and notify
the Executive Associate for Regulatory Operations designated for the
District.
* Page 22 -- GAO states that 61% of suspensions of inspection related
to humane handling "occurred during DVMSs humane handling audit
visits." This is incorrect. Of the 97 suspensions related to humane
handling violations in CY 2008, 84.5% (82 suspensions) were initiated
by in-plant veterinarians or inspection personnel. Only 15.5% (15
suspensions) occurred during DVMS visits. [See comment 3]
* Page 25 ” In the first full paragraph, discussing the survey results
concerning training, GAO states that 57% of 11Cs reported incorrect
answers on "at least one of six possible signs of sensibility."
However, footnote 17 on the same page 25 states that when GAO queried
the inspection program personnel they "added two [signs] that, alone,
do not generally indicate sensibility." It is unclear, therefore, what
percentage of respondents in fact gave "incorrect answers." GAO's
finding here that inspectors-in-charge "may not have been sufficiently
trained" is thus called into question. [See comment 16]
* Page 26 ” The second bullet concerns a National Academies' Institute
of Medicine study recommending "testing and improved training" for
inspection program personnel. This study was requested by FSIS and
concerned the use of pathogen control indicators in food safety
verification. It is unclear how it is applicable to humane handling
verification activities. [See comment 17]
* Page 31 - In the first full paragraph, GAO implies that FSIS applies
inconsistent amounts of time to humane handling verification in light
of differing slaughter volumes at individual establishments. HMSA
verification is independent of slaughter volume. Compliance is a
function of an establishment's controls and the intensity of
verification corresponds to establishment performance over time. [See
comment 18]
*Pages 33 and 34 ” The table and the narrative reference the "total
amount specified for FSIS inspection in the agency annual
appropriation," and go on to imply that too small a percentage is used
for humane handling verification. The referenced funding for "FSIS
inspection" included livestock slaughter, poultry slaughter, and
processing inspection; egg inspection; import inspection; in-commerce
compliance; district office activities; and food safety enforcement
activities. Since only the portions of the appropriation related to
livestock slaughter inspection would be relevant to humane handling
activity, the GAO conclusion that only "slightly above 1 percent of
FSIS' total inspection appropriations" is related to humane handling
is very misleading. [See comment 19]
* Page 40 ” The first sentence is contrary to the USDA Office of
Inspector General's (OIG) finding concerning the events at
Hallmark/Westland. GAO concludes that it is "difficult to know whether
the reported incidents of egregious animal handling at the slaughter
plants in California and Vermont are isolated cases or indicative of a
more widespread problem." 01G found that "the events that occurred at
Hallmark were not a systemic failure of the inspection
processes/system as designed by FSIS." Given this finding, and the
increased scrutiny paid to humane handling compliance by FSIS since
Hallmark/Westland, it seems unlikely that there is a significant
volume of egregious humane handling violations undetected by FSIS.
[See comment 20]
Sincerely,
Signed by:
Jerold R. Mande:
Deputy Under Secretary for Food Safety:
The following are GAO's comments on the U.S. Department of
Agriculture's letter dated January 22, 2010.
GAO Comments:
1. Our report acknowledges FSIS's efforts to increase its humane
handling enforcement efforts since the events at Westland/Hallmark.
However, FSIS did not provide source material for some of the data in
its comments, making it difficult to determine the completeness and
reliability of the data provided. Therefore we could not include in
the report the data that FSIS provides in its comments.
2. We believe our report provides an accurate picture of FSIS's humane
handling enforcement activities. However, we have modified text in
response to FSIS's technical comments as appropriate or have explained
why we disagree with FSIS's comments, as noted below.
