Many people have asked what exactly is a robust systematic approach for humane slaughter. Lucy Anthenill, a DVMS inspector for FSIS/USDA gave a presentation at the NAMI Animal Care and Handling Conference of the items she looks for when she is assessing a plant for humane compliance. There are two basic requirements: 1) a robust systematic approach is similar to a HACCP plan and 2) the FSIS should have access to the records. FSIS regulations and directives do not specify that the plan must be written but both Dr. Anthenill and most plant managers would agree that a written plan is definitely preferred. Dr. Anthenill has visited plants where nobody could find the records for the robust systematic approach. This shows a lack of commitment that their plan is definitely not robust. People in the plant must actually be USING the materials to make the system robust. Each plant should have its own customized system, which is written to follow the actual procedures done in their plant. Copying wording verbatim from the FSIS/USDA website is not recommended. The website does contain much useful information and it can be accessed by typing the following title into Google. FSIS Compliance Guide to a Systematic Approach to Humane Handling of Livestock 2013. Other useful sources of information are www.grandin.com and the AVMA Humane Slaughter Guidelines 2016 edition.

Dr. Antenill outlined the components that a robust approach should have. I have put it into an outline that will make it easier for people who are first developing a program to understand. A robust systematic approach should have two major components which can be kept in separate binders for paper documents or separate sections of an online document. The two sections are your overall written plan and the second section would be your daily, weekly, and monthly inspections of your procedures, along with corrective actions for problems.

Section 1 – (FSIS/USDA Access to this entire section). Written Plan for Robust Systematic Approach.
It is recommended that it should contain the following items.

1. Mission Statement of Goals (USDA/FSIS access) – few sentences, about overall goals.
2. Standard Operating Procedures (FSIS/USDA access) for YOUR plant.  An SOP should be written for the following areas.  Use plain simple language and each SOP may be a few sentences or a short paragraph.

• Unloading trucks.
• Penning in stockyard (lairage)
• Animal driving practices and driving aid use
• Handling and stunning nonambulatory animals
• Stunning – If you routinely shoot animals twice (security stun) state the procedure here.  Describe all stunning instruments both the main stunners and stunners that are used in the yards.  Describe procedures to insure that all signs of brain activity are ABSENT before starting invasive dressing procedures.
• Methods and location of people to determine that the animal is unconscious and insensible.
• Emergency plan for storms, power failures and other problems.  What will you do if you have animals in route? Where will you direct them?
• Living document – When a plant improves a procedure, there should be a record of it.  To make this easier for small plants, you could keep a folder of improvements.  Some examples might be, rubber mat flooring in stun box, a new procedure for handling nonambulatory animals or an additional new gate.  When a plant is completely remodeled or has new construction, it is recommended to write new SOP’

Section 2 – Internal Compliance Documents. (FSIS/USDA has access)

• Training Records (FSIS/USDA access) – State training materials that were used and it should contain dates, employee names, and signatures.  It is strongly recommended that the materials are also available in Spanish unless all employees speak good English.
  
• Stunner Maintenance Records (FSIS/USDA access) – Should have records for BOTH the main stunners and stunners or firearms used for nonambulatory animals and return to sensibility in the bleed area.
• Records of Corrective Actions (FSISUSDA access) – All responses to NR’s NOIE’s and suspensions are recorded.  Also include corrective actions you made to improve a procedure.
• Pre-Op Inspections (FSIS/USDA access) – This would be similar to food safety pre-op inspections that are done to insure equipment is clean.  Daily pre-Op should including the following:
• Walk through of unloading ramps and main drive alleys and chutes for maintenance issues.
• Check location of stunners and cartridges that are used in the yards for nonambulatory animals.  Are they located and ready to use in the manner stated in your SOP?
• Check that both the main stunner and your backup stunners and cartridges are located according to your SOP. Back-up equipment must be immediately available if the main stunner fails.  On pneumatic stunners, also check condition of the balancers and air compressor.
• Operate all the parts of the stun box, restraint box or conveyor restrainer for proper operation, according to your SOP.

Records of Internal Audits (FSIS/USDA Access)
Includes internal audits using NAMI (AMI) guidelines.  If any part of the weekly NAMI audit is failed, there should be a recorded correction action.  Example – high vocalization score was improved by reducing pressure applied by a headholder.  

Records of Outside Audits and video footage (FSIS/USDA access is determined on a case-by-case basis by plant management) – Some examples are customer audits, third party remote video audits and archived video footage.

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