enforCement of federal laW in foreign Plants slaughter conditions and procedures. Three of the deficiencies were cited in the body of the 2004-2005 audits and four were noted as having occurred during previous audits conducted in the years 2000 through 2003. No humane deficiencies whatsoever were noted in 33 foreign country audits conducted in 2006 and 2007. Following are the foreign country humane handling and slaughter deficiencies cited by the FSIS in its 2004-2005 audit reports (some deficiencies occurred in previous years, as noted in the paragraph above): Brazil—At one establishment, no water was provided to animals held in the suspect pen (August 2003 audit). 178 Costa Rica—In the animal holding pen at one establishment, a one-foot high cement barrier was identified as a potential trip hazard for animals (June 2004 audit); no water was provided to animals in holding pens at two establishments (September 2003 audit). 179 Honduras—In one of two establishments, the holding pen for cattle had numerous bolts protruding from the wall into the pen, presenting a potential safety hazard to animals (October 2005 audit). 180 Mexico—For two of three cattle observed, more than one application of the captive bolt device was required to render the animals insensible (November 2004 audit). 181 Poland—In one establishment, hogs were not properly stunned prior to being shackled, hoisted, thrown or cut (November to December 2003 audit). 182 Slovakia—In one establishment, hogs were not properly stunned prior to being shackled, hoisted, thrown or cut (June 2000 audit). 183 The small number of cited deficiencies of humane standards compared with the far larger number cited for food safety suggests that either foreign certified establishments are much better at animal welfare than they are at food safety, or that the FSIS makes little effort to observe and/or cite humane conditions and procedures. When the FSIS Office of International Affairs was questioned regarding the small number of deficiencies cited 178 USDA-FSIS, Office of International Affairs, Final report of an audit carried out in Brazil covering Brazil’s meat inspection system, August 26 to September 28, 2004. (http://www.fsis.usda.gov/OPPDE/FAR/Brazil/ Brazil2004.pdf) 179 Costa Rica also cited for one establishment found to be slaughtering non-ambulatory disabled cattle. USDA- FSIS, Office of International Affairs, Final report of an enforcement audit covering Costa Rica’s meat inspection system, June 8 to June 17, 2004. (http://www.fsis.usda.gov/OPPDE/FAR/CostaRica/CostaRica2004.pdf) 180 USDA-FSIS, Office of International Affairs, Final report of an audit carried out in Honduras covering Honduras’ meat inspection system, October 18 to October 28, 2005. (http://www.fsis.usda.gov/OPPDE/FAR/ Honduras/HondurasOct2005.pdf) 181 USDA-FSIS, Office of International Affairs, Final report of an audit carried out in Mexico covering Mexico’s meat inspection system, November 3 to November 18, 2004. (http://www.fsis.usda.gov/OPPDE/FAR/Mexico/ MexicoNov04.pdf) 182 USDA-FSIS, Office of International Affairs, Final report of an enforcement audit covering Poland’s meat inspection system, July 14 to August 6, 2004. (http://www.fsis.usda.gov/OPPDE/FAR/Poland/Poland2004.pdf) 183 USDA-FSIS, Office of International Affairs, Final report of an audit carried out in Slovakia covering Slovakia’s meat inspection system, October 19 to October 25, 2005. (http://www.fsis.usda.gov/OPPDE/FAR/ Slovakia/SlovakiaOct2005.pdf) 61
Crimes Without ConsequenCes in humane handling and slaughter, it responded that this finding “indicates a high level of compliance in foreign plants.” 184 However, it seems unlikely that foreign plants found to be grossly lacking in terms of food safety would be competent in the area of humane handling. The fact that FSIS does not even question foreign countries about humane standards during the eligibility determination process reinforces the perception that animal welfare is, in fact, a low priority for the agency. 184 Personal communication from Karen Stuck. 62