3. We revised the report to reflect the agency's comments by deleting
the portion of our analysis in our draft report that related to the
suspension data that occurred on the days that DVMSs conducted humane
handling audits. The report now states that the recods of DVMS audit
visits are incomplete and that we were unable to conduct the complete
analysis. As a result, we could not fully determine how often DVMSs
conducted humane handling audit visits nor whether there is a higher
rate of enforcement actions on the days that DVMSs conducted their
audits for humane handling. Specifically, our original analysis of the
DVMS visits was based on data that FSIS provided to us during the
course of our review. Based on the information originally provided to
us by FSIS during our audit, these data met all of GAO's data
reliability standards. In January 2010, after receiving a draft copy
of this report for comment, FSIS provided us with revised suspension
data and informed us that the original data it had provided were
incomplete. However, after reviewing the January 2010 data, we believe
the revised data contain incomplete information, and we are therefore
unable to corroborate the DVMS humane handling audit visit data.
4. We modified the report to clarify that the FSIS Administrator may
file a complaint to withdraw a grant of federal inspection.
5. We modified the report to clarify the difference between a
withdrawal of inspectors and a withdrawal of the grant of inspection.
We added that only the FSIS Administrator may file a complaint to
withdraw a grant of federal inspection. However, the district office
can still request such a withdrawal. In 2004, we recommended that FSIS
establish additional, clear, specific and consistent criteria for
district offices to use when considering whether to take enforcement
actions because of repeat violations.[Footnote 26] We continue to
believe that more specific guidance would be valuable to better
address situations such as the one at the Bushway Packing plant in
Vermont. It is also important to note that inspectors need to be
trained to identify what actions may warrant such a request to ensure
that FSIS is fully enforcing HMSA.
6. Although we did not state that numerical scoring is not regulatory
in nature, we did state that using it to measure compliance would be
inconsistent with the HMSA requirement that animals be rendered
insensible to pain on the first blow. However, we believe that FSIS,
in using its enforcement discretion, should identify some type of
objective tool, such as a numerical scoring mechanism, and instruct
all inspectors-in-charge at plants to use this measure to assist them
in evaluating their plants' HMSA performance and determining what, if
any, enforcement actions are necessary in the agency's exercise of its
enforcement discretion.
7. We acknowledge in the report FSIS's efforts to strengthen its
analysis of humane handling data later this year. Although FSIS
officials informed us of plans to implement the Public Health
Information System, we found that those plans have experienced delays,
and the system has yet to be implemented. For example, Public Health
Information System was originally scheduled to be fully functional in
the fall 2009--we now understand that the expected date has shifted to
the end of 2010. Without the availability of this system, we analyzed
the humane handling data that FSIS made available to us during the
course of our review.
8. FSIS questioned whether our survey results provide evidence of
systemic inconsistencies in enforcement. Our survey results are based
on strict adherence to GAO standards and methodology to ensure the
most accurate results possible, as summarized in appendix I of this
report. From May 2009 through July 2009, we surveyed inspectors-in-
charge--those responsible for reporting on humane handling enforcement
in the plants--from a random sample of inspectors at 257 livestock
slaughter plants that were stratified by size--very small, small, and
large. We obtained an overall survey response rate of 93 percent.
[Footnote 27]
9. Concerning FSIS's comment on two of our survey questions, our
survey results showed that 29 percent of the inspectors reported that
they would not take any enforcement action or did not know what
enforcement action to take for electrical prodding of most animals.
Ten percent of the inspectors reported that they would take no
enforcement action or did not know what action to take for electrical
prodding in the rectal area. These figures suggest that FSIS may not
be fully enforcing HMSA. While FSIS states that HMSA enforcement
requires that inspectors make qualitative judgments since each
livestock slaughter operation is unique, we found that humane handling
experts in academia and industry firmly believe that such judgments
need to be based on some type of objective standards, regardless of
the size, construction, layout and staffing at the plants. We
appreciate FSIS's statement that it plans to examine the GAO survey
results as it continues to improve its enforcement training and
policies and urge FSIS to fully use the information in the survey
results to identify practices that may achieve more consistent
enforcement of HMSA.
