Comment from Julia Braid

The impact of the poultry slaughter inspection proposal on the handling of live birds has not been studied. Increased line speed poses a risk to animal welfare by potentially increasing the incidence of injuries like bruises and fractures, and of birds dying in ways other than by prescribed methods of slaughter (e.g., being drowned in the scalding tank). Fewer USDA inspectors monitoring carcasses means less opportunity for signs that birds have been inhumanely handled to be detected and dealt with properly. The rule change must be rejected or, at a minimum, delayed until the issue of animal welfare can be adequately studied and any potential negative consequences addressed. Please consider allowing a review of the humane implications of this change to your process.