UNITED STATES DEPARTMENT OF AGRICULTURE

PETITION FOR AGENCY ACTION TO FULLY COMPLY WITH THE MANDATES OF THE HUMANE METHODS OF LIVESTOCK SLAUGHTER ACT

Submitted to:

Ann Veneman, Secretary
United States Department of Agriculture
1400 Independence Avenue, S.W.
Washington, D.C. 20250

Submitted by:

People for the Ethical Treatment of Animals, Inc.
Matthew Penzer, Esq., Legal Counsel
501 Front Street
Norfolk, Virginia 23510
(757) 622-7382

December 11, 2001

1. This is a petition for agency action to address the failure of the Secretary of Agriculture (Secretary) to fully implement the mandates of the Humane Methods of Livestock Slaughter Act (Act), 7 U.S.C. §§ 1901-1906. Under the Act, Congress "declared [it] to be the policy of the United States that the slaughtering of livestock and the handling of livestock in connection with slaughter shall be carried out only by humane methods." 7 U.S.C. § 1901 (emphasis added). Animals bred, born, and raised for no other purpose than to ultimately be slaughtered are, from the time they are born, being "handled in connection with slaughter" and, therefore, must be protected for their entire lives by humane handling methods, as required by the Act. PETA, therefore, seeks agency action to designate methods for the humane treatment of livestock handled in connection with slaughter, methods that are applicable from the time the animals are born to the time they are killed, as mandated by the Act.

2. PETA further seeks agency action to address the limited application of the "humane slaughter" mandates of the Act only to those "official" establishments the agency has designated as subject to federal inspection pursuant to the terms of the Federal Meat Inspection Act (the relationship between the two Acts is detailed within this petition). The Humane Methods of Slaughter Act makes no provision for such limited application and so must be applied to the slaughter of livestock at all locations, including those diseased, injured, underweight, or otherwise unhealthy or "unprofitable" animals killed on "farms" and at other livestock facilities. PETA seeks agency action to apply the humane treatment requirements, as mandated by the Act, to the slaughter of all livestock, regardless of the particular location at which they are killed.

3. This petition is filed pursuant to 5 U.S.C. § 553(e) and 7 C.F.R. § 1.28. The petition is submitted to Ann Veneman, who, in her official capacity as Secretary of the United States Department of Agriculture, is responsible for complying with the mandates of the Act.

4. The petitioner, People for the Ethical Treatment of Animals (PETA), is an international nonprofit membership corporation organized under the laws of Virginia, where it is headquartered. PETA is the largest animal rights organization in the world. PETA and its members are committed to eliminating the suffering of animals and ensuring their humane treatment. PETA has conducted investigations into and campaigned extensively on the issue of livestock handling in the agriculture industry, especially on "factory farms," where cruel treatment and needless suffering are so prevalent. PETA has also actively investigated and campaigned against the inhumane slaughter of such animals. In addition to its campaigning activities, PETA actively informs its members and others about, and scrupulously protects, their legal rights. PETA files this petition on its own behalf and on behalf of its members.

A. The Act

5. In the Humane Methods of Livestock Slaughter Act, it is "declared to be the policy of the United States that the slaughtering of livestock and the handling of livestock in connection with slaughter shall be carried out only by humane methods." 7 U.S.C. § 1901 (emphasis added).

6. The Act is designed to, among other things, prevent the needless suffering of livestock. 7 U.S.C. § 1901.

7. With respect to each species of livestock, the Act requires that the Secretary designate methods of "handling in connection with slaughter" that conform to the policy stated in the Act, that is, that comply with humane standards. Such designations are an ongoing obligation of the Secretary. 7 U.S.C. § 1904.

8. However, as of the filing of this petition, the Secretary has failed to designate humane methods for nearly the entire "handling in connection with slaughter" process, thereby leaving cows, pigs, and other livestock animals to suffer miserably for most of their lives, in violation of the Act’s mandate.

9. Livestock bred, born, and raised for slaughter are, from the moment they are born to the moment they are killed, being "handled in connection with slaughter." They are born with the specific intent that they be slaughtered. They are raised with the specific intent that they be slaughtered. They are fattened with the specific intent that they be slaughtered. They are genetically manipulated with the specific intent that they be slaughtered. In short, everything about their existence is done with the specific intent that they be ultimately slaughtered. There is no aspect of their lives that is not geared toward their inevitable slaughter.

