2) WORKER INJURIES

Violations of humane slaughter regulations not only cause undue suffering to animals but pose serious safety risks to the workers. Workers at IBP-Wallula have reported serious injuries while attempting to skin and remove the legs of live, thrashing cows. This is also documented in the affidavits:

Affidavit #9:

"The live cows cause a lot of injuries in there. I have been injured three times. My most recent injury was about a year ago. I use an air knife for my job. The cow was alive. The supervisor was holding the cow's leg so I could do my job. When the air knife and the cow started to move around, the cow kicked my arm up, and the air knife went into my wrist."

Affidavit #10:

"I got kicked in the jaw by a cow that had been knocked but it was still alive. They had already knocked the cow and it was still alive and it kicked me under the chin. I received seven stitches for that."

Affidavit #16:

"There are accidents because the cows are still alive. At the back hoof, the cow was kicking and it cut off one worker's three fingers. The cows are kicking and jumping and everything. And the company didn't save the fingers, so the worker lost them...."

3) CONTAMINATED MEAT

Processing of conscious animals also diminishes the safety of the meat produced. At current line speeds, neither federal inspectors nor workers can ensure the removal of adulterants.

Affidavit #4:

"It's real hard to do your job because the cows are moving at the same time you're trying to do your job....Sometimes you can't even do your job not only because the cows are alive, but because the chain is running so fast. Even though I'm supposed to trim contaminants, you don't have time to clean all the pus, shit, hair, and dirt off the cows."

Affidavit #2:

"Sometimes when the cows have manure on them and the cows are alive usually it's the supervisor who holds the legs so the workers can do their jobs and the cow

pulls or something and the supervisor has to let go of it, the skin flips around and gets manure off the cow's skin, and you can see that the meat is all green and all dirty from the manure. The meat gets dirty with manure because the skin is dirty and the cows are kicking."

Affidavit #7:

"I see cows with a lot of contamination. A lot of pus. Because the inspector's not watching. And there's a lot of contamination on the floor. All the cows that are passing by, they're getting contaminated too. And then USDA doesn't go out there and watch them anymore...."

There are two reasons that "...USDA doesn't go out there and watch them anymore...." First, in 1998, the USDA implemented an inspection program called Hazard Analysis Critical Control Points (HACCP). HACCP transfers many federal inspection duties from USDA inspectors to corporate quality control personnel. By reducing the authority of inspectors in the plant, and by giving the plant's operator more influence over where inspection activities are conducted, the implementation of HACCP at IBP-Wallula has severely impeded inspectors' ability to ensure compliance with meat safety and, to a greater extent, humane slaughter regulations.

Second, the plant operator recently erected a steel partition on the kill floor which, in effect, seals off the skinning and dismembering areas from the USDA head inspection station. The head inspection station is the station where humane slaughter violations had previously been observed. This completely obstructs USDA inspectors' view of humane slaughter violations.

Affidavit #9:

"Today, it's rare that USDA is in the area. USDA used to stop the line for live cows. Three to four years ago, USDA used to go in and inspect the lines and things. The company is supposed to be supervised by the USDA so everything can go right. But, the USDA and the company kind of made a contract with each other. Before, the USDA would inspect, but now USDA has left it up to IBP...."

Affidavit #17:

"Until two or three years ago, the USDA inspectors stopped the line for live cows. The inspector, if he saw a cow that was still conscious, stopped the chain. But not any more. The USDA is never in the area. Plus, IBP put a metal wall so that inspectors can't see when the cows are alive."

Affidavit #3:

"I've seen a lot of changes in USDA coming back to this area to see what's going on. When I first started, if USDA passed a live beef on the chain, they stopped the chain. But now the company put a piece of metal between where the head inspectors are stationed and where the slaughter takes place.... So now the inspectors don't stop the chain when the live beef pass....I'd estimate that USDA inspectors come back there to look around about once a month."

REQUEST FOR INITIATION OF ENFORCEMENT ACTION

Workers state that the humane slaughter violations described in the attached affidavits have been ongoing at IBP-Wallula for many years, despite their repeated requests to supervisors for corrective action. Indeed, one year ago, workers made information about humane slaughter violations public but neither management nor regulatory authorities took action in response...

Based on the facts and legal arguments set forth above, we request that you initiate an enforcement action against IBP-Wallula to remedy the demonstrated threats to animal welfare and worker safety and to prosecute the company for the demonstrated violations of state and federal requirements. Washington state law provides a variety of remedies and penalties for violations of the humane slaughter and animal cruelty laws, including civil and criminal penalties, and injunctive relief. This is an opportunity for Washington to demonstrate national leadership in addressing irresponsible and illegal activity which hitherto has been largely ignored by the federal government.

We'd like to thank the following organizations who signed onto HFA's petition: