People who manage both large and small meat plants need guidance that is simple and easy to understand. Some of the directives and documents from the US Dept. of Agriculture's (USDA's) Food Safety and Inspection Service (FSIS) are hard for managers and quality assurance employees to understand. A major issue is finding an easy-to-understand definition of a robust systematic approach for humane slaughter compliance.

I recently had the opportunity to talk to Patty Bennett, DVM, who is the Humane Handling Enforcement Officer for USDA/FSIS. We were on a conference call during the 2017 North American Meat Institute's Animal Welfare Committee Meeting. I asked her to give me the definition of a robust systematic approach in plain, simple language that a plant manager could easily understand. After our discussion, the definition could be boiled down to six major points. The fust three points are clearly outlined in the document titled "FSIS Compliance Guide for a Systematic Approach to the Human Handling of Livestock." The last three points she indeed, outlined in plain, easy-to-understand language.

1. Written procedures are required for a robust systematic approach. The written procedures must describe both the operating procedures and the actions that will be taken if there is a failure.

2. Written records are required. These records would contain the written procedures. They would also contain corrective actions and plant internal audits.

3. FSIS review. Records would be shared with the FSIS upon request.

The above three items are "straight from the book." The last three items are paraphrased from notes from my conversation with Dr. Bennett:

1. The written program must match actual operations in the plant. My interpretation of that is: The system is not robust if plant operations are not reflecting the written document.

2. Does it work? There is a need for constant monitoring to determine if the program is working. My interpretation is: Both the internal monitoring methods and records of corrective actions for problems must be include in the written records. This would allow someone who is reviewing the records to determine if procedures are improving or becoming worse.

3. Provide definite ways to fix problems. This is especially relevant if there are re-occuring problems. Explains how problems are fixed.

Dr. Bennett made it clear that a plant can have a robust systematic approach even if it is under an enforcement action.

Additional information is available online www.grandin.com and in the December 2016 column I wrote for MEAT+POULTRY titled: "Taking a robust approach." This column covers a talk given by Lucy Anthenill, DVM inspector, at the 2016 NAMI Animal Care and Handling Conference.

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