10. The only reasonable and lawful interpretation, then, of the Act is that humane handling methods be required for every moment in the lives of livestock bred, born, and raised for slaughter and that humane slaughter methods be applied to the killing of such livestock, whether or not that killing takes place at an "official" slaughterhouse or at a farm. Such application is not only consistent with and, in fact, mandated by the plain language of the Act, which contains no express limitation as to time or location of handling or slaughter, it is the only way to fully ensure the prevention of the needless suffering of livestock.

B. Livestock Suffering and Animal "Handling"

11. Livestock handled in connection with slaughter in this country suffer miserably. Some animals spend nearly their entire lives in total isolation in spaces so small that they are unable to even turn around. Others spend their lives in severely cramped and overcrowded confinement. They are routinely kept in filthy conditions, conditions that include fecal matter caking on their bodies and the floors around them and the burning smell of ammonia that comes from so much urine constantly surrounding them in their poorly ventilated facilities, often resulting in severe respiratory diseases. Many animals are kept indoors in stalls or cages with cement or metal floors, never seeing the sun until the day they are loaded onto trucks to endure long, arduous rides to the slaughterhouse. They are denied all that is natural to them and know only pain and suffering for nearly their entire lives. (Pictures of animals being handled on factory farms and other livestock operations are attached to this petition as Composite Exhibit "A(1)-(12)"; a video of representative footage is attached as Exhibit "B." These exhibits are incorporated as if fully set forth herein.) This suffering is a result of the Secretary’s failure to fully implement the mandates of the Act. Some descriptive examples of livestock suffering—certainly far from an exhaustive list—are detailed in the paragraphs below.

12. Cows, in preparation for their ultimate slaughter, are routinely branded with scorching hot irons (which results in third-degree burns), their nerve-filled horns are cut off (often with crude instruments, such as bolt-cutters), and they are castrated, all without anesthesia.

13. Calves raised for veal are often tied in stalls barely larger than their own bodies and spend weeks in near-total darkness, unable to move freely or turn around. They are fed an intentionally nutrient-deficient liquid diet, which causes chronic diarrhea. After suffering through approximately sixteen weeks of being handled this way, they are removed from their stalls, their sore legs often too painful and swollen from lack of movement to even permit them to walk properly, and are slaughtered.

14. Pigs, also in preparation for their ultimate slaughter, routinely have their tails cut off (the industry’s response to the pigs’ stress-induced behavior of tail-biting), their teeth are cut to prevent them from injuring each other when they become aggressive from overcrowding, "notches" are cut into their ears, and they are castrated, all without anesthesia.

15. Overcrowding pigs is the norm in intensive production operations. In such operations, pigs are kept twenty-four hours a day on slatted concrete or wooden floors above piles of their own waste. In nature, pigs are clean animals (they roll in mud in order to keep the heat and flies off their bodies), and have a keen sense of smell. The stench of ammonia in large production facilities is not only miserable to endure, but often leads to pneumonia and other respiratory ailments, bleeding ulcers, burning and tearing eyes, nosebleeds, tissue and bone mutations, and more. Additionally, the intelligence level of pigs, which is believed to be equal to or greater than that of dogs, makes them particularly vulnerable to psychological suffering.

16. Regarding the transport of livestock animals in connection with slaughter, each year millions of animals are forced to endure grueling conditions. They are often packed into trucks so tightly that there isn’t even room to turn around or lie down. They are exposed to all weather extremes, and it is not uncommon, upon arrival at their final destination, to find animals dead of heat exposure or frozen to the sides of trucks. One PETA campaigner, for example, witnessed a truck in Minnesota that was transporting exposed pigs in near-blizzard conditions (the wind chill was around minus sixty degrees). Another found himself driving behind a two-tiered truck that was transporting cows in searing summer heat. The cows were packed so tightly together that not only could they barely move, but some of the cows were also on the floor pinned beneath others and appeared unable to get up. There were ears, tails, and other body parts pressed so forcefully against the truck walls that they were hanging out through the holes on the side. Such examples represent just a few of the extreme hardships that animals are subjected to while being transported in connection with slaughter.

C. Farm Slaughter

17. In addition to the misery suffered by livestock during the handling process, every year millions of animals are killed by painful, inhumane methods at the farms themselves. Whether it be because they are diseased, injured, underweight, or crippled, or simply because, for whatever reason, it is no longer "cost effective" to keep them alive, livestock are routinely slaughtered at "farming" operations in horrifically cruel ways. Among other methods, these animals are killed with captive-bolt guns (often improperly administered by poorly trained workers with faulty equipment), shot, beaten to death, slammed to the ground, abandoned, and denied veterinary care, and some are even left to suffocate when, still conscious, they are buried beneath a pile of other farm-slaughtered carcasses. Whether it be by these or other methods, it is all too common for animals slaughtered on farms to be killed without regard for their pain or suffering.