10.We modified the report to clarify that HMSA exempts ritual
slaughter from the requirement we discuss in the sentences immediately
preceding the text in that section of the report--that an animal be
rendered insensible to pain on the first blow--not to the general HMSA
requirements.
11. Our report is correct as stated. FSIS refers to FSIS Directive
6900.2, Rev. 1, section VI (A) but FSIS does not refer to section VI
(B), which states that if an inspector determines that "a
noncompliance with humane slaughter and handling requirements has
occurred and animals are being injured or treated inhumanely," the
inspector is to take two specific actions: (1) document the
noncompliance on a noncompliance record and (2) take a regulatory
control action. FSIS's misapplication of the directive may further
illustrate the lack of clarity in FSIS policy on humane handling
enforcement, which may contribute to the lack of a clear understanding
at the inspector level.
12. Nearly three-quarters of the inspectors-in-charge responding in
our survey reported that they were not veterinarians. While 100
percent of the IICs at the large plants that we surveyed were
veterinarians, 88 percent of those at very small plants in our
representative survey were not veterinarians, and 57 percent of IICs
at small plants were not veterinarians. In addition, we modified the
text to clarify the responsibility of FSIS veterinarians prior to
slaughter.
13. We modified figure 3 to show that patrol veterinarian only applies
to some small and very small plants.
14. On page 31 of this report, we state that "FSIS began analyzing
data across districts from the Humane Activities Tracking System in
2008--4 years after it developed the system." We also recognize that
the Data Analysis Integration Group began "reporting quarterly on HMSA
enforcement, including the amount of time inspectors have devoted to
HMSA, the number of plants suspended, and the number of noncompliance
reports issued in 2009." In reviewing these reports, however, we found
no analysis indicating that FSIS used these data to evaluate HSMA
enforcement across the districts and plants to identify inconsistent
enforcement. Also, FSIS officials acknowledged in our final meeting in
November 2009, that it has never conducted any analysis of the
noncompliance reports to determine patterns or trends in HMSA
enforcement. Furthermore, although FSIS provided us with its monthly
minutes of its DVMS conference calls from March through September
2009, these minutes did not identify any FSIS analysis of HMSA
enforcement across the districts and possible inconsistent patterns.
FSIS did not grant our request to attend the monthly DVMS conference
calls in order to better understand the nature of the DVMS discussion
and attempt to determine if such analysis was under way.
15. We modified the text to indicate that there is "no clear directive
to do so in guidance." Although regulations and policy documents
describe when suspensions may take place, the agency has offered no
clear directive as to when they should take place.
16. We changed the text to state "six possible signs of sensibility"
to clarify, as noted in footnote 17 (now footnote 15), that the list
of signs included two that, alone, do not generally indicate
sensibility. In addition, we re-checked the coding used in our
analysis to ensure that the calculations were correct. We found no
discrepancies or errors. Therefore, these results clearly demonstrate
that inspectors-in-charge may not have been sufficiently trained.
17. The National Academies' Institute of Medicine study found
weaknesses in the noncompliance reports, and as we stated, the
institute recommended testing and improved training with special
emphasis on the quality and consistency of noncompliance reports for
food safety issues. Because FSIS's inspection personnel are
responsible for completing noncompliance reports for both food safety
and humane handling violations, it is evident that improving training
on the quality and consistency of those reports would be useful in
supporting FSIS humane handling compliance efforts.
18. Our analysis of similar sized plants with similar slaughter
volumes revealed substantial differences in the amount of time devoted
to humane handling in different districts. This information might
better inform FSIS officials to manage resources and/or training to
help improve performance.
