The Animal Welfare Institute, Compassion in World Farming, the Humane Society of the United States, Humane Society Legislative Fund, Humane Society Veterinary Medical Association, and World Animal Protection have jointly petitioned USDA’s Food Safety and Inspection Service (FSIS) for a policy change.

Their petition requests that FSIS conduct rulemaking to require swine slaughter establishments that use carbon dioxide stunning to install video cameras inside their stunning areas. The petition argues that rulemaking is necessary to ensure that pigs are stunned in compliance with the Federal Meat Inspection Act and the Humane Methods of Slaughter Act.

The request is being considered as a petition for policy change under FSIS’ regulations on petitions (9 CFR part 392). The petition has been referred to the Office of Policy and Program Development for review and has been assigned petition number 23-05.

The animal activist groups want FSIS to require slaughter establishments to install video cameras inside gondolas used in carbon dioxide (CO2) gas slaughter systems employed to stun and kill pigs.

They claim that such a requirement is necessary to ensure that the interiors of the gondolas, and all of the pigs inside of the gondolas, can be examined and inspected during stunning or killing so that FSIS inspectors are able to evaluate whether the animals are being slaughtered humanely, as required by law. See 21 U.S.C. § 603(b), requiring inspectors to make “an examination and inspection of the method by which amenable species are slaughtered and carried out only by humane methods.”

According to the petition, the use of CO2 gas for stunning pigs in connection with slaughter has been permitted in the United States for more than a century. Its use for killing pigs for slaughter was authorized by FSIS in 1994.

 USDA data regarding the number of slaughter establishments that use CO2 to stun or kill pigs, and the numbers of pigs stunned and killed, is not publicly available. The petitioners requested this data by asking FSIS, but the agency declined to provide the information.

The petition says It is clear, however, that in the United States today, “CO2 stunning of pigs is the major method that is used in large slaughter plants.”

According to unpublished data from the Pig Improvement Company, the use of CO2 gas to stun pigs has increased dramatically in recent decades. In 1999, CO2 was used to stun 2 percent of all pigs and 2.2 percent of pigs in establishments that slaughtered more than 4,500 pigs per day. By 2020, those numbers had risen to 86.2 percent and 96.2 percent, respectively. Today, according to FSIS enforcement records, at least 32 slaughter plants use CO2 gas slaughter systems.

According to the National Agricultural Statistics Service, in 2020 (the most recent year represented in the Pig Improvement Company report) more than 131 million pigs were slaughtered in the United States. If 86.2 percent of those pigs were slaughtered using CO2 gas, then approximately 113.5 million pigs were stunned or killed using CO2 gas systems in 2020. That figure is several times greater than the combined total number of cattle, calves, and sheep slaughtered in the country in the same year (about 36.4 million).

Because CO2 gas is used to stun and kill such a large number of animals annually, the petitioners argue that it is particularly important to ensure that it is deployed in a manner that is compliant with humane slaughter requirements.

According to the petition, “FSIS must require slaughter establishments to install video cameras inside gondolas to enable plant inspection personnel to observe the stunning or killing of pigs during CO2 gas operations in order to evaluate whether they are slaughtered humanely. “

It goes on to say “As discussed above, the agency has the legal responsibility and obligation to examine and inspect all methods used for slaughter, including the use of CO2 gas. Further, the agency’s own directives and guidelines identify the benefits of using video records to ensure compliance with humane handling and slaughter requirements, and FSIS already recommends that the industry use video surveillance technology.

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