18. There is no protection for these farm-slaughtered animals because the mandates of the Act are currently only applied to those "official" establishments that the Secretary has designated as subject to federal inspection under the Federal Meat Inspection Act (FMIA), this despite the fact that the Humane Methods of Livestock Slaughter Act makes no such limitation, but by its language applies to the slaughter of all commercial livestock, which would include those diseased, injured, underweight, or otherwise unhealthy or "unprofitable" animals killed on "farms" and at other livestock facilities. So such limitation is contrary to the mandates of the Act. The Act makes no reference to the location or purpose for which an animal is slaughtered (e.g., an animal slaughtered for human consumption), nor should it, as where an animal is killed or what happens to an animal after death has no impact on the animal’s capacity to suffer while being slaughtered. By its plain language, then, the Act must be applied to all commercial livestock, regardless of the location at which they are slaughtered. Despite the animals’ capacity to suffer, the Secretary has failed to comply with the Act and to ensure that all livestock, including animals slaughtered at farms and at other livestock facilities, are killed only by humane methods.

D. Conclusion

19. Last year alone, the suffering detailed above was endured by, and ended with the deaths of, more than 100 million pigs, 40 million cows and calves, 3.5 million sheep and lambs, and tens of thousands of other species of "livestock" animals. This year, the same ill treatment awaits an equal number of animals. All of this suffering, and much more that has not been specifically set forth (but that has been generally alleged) herein, was needless and resulted from the Secretary’s failure to comply with the Act’s mandates by designating humane methods of treatment.

20. Continuation of the suffering detailed above is inevitable without the full implementation of the mandates of the Act. This is so because industry guidelines are formulated based on "performance" interests rather than "welfare" interests. While it may be the stated policy of the United States that needless suffering be prevented by only handling and slaughtering animals by humane methods, the industry conducts research, continually publishes articles, and implements methods that expose its view of animals as "production machines." The pain and fear involved in such procedures as castration and the cutting off of horns, for example, are measured in terms of performance diminishment, rather than the animals’ suffering. The industry opposed passage of the Act, but its passage was a moral imperative. It is now time to ensure that that moral imperative is fully implemented.

21. The prevention of the needless suffering of livestock can only be fully achieved by applying the Act comprehensively to all phases of the handling and slaughter process. Animals do not develop the capacity to suffer on the day they arrive at the slaughterhouse; they possess that capacity their entire lives. Thus, the only way to ensure that the Act is fully implemented in accordance with its mandates is to apply it to the entire lives of animals that are bred, born, and raised in connection with their ultimate slaughter and to the killing of those animals, regardless of the location at which that killing takes place. Any policy that doesn’t fully apply the Act in this manner is necessarily unreasonable and, thus, unlawful.

22. PETA has conducted investigations of various livestock operations and uncovered and documented a disturbingly high degree of cruelty and suffering that pervades the industry. For example, between October 28, 2000, and January 10, 2001, PETA conducted an undercover investigation of a "pig finisher" facility in Oklahoma, owned by one of the largest pork producers in the country. Among the incidents of suffering as a result of inhumane livestock handling that PETA’s investigation exposed, many of which are included on the video submitted with this petition, were the following:

a) On numerous occasions, pigs were repeatedly beaten with hooked, metal gate rods, causing severe pain and immense suffering to the animals. In one particular instance, the farm manager is documented beating, with great force, a partially crippled pig. The manager continued to beat the pig as the pig frantically dragged himself across the floor in an attempt to escape the pain of the repeated blows to his head.

b) There were repeated instances at the farm of sick, injured, or otherwise debilitated pigs being simply neglected and left to languish unaided until they eventually died. No veterinary care was provided for these animals. On one such occasion, a young crippled pig was left untreated, without food or water, unable to move and in a state of intense suffering for days. Although a farm worker could have humanely relieved her of her suffering when she became too ill to eat and showed signs of lameness two weeks earlier, instead she was ignored, and her condition worsened until her severely emaciated body could no longer support her. She died on the feces- and urine-saturated floor in the exact place where, lame and exhausted, she had fallen several days earlier. (Her suffering is seen in the video footage submitted with this petition, as well as in the photographs marked as Exhibit "A-1.")

