Notice of Deferral Letter from FSIS to EST. M21069 (April 29, 2013)

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5. Hogs will be monitored for insensibility and additional adjustments will be made to the stun time
to eliminate returning to sensibility.
6. Upper management will conduct a meeting with Stunning personnel on the necessity to take
immediate action (line stoppage) when a hog sensibility issue arises. Company will take
immediate action to control situation.
On Apri126, 2013 you submitted your preventive measures:
Immediate Review:
I) Reviewed Stun Tracking program for operator errors or significant changes in amperage or
voltage. Program evaluates every stun. Stunning log didn't show any outstanding deviations in
the stunning operation in either operator errors or current fluctuations. Reviewed findings with
Management personnel.
2) Reviewed wetting of hogs prior to entering restrainer and wand placement on hogs. Concern was
that the hogs were being over sprayed which could cause random electrical shortage. Slaughter
Management personnel found the hogs were being properly wetted and this concern was
dismissed. Wand placement was also checked. Wand placement was good. Slaughter
Superintendent reviewed the concerns with responsible personnel.
3) Maintenance disassembled, cleaned, reassembled, and tested all 5 sets of stunner wands.
Replaced male plug and head side stunner tip on# I wand. Task was completed on 4/17/13 by
Maintenance personnel.
4) Disassembled both female plugs for stunner wand connections and inspected for moisture,
corrosion, and loose connections. Task was completed on 4/17/13 by Maintenance personnel.
Immediate Corrective Actions:
1) Replaced 16 restrainer slats (Eliminated possible current grounding issue). Task was
completed on 4118/13 by Maintenance personnel.
2) Increased stun dwell time. Dwell time was increased prior to start of stunning operations by
Maintenance personnel on 4/18/13.Stun time was verified through Stun Tracking Program.
Current average dwell time is at 4.5 seconds.
3) Replaced one ofthe stunning control boxes with backup box. Replaced electrical contacts in
box. Back up box was installed on 4/18/13 by Maintenance personnel. Electrical contacts
were replaced by Maintenance personnel on 4/18/13.
4) Installed new wiring from stunning control box to wand's plugs. Replaced cords and female
plugs which connect to stunning wands. Tasks were completed on 4/18/13 by Maintenance
personnel.

5) Modified roller bed on exit end of restrainer. New plastic roller was installed on 4/18/13 by
Maintenance personnel.
6) Ordered and installed a new stunning box to replace existing box. Box was ordered on
4/18/13 and installed on 4/20/13. New box was installed by Maintenance personnel.
The investigation into the occurrence did not provide any one specific failure. As a result, replacement
stunning boxes, new wiring from stunning boxes to stunning cords, new plugs on the stunning wands,
new stunning cords, and replacement restrainer slats were installed. Moving forward PIP will implement
the following ongoing corrective actions to prevent reoccurrence:
l) All Stunning and QA personnel will be re-trained on proper stunning techniques and
determining sensibility of hogs. This training will include Electric Stunning ofPigs and
Sheep (updated Apri12011) and How to Determine Insensibility in Cattle, Pigs, and
Sheep in Slaughter Plants (Revised Nov. 2010) by Temple Grandin, Dept. of Animal
Science, CSU. Documented retraining was completed on 4/26/13. Training records are
available to FSIS for review. Copies of training records will accompany this response.
2) Stunning wands will be completely gone through on a weekly basis to clean or replace any
parts that have become damaged or less effective through use. Actions will be documented on
weekly PM log. Records are available to FSIS personnel upon request. This will be an
ongomg program.
3) Pre-operational testing of stunning system by Maintenance personnel to ensure proper
operation. Maintenance management monitored setup testing and startup of Stunners. This
testing included both stunning boxes. Maintenance management will monitor setup for 2
weeks effective 4/18/13. Setup will be reevaluated at that time. Verification of stunning boxes
pre-operational testing is recorded on Stun Tracking Program located in the QA office. QA
supervisor will review tests for accuracy (99% or higher) and inform Maintenance if
additional testing needs to be performed. These records are stored electronically and available
to FSIS personnel upon request. Management will initial and record any observations or
deviations on a print out of the test stuns.
4) Hourly sensibility audits conducted by QA personnel. Frequency to QA sensibility audits
have been increased from 20 hogs to 30 effective 4/26/13 for 30 days and re-evaluated. These
records are stored in the Production Daily Packets and available to FSIS upon request.
5) Trained personnel in place to apply measures to render animals insensible ifsensibility is
observed. Trained employee is responsible for monitoring the sensibility of each hog on the
bleed rail. Any hog displaying signs of sensibility will be knocked. Number of knocks
conducted in an hourly period will be communicated to QA personnel conducting hourly
sensibility checks. The number of knocks and reason for it will be documented on the
Sensibility Audit form.

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