Written humane handling programs - robust or bust?

Can anyone imagine trying to manage and direct food safety, occupational safety, or human resources without the aide of written programs and associated recordkeeping in today’s highly regulated environment? The legal liabilities alone by not having written programs and recordkeeping are too numerous to count.  For those not too familiar with humane animal handling and the initial and critical steps of harvesting live animals, know that it’s a unique and expansive world within its own that can be fraught with daily surprises at nearly every rounded corner starting from the continuum of the delivery and unloading of animals, to hoisting, hanging, sticking and bleed-out stages of harvesting. This is one area of industry that can never have enough training and re-training of its employees.  Many people both in and out of industry are surprised when informed that FSIS does not have a statutory or a regulatory basis to require USDA harvesting establishments to have in place a formal written humane handling program, except for meat destined for the school lunch program.