c) There were cruel and protracted killings. Some young pigs (weighing forty to sixty pounds) were hoisted over employees’ heads and slammed to the ground. Farm workers were observed using a hammer to bludgeon fully conscious half-grown pigs to death. And, on numerous occasions, workers improperly and inhumanely used a captive-bolt gun in their attempts to kill pigs. Often, the pigs were shot behind the ears rather than on the forehead, as is required in order to ensure that the bolt penetrates the pigs’ brains and immediately stuns the animals. It is apparent that these pigs suffered excruciating pain as a result of the improperly administered shots, as they writhed and screamed until further, properly positioned shots were administered. In an effort to restrain a young pig, two farm workers stood on the rib cage of the weakened, struggling animal. The pig, unable to cry out but obviously experiencing intense pain and fear, gasped desperately for breath under the weight of the two men before they finally killed the animal.

d) Cruel methods of transporting pigs were used throughout the facility. Live pigs were hoisted and dropped over fences and pen gates by farm workers. In some cases, these pigs hit the tops of the gates and flipped over before finally slamming against the ground. The farm manager repeatedly grabbed 120-pound pigs by their ears (which are very sensitive) and flipped them in order to "throw" the animals across a pen, a process which caused great panic, pain, and suffering.

e) On numerous occasions, farm employees attached wire snares to the ears of crippled pigs and dragged the animals for great distances. These pigs squealed in pain and struggled throughout the ordeals, yet no relief was given. Some of these pigs weighed more than 100 pounds.

23. The incidents described above are inhumane, resulted in much pain and suffering to the animals, and represent only a small portion of the barbaric handling procedures and resulting animal suffering that occur in the livestock industry. In an earlier investigation, for example, PETA documented farm workers killing pigs by dropping cement blocks on their heads and an incident in which farm workers beat a pig with a wrench, used a knife to cut her throat (not deep enough to immediately kill her, though), and then sliced the skin off her back as she cried out and writhed in excruciating pain; the conscious animal continued to struggle in vain as a worker continued to torture her by cutting off her leg with a saw. (A portion of this horrific incident is included on the video submitted with this petition.)

24. Because the Secretary has failed to fully comply with the mandates of the Act, livestock animals handled and killed on farms are unprotected from the types of grotesque abuses detailed above, and throughout this complaint, and often suffer their entire lives because of that vulnerability. Even in the most egregious instances of abuse, there is often no consequence for the abuser. PETA is aware of only two instances in which factory farm workers were charged with felonies for cruel animal handling practices—both of which were the result of PETA’s own investigations.

25. One of the reasons why farm workers can, in most circumstances, avoid penalty for acts of hideous cruelty is because, while every state condemns animal cruelty as a criminal act, many states except from prosecution "accepted" or otherwise customary farming practices. Without the Act’s mandated designation of humane handling and killing methods, there are no minimum guidelines to establish what an "acceptable" farming practice is. Farmers are generally free to handle these animals in whatever manner they choose, regardless of the degree of suffering that results, so long as it is claimed to be an acceptable or customary practice. Such unchecked power is intolerable when it results in such widespread suffering. The simple act of designating humane handling and slaughter methods to be universally applied to livestock operations would prevent much of this suffering.

26. PETA has uncovered, and continues to uncover, incidents of cruelty such as those documented within this petition and more. PETA’s investigations have exposed and confirmed the dire need for the designation of such humane methods of slaughter—at whatever location that slaughter takes place—and handling from birth to death, and for immediate agency action to fully implement the mandates of the Act to accomplish this.

27. Designating strong and far-reaching standards for the prevention of needless suffering is in the public interest. Giving the Act its broadest application achieves the maximum benefit, then, for a society that undoubtedly abhors instances of unnecessary animal suffering.

28. Most Americans believe it is wrong to inflict suffering upon animals, even upon animals raised for food. The public knows, for example, that it would be wrong to keep the family cat tied up or otherwise confined for her entire life in her litter box. And yet for calves, pigs, and many other livestock animals, this is exactly the reality of their existence. They are tied or otherwise confined to small, often dark, spaces with poor ventilation and forced to live on slatted floors directly above the overwhelming filth and stench of their massive amounts of feces and urine. Whether these animals are being raised for food or not, most Americans believe this type of suffering is intolerable.