19. We disagree. We conducted this analysis in an effort to gain some
perspective on the percent of FSIS annual appropriation for inspection
devoted to humane handling and estimated that it has been above 1
percent of FSIS's total annual inspection appropriation. FSIS
officials informed us that 80 percent of their time should be devoted
to food safety and 20 percent to humane handling inspection and other
activities. Because FSIS cannot track humane handling funds
separately, the agency was unable to provide the amount of funds that
it devotes to humane handling activities. To provide context for the
reader, we estimated the percentage of the total annual inspection
appropriations dedicated to HMSA enforcement. We modified the text to
expand the definition of FSIS inspection fund to include other
activities such as livestock slaughter, poultry slaughter, processing
inspection, egg inspection, import inspection, in-commerce compliance,
district office activities and food safety enforcement activities.
However, this clarification does not change the calculation.
20. We disagree. While the OIG report states that "events that
occurred at Hallmark were not a systemic failure of the inspection
processes/system as designed by FSIS," it is important to note that
its scope was based on observations at 10 cull cow (older and weaker)
slaughter facilities. Nevertheless, the OIG report presented 25
recommendations to strengthen FSIS activities, and FSIS accepted all
of these recommendations. Specifically, OIG recommended that FSIS
needs to "reassess the inhumane handling risks associated with cull
slaughter establishments and determine if more frequent or in-depth
reviews need to be conducted." The report also recommended "that a
structured training and development program, with a continuing
education component, be developed for both its inspection and
management resources." Furthermore, our survey results and analysis of
HMSA enforcement data --that inspectors did not consistently identify
and take enforcement action for humane handling violations for the
period we reviewed--indicate a more widespread problem. Therefore, we
continue to believe that it is difficult to know whether these
incidents are isolated or not, and the extent of such incidents is
difficult to determine because FSIS does not evaluate the narrative in
noncompliance reports.
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Lisa Shames, (202) 512-3841, or shamesl@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, other key contributors to
this report were Thomas M. Cook, Assistant Director; Nanette J.
Barton; Michele E. Lockhart; Beverly A. Peterson; Carol Herrnstadt
Shulman; and Tyra J. Thompson. Important contributions were also made
by Kevin S. Bray, Michele C. Fejfar, Justin Fisher, Carol Henn,
Kirsten Lauber, and Ying Long.
[End of section]
Footnotes:
[1] GAO, Humane Methods of Slaughter Act: USDA Has Addressed Some
Problems but Still Faces Enforcement Challenges, [hyperlink,
http://www.gao.gov/products/GAO-04-247] (Washington, D.C.: Jan. 30,
2004). Also, see GAO, Humane Methods of Handling and Slaughter: Public
Reporting on Violations Can Identify Enforcement Challenges and
Enhance Transparency, [hyperlink,
http://www.gao.gov/products/GAO-08-686T] (Washington, D.C.: Apr. 17,
2008).
[2] U.S. Department of Agriculture, Office of Inspector General, Great
Plains Region, Audit Report: Evaluation of FSIS Management Controls
Over Pre-Slaughter Activities, Report No. 24601-0007KC (November 2008).
[3] All full sample percentage estimates from the survey have margins
of error at the 95 percent confidence level of plus or minus 7
percentage points or less, unless otherwise noted. Percentage
estimates by plant size have margins of error at the 95 percent
confidence level of plus or minus 10 percentage points or less, unless
otherwise noted.
[4] Dr. Grandin has served as a consultant to industry and FSIS,
written extensively on modern methods of livestock handling, and has
designed slaughter facilities that have helped improve animal welfare
in the United States.
[5] A captive bolt gun contains a steel bolt--powered by either
compressed air or a blank cartridge--that is driven into an animal's
brain and then retracted into the gun, which resets the bolt for the
next animal. This gun has the same effect as a gun with live bullets
but is safer than a firearm.
[6] U.S. Department of Agriculture, Food Safety and Inspection
Service, FSIS Notice 12-05, Documentation of Humane Handling
Activities (Feb. 18, 2005).
[7] Dr. Temple Grandin, testimony before the Domestic Policy
Subcommittee, House Committee on Oversight and Government Reform,
"After the Beef Recall: Exploring Greater Transparency in the Meat
Industry" (Washington, D.C: Apr. 17, 2008).
