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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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