Exhibit A

From: Sidrak, Hany - FSIS

To: (b) (6) @chickenusa.org
Cc: Bronstein, Philip - FSIS
Subject: RE: Chiller Question
Date: Tuesday, April 14, 2020 12:12:23 PM

Hi Ashley - Please see responses below, in red.  Thanks.

 
Hany Sidrak, DVM | Deputy Assistant Administrator | Office of Field Operations |
USDA, FSIS | 1400 Independence Ave. Room 344-E, Whitten Building, DC 20250 |
D e s k : (b) (6) | C e l l : (b) (6)
 
From: Ashley Peterson (b) (6) @chickenusa.org>
Sent: Tuesday, April 14, 2020 11:10 AM
To: Sidrak, Hany - FSIS <hany.sidrak@usda.gov>; Bronstein, Philip - FSIS
<philip.bronstein@usda.gov>
Subject: RE: Chiller Question
 
Thank you, Hany.  I have a few additional questions for you that popped up recently.
 
We are getting reports from different establishments that suggest that there may be a
standard set of questions being asked of plants that have a confirmed COVID employee.  Has
FSIS established a standardized list? Not that I’m aware of.
 
What will the Agency do if they are unable to provide inspection and the industry has birds
waiting in the field? So far, we have not experience this situation.  FSIS will do everything
possible to provide inspection services and we’ve prioritized AM and PM inspection, followed
by FS, then OCP.  The Agency has made employees in other program areas with inspection
background available to cover in-plant inspection positions. Additionally, the Agency has
reached out to other Gov agencies e.g. APHIS, AMS, and State MPI programs to cover FSIS in-
plant inspection positions with employees with meat and poultry inspection background as
needed. 
 
If an FSIS employee is confirmed positive that works on first shift, will second shift IPP also be
impacted if there is no “close contact” between shifts? Don’t think this will be considered
close contact; however, FSIS will follow the local health department decision on these type
situations.
 
We have a few plants who are considering opting into NPIS but are wonder what flexibilities
the Agency can provide so this is a rapid conversion. The districts have been successfully
working with plants requesting conversions to NPIS.  Since April 1, five plants have been
converted to NPIS while they continue to work on issues such as imperfect compliance with
regulatory standards required for the USDA PM inspection stand at the end of the line. The
Agency has been allowing FI7s to perform PM inspection (Carcass Inspection) only while
recruiting and filling the required CSI 9s in NPIS plants.
 
If a company wants to run birds through a processing plant but the birds are simply being

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 slaughtered for rendering (no human food), would FSIS need to be present for this to occur? 
Birds may be diverted for rendering before picking, after picking, or after evisceration
(depending on the agreement with the rendering company).  We could provide assurances
that these birds are, in fact, being rendered and alert the DO that the plant may be running on
Sunday to kill these birds (as an example) The PPIA actually prohibits us from inspecting birds
slaughtered or processed for rendering at an official establishment, but requires denaturing
or other identification of the product as inedible.  So, it can be done.  FSIS amended 381.152
last year to clarify that we don’t have to be there when this happens.
 
§460. Miscellaneous activities subject to regulation
(a) Prohibition of inspection of articles not intended for use as human food; denaturation or
other identification prior to distribution in commerce; inedible articles
Inspection shall not be provided under this chapter at any establishment for the slaughter of
poultry or the processing of any carcasses or parts or products of poultry, which are not
intended for use as human food, but such articles shall, prior to their offer for sale or
transportation in commerce, unless naturally inedible by humans, be denatured or otherwise
identified as prescribed by regulations of the Secretary to deter their use for human food. No
person shall buy, sell, transport, or offer for sale or transportation, or receive for
transportation, in commerce, or import, any poultry carcasses or parts or products thereof
which are not intended for use as human food unless they are denatured or otherwise
identified as required by the regulations of the Secretary or are naturally inedible by humans.
 
Several plants have recently received line speed waivers but most of those plants are
experiencing no labor shortages from either their own employees or FSIS employees.  If these
establishments do not increase their line speeds, will IPP increase the number of inspection
tasks anyhow?  The Agency is not changing any inspection policies including methodologies,
frequencies, etc.
 
Thank you in advance and I’d be happy to hop on a call if that is easier.
 
Ashley  
 
From: Sidrak, Hany - FSIS <hany.sidrak@usda.gov>
Sent: Monday, April 13, 2020 6:47 PM
To: Ashley Peterson (b) (6) @chickenusa.org>; Bronstein, Philip - FSIS
<philip.bronstein@usda.gov>
Subject: Re: Chiller Question
 
Hi Ashley - All is well and hope the same for you.
 
Thus far, I’m not aware of inspection not being able to perform the 300-carcass leukoais check;
however, instruction to IPP in case of short staffing to prioritize carcass inspection, then food safety
verification, and finally OCP checks such as the Leukosis check in NPIS plants.
 
On the issue of chilling larger carcasses, I’m not sure what type of waiver you’re thinking of but think

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