[8] Dr. Temple Grandin, testimony before the Domestic Policy
Subcommittee, House Committee on Oversight and Government Reform,
"After the Beef Recall: Exploring Greater Transparency in the Meat
Industry" (Washington, D.C. Apr. 17, 2008).
[9] C.F.R. § 313.2(b).
[10] Electrical stuns must be properly placed on the animal to ensure
effective stunning; that is, the current must go through the brain.
[11] See 9 C.F.R. §§ 313.5, 313.15, 313.16, 313.30.
[12] The inspector's report did not indicate whether the original
captive bolt stun gun was functioning properly.
[13] These five FSIS districts are Albany, Beltsville, Chicago, Des
Moines, and Lawrence.
[14] [hyperlink, http://www.gao.gov/products/GAO-04-247].
[15] Our survey presented the four signs of sensibility--natural
blinking, lifting head straight up and keeping it up (righting
reflex), rhythmic breathing, and vocalizing--and added two that,
alone, do not generally indicate sensibility--rear leg(s) kicking and
tail moving. In our assessment, if the respondent selected at least
one of the two signs that do not indicate sensibility or if he or she
indicated that they did not know the answer, the respondent's answer
was considered to be incorrect in our calculation.
[16] [hyperlink, http://www.gao.gov/products/GAO-04-247].
[17] In addition, we identified a set of principles to help federal
agencies improve the effectiveness of their training efforts. See GAO,
Human Capital: A Guide for Assessing Strategic Training and
Development Efforts in the Federal Government, [hyperlink,
http://www.gao.gov/products/GAO-04-546G] (Washington, D.C.: Mar. 1,
2004).
[18] Institute of Medicine of the National Academies, Review of the
Use of Process Control Indicators in the FSIS Public Health Risk-Based
Inspection System (Washington, D.C: Mar. 3, 2009).
[19] U.S. Department of Agriculture, Food Safety and Inspection
Service, FSIS Directive 6910.1, Rev. 1, District Veterinary Medical
Specialist Work Methods (Dec. 7, 2009).
[20] U.S. Department of Agriculture, Office of Inspector General,
Great Plains Region, Evaluation of FSIS Management Controls Over Pre-
Slaughter Activities, Report No. 24601-0007KC ( November 2008).
[21] Fiscal year 2008 data were the latest available at the time of
our review.
[22] An FTE generally consists of one or more employed individuals who
collectively complete 2,080 work hours in a given year. Therefore,
either one full-time employee or two half-time employees equal one FTE.
[23] GAO, Veterinarian Workforce: Actions Are Needed to Ensure
Sufficient Capacity for Protecting Public and Animal Health,
[hyperlink, http://www.gao.gov/products/GAO-09-178] (Washington, D.C.:
Feb. 4, 2009).
[24] See GAO, Agency Performance Plans: Examples of Practices that Can
Improve Usefulness to Decisionmakers, [hyperlink,
http://www.gao.gov/products/GAO/GGD/AIMD-99-69] (Washington, D.C.:
Feb. 26, 1999) and GAO, Agencies Strategic Plans Under GPRA: Key
Questions to Facilitate Congressional Review, [hyperlink,
http://www.gao.gov/products/GAO/GGD-10.1.16] (Washington, D.C.: May
1997).
[25] All full sample percentage estimates from the survey have margins
of error at the 95 percent confidence level of plus or minus 7
percentage points or less, unless otherwise noted. Percentage
estimates by plant size have margins of error at the 95 percent
confidence level of plus or minus 10 percentage points or less, unless
otherwise noted.
[26] [hyperlink, http://www.gao.gov/products/GAO-04-24].
[27] All full sample percentage estimates from the survey have margins
of error at the 95 percent confidence level of +/-7 percentage points
or less, unless otherwise noted. Percentage estimates by plant size
have margins of error at the 95 percent confidence level of +/-10
percentage points or less, unless otherwise noted.
[End of section]
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