Workplace Safety and Health
Safety in the Meat and Poultry Industry, While Improving, Could Be Further Strengthened Gao ID: GAO-05-96 January 12, 2005Because meatpacking is one of the most dangerous industries in the United States, we were asked to provide the Congress with information on the characteristics of workers in the meat and poultry industry and the conditions in which they work, the types of injuries and illnesses these workers incur, how injury and illness rates have changed over the past decade, and factors that may have affected these rates. We were also asked to determine what is known about the effectiveness of the Occupational Safety and Health Administration's (OSHA) efforts to improve safety and health in the meat and poultry industries.
The largest proportions of workers in the meat and poultry industry, according to the Bureau of Labor Statistics (BLS), are young, male, and/or Hispanic. Although the majority of workers are citizens, an estimated 26 percent of them are foreign-born noncitizens. They work in hazardous conditions involving loud noise, sharp tools, and dangerous machinery. Many workers must stand for long periods of time wielding knives and hooks to slaughter or process meat on a production line that moves very quickly. Workers responsible for cleaning the plant must use strong chemicals and hot pressurized water. While, according to BLS, injuries and illnesses have declined over the past decade, the meat and poultry industry still has one of the highest rates of injury and illness of any industry. The most common injuries are cuts, strains, cumulative trauma, and injuries sustained from falls, but more serious injuries, such as fractures and amputation, also occur. According to BLS, the injury and illness rate for the industry has declined from an estimated 29.5 injuries and illnesses per 100 full-time workers in 1992 to 14.7 in 2001. Injury and illness rates can be affected by many factors, such as the amount and quality of training, employee turnover rates, increased mechanization, and the speed of the production line. Some evidence suggests that OSHA's efforts have had a positive impact on the injury and illness rates of workers in meat and poultry plants. However, while the criteria OSHA uses to select plants for inspection--which focus on plants with relatively high injury and illness rates--are reasonable, OSHA could improve its selection process by also considering trends in plants' injury and illness rates over time. In addition, it is difficult to assess the effectiveness of OSHA's efforts because the agency does not assign a unique identifier to each plant, making it hard to compare the data it collects on specific plants' injury and illness rates with the information the agency collects on the results of its plant inspections and other programs.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-96, Workplace Safety and Health: Safety in the Meat and Poultry Industry, While Improving, Could Be Further Strengthened
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Report to the Ranking Minority Member, Committee on Health, Education,
Labor, and Pensions,
U.S. Senate:
United States Government Accountability Office:
GAO:
January 2005:
Workplace Safety and Health:
Safety in the Meat and Poultry Industry, while Improving, Could Be
Further Strengthened:
GAO-05-96:
GAO Highlights:
Highlights of GAO-05-96, a report to the Ranking Minority Member,
Committee on Health, Education, Labor and Pensions, U.S. Senate:
Why GAO Did This Study:
Because meatpacking is one of the most dangerous industries in the
United States, we were asked to provide the Congress with information
on the characteristics of workers in the meat and poultry industry and
the conditions in which they work, the types of injuries and illnesses
these workers incur, how injury and illness rates have changed over the
past decade, and factors that may have affected these rates. We were
also asked to determine what is known about the effectiveness of the
Occupational Safety and Health Administration‘s (OSHA) efforts to
improve safety and health in the meat and poultry industries.
What GAO Found:
The largest proportions of workers in the meat and poultry industry,
according to the Bureau of Labor Statistics (BLS), are young, male,
and/or Hispanic. Although the majority of workers are citizens, an
estimated 26 percent of them are foreign-born noncitizens. They work in
hazardous conditions involving loud noise, sharp tools, and dangerous
machinery. Many workers must stand for long periods of time wielding
knives and hooks to slaughter or process meat on a production line that
moves very quickly. Workers responsible for cleaning the plant must use
strong chemicals and hot pressurized water.
While, according to BLS, injuries and illnesses have declined over the
past decade, the meat and poultry industry still has one of the highest
rates of injury and illness of any industry. The most common injuries
are cuts, strains, cumulative trauma, and injuries sustained from
falls, but more serious injuries, such as fractures and amputation,
also occur. According to BLS, the injury and illness rate for the
industry has declined from an estimated 29.5 injuries and illnesses per
100 full-time workers in 1992 to 14.7 in 2001. Injury and illness rates
can be affected by many factors, such as the amount and quality of
training, employee turnover rates, increased mechanization, and the
speed of the production line.
Some evidence suggests that OSHA‘s efforts have had a positive impact
on the injury and illness rates of workers in meat and poultry plants.
However, while the criteria OSHA uses to select plants for inspection-
which focus on plants with relatively high injury and illness rates-are
reasonable, OSHA could improve its selection process by also
considering trends in plants‘ injury and illness rates over time. In
addition, it is difficult to assess the effectiveness of OSHA‘s efforts
because the agency does not assign a unique identifier to each plant,
making it hard to compare the data it collects on specific plants‘
injury and illness rates with the information the agency collects on
the results of its plant inspections and other programs.