29. That same sentiment has resonated in the halls of the United States Congress. On July 9, 2001, Senator Robert Byrd (D-WV) commented on the extraordinary degree of cruelty within the livestock industry. "Our inhumane treatment of livestock is becoming widespread and more and more barbaric," he said. Among the numerous instances of cruelty he cited was the observation that "(o)n profit-driven factory farms, veal calves are confined to dark wooden crates so small that they are prevented from lying down or scratching themselves. These creatures feel; they know pain. They suffer pain just as we humans suffer pain." 147 Cong. Rec. S7310-12, S7311 (2001).

30. That the Secretary has failed to fully implement the mandates of the Act to prevent such great pain and suffering denies the basic principles of compassion that provided the impetus for the Act’s very creation.

31. Simply put, it is inexcusable and beyond any sense of humanity to ignore the suffering of the millions of livestock animals waiting for protection from inhumane treatment. Regardless of the reason for which they are being raised and handled, they all have the capacity to suffer, and the Secretary must, therefore, take great care to prevent such suffering at every stage of their lives. There is simply no justification for failing to fully implement the mandates of the Act to ensure the complete protection of animals from needless suffering.

A. Scope of the Act Extends to the Farm

32. Congress has already indicated that the scope of the Act extends to the farm and similar livestock "handling" facilities. In the 1996 Farm Bill, Congress included a note to attach to the Act that authorized the Secretary to use available appropriations from that bill to issue guidelines for the humane transport of equines to slaughter, thereby firmly establishing that the slaughter handling process extends all the way to the farm, far beyond the "official" slaughterhouse. H.R. 2854, 104th Cong. §§ 901-905 (1996). Consequently, the reach of the Act’s protections extend all the way to the farm, as well.

33. Thus, Congress’ recognition that the slaughter handling process begins at the farm, and not at the time the animal arrives at the slaughterhouse, supports PETA’s position that animals bred, born, and raised for no other purpose than to ultimately be slaughtered, are from the moment of their births, and throughout their lives on the farm, being handled in connection with slaughter and are, therefore, entitled to the protection from needless suffering mandated by the Act for that entire time.

34. To pick any single day in the lives of these animals and suggest that suddenly they are being handled in connection with slaughter is arbitrary and capricious and ignores the reality of the slaughter industry. On farms, animals are being prepared for slaughter from the day they are born. It is wholly unreasonable to take a position that there is any day in the lives of these animals that differs in any way from the days that preceded it from the perspective of their being handled in connection with their ultimate slaughter. Such a position defies logic.

35. From the perspective of preventing needless suffering, which is the Act’s stated purpose, PETA’s position is, again, the only reasonable interpretation of the Act. Animals have the capacity to suffer from the day they are born. For animals that spend their entire lives in a nearly constant state of suffering, humane handling and slaughter methods provided for the last one or two days of their existence—conditioned upon their surviving the misery of the farm and transport—offer little relief. Such a position is untenable from both a legal and moral perspective for any legislature or agency that claims to be concerned with the prevention of needless suffering. The Act must be implemented to its fullest extent.

36. Although Congress did not authorize appropriations from the 1996 bill to be used to issue guidelines for other species of livestock or poultry, such appropriations limitation does not relieve the Secretary of the responsibility to comply with the Act’s express mandate to designate humane methods of slaughter and handling in connection with slaughter "with respect to each species of livestock." 7 U.S.C. § 1904 (emphasis added).

37. Congress noted the needs of equines in the bill relating to their transport. However, cows and pigs, for example, are in just as much need of protection from inhumane treatment during transport as horses and other equines are. Certainly cows and pigs have just as much need as horses to avoid being overcrowded or shocked with electric prods. Cows and pigs have a need not to die from exposure to the extreme elements during transport or to have their skin freeze to the walls of trucks only to be ripped apart from that skin upon arrival at their destinations and thrown onto piles of other dying animals. There is no justification for addressing the transport needs of horses while ignoring those of other species. Every one of those species has the capacity to feel pain and to suffer.

38. And, importantly for this petition, the language of the Act expressly dictates that humane handling methods be designated for every species of livestock, and so it cannot be limited only to horses. There is now no argument but that the Act covers the transport of livestock, and so, in light of this, the Secretary is mandated, pursuant to the Act, to designate humane transport methods for each species of livestock.

39. PETA emphasizes, however, that while the scope of the Act to cover transport is beyond question, it is arbitrary and inconsistent with the Act’s language or purpose to stop there. The reach of the Act clearly extends to the farm, as detailed above. It is worth noting again that these animals are being handled in connection with slaughter and are capable of suffering from the day they are born. The only reasonable interpretation and application of the Act is to designate humane handling and killing methods to prevent needless suffering of animals from birth to death.

