October 27, 2010
Docket Clerk, U.S. Department of Agriculture,
FSIS, Room 2-2127, George Washington Carver Center,
5601 Sunnyside Avenue, Mailstop 5272,
Beltsville, MD 20705-5474
Draft compliance guidelines for use of video….docket number FSIS-2010-0016
Comments
The long awaited guidelines fail to adequately address the core issue: humane animal handling. However, electronic monitoring is no assurance the establishment intends to meet requirements for humane handling because management is free to direct otherwise. Crimes Without Consequences is testament to that freedom.
The Inspector General suggests a numerical scoring system, details up to 66 percent of inspectors suggest the use of video surveillance and said inspectors did not consistently identify and take enforcement action for humane handling violations.
FSIS “encourages” use of technology to ensure humane handling but fails to detail sufficient focus and mandate its use. Caught on camera is irrefutable evidence. It should be law and a proposed draft is attached herewith.
Sincerely,
John Winston
Comment from John Winston
This is comment on Notice
Compliance Guides; Availability, etc.: Use of Video or Other Electronic Monitoring or Recording Equipment in Federally Inspected Establishments
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Comment from John Winston
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Comment from John Winston
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