C. Inspection

40. There is a distinction to be made between the designation of humane handling and slaughter methods that the Act mandates and the inspection of "official" slaughterhouses for violations of some of those methods. The Federal Meat Inspection Act (FMIA) requires the inspection of official slaughterhouses to monitor for adulterated meat. 21 U.S.C. § 601 et seq. In 1978, the FMIA was amended to permit inspectors to impose penalties for violations of the Humane Methods of Livestock Slaughter Act that occur within such establishments. While this amendment works to provide enforcement for inhumane practices in slaughterhouses, it does not in any way limit Act’s requirement for the designation of humane methods of handling and slaughter without regard to the location at which that handling and slaughter takes place.

41. In analogy, if there was a federal law that prohibited all assaults, without limitation as to location, and another law that stated that customs officers could arrest anyone who commits an assault within a customs facility, that would provide one aspect of enforcement to the assault law but wouldn’t mean that the assault law was then only to be applied to customs facilities. Similarly, the Act contains no language that would limit its application only to federally inspected slaughterhouses. So, while the FMIA provides an enforcement aspect to violations of the Act that occur within official slaughterhouses, such an aspect cannot be interpreted as a limitation on the application of the Act in general. In other words, application of the Federal Meat Inspection Act is limited by its express terms to federally inspected slaughterhouses; the Humane Methods of Livestock Slaughter Act, however, contains no such limitation, and so must be universally applied.

42. Since its inception in 1980, PETA has continuously fought to expose and relieve the suffering of animals and to ensure their humane treatment, including during those situations where animals are slaughtered and handled in connection with slaughter. PETA is recognized across the country and throughout the world as an organization dedicated to the protection and advancement of the rights of its members and its constituents, the animals.

43. PETA’s activities to raise awareness of and alleviate the suffering of animals being slaughtered and handled in connection with slaughter on farms and during transport routinely involve, among other things, research, investigations, campaigns and demonstrations, preparation and issuance of educational literature, media interviews, documentation of findings at individual farms, informational Web sites (such as GoVeg.com and CowsAreCool.com), petitions and comments on relevant issues to federal and state government agencies, and more. As part of its efforts, PETA has successfully campaigned against a number of leading food-related companies, for which tens of millions of livestock animals are handled and slaughtered annually under cruel and inhumane conditions.

44. PETA has engaged in, and continues to engage in, investigations of specific allegations of cruelty to animals, including in livestock operations and, where remedies are available, takes action against those operations. PETA is limited, however, in its ability to remedy the livestock abuses revealed by its own investigations or by complaints from its members or the public because of the Secretary’s failure to fully implement the Act, which denies PETA the ability to petition the government pursuant to the Act for redress of the injuries to the organization, its members, and the animals.

45. Additionally, by failing to fully designate humane methods of slaughter and handling in connection with slaughter, the Secretary has denied PETA and its members their rights to review such methods and comment on them.

46. Much of the resources PETA utilizes in order to investigate, expose, and remedy situations of livestock suffering are incurred as a direct result of the Secretary’s failure to fully implement the protection measures required by the Act. Because the animals are not receiving the humane safeguards to which they are entitled by law, PETA must seek those safeguards for them.

47. PETA is filing this petition on behalf of itself and on behalf of its members, each of whom shares a common interest in the prevention of animal suffering.

For the reasons specified within this petition, PETA requests that the Secretary take agency action in the following respects:

1. Designate and implement humane methods of handling livestock "in connection with slaughter" that prevent needless suffering for the entire lives of animals bred, born, and raised for no other purpose than to be slaughtered.

2. Designate and implement humane methods of slaughtering livestock at all places where livestock are slaughtered, rather than just at those "official" slaughterhouses currently subject to federal inspection.

As detailed throughout this petition, PETA’s requests for agency action are mandated by the plain language of the Act and, once implemented, would give full effect to the Act’s stated purpose, the prevention of needless suffering of animals. Agency action in this regard is long overdue and urgently needed, as animals are suffering every day by the millions as a result of its failure to designate protective guidelines. In light of these circumstances, and on the expectation that the agency will be as concerned about the prevention of needless animal suffering as PETA and the public are, the petitioner requests a response to this petition within ninety days.

Respectfully submitted,

_________________________________________
Matthew Penzer, Esq.
Legal Counsel
People for the Ethical Treatment of Animals, Inc.
501 Front Street
Norfolk, Virgina 23510
(757) 622-7382

December 11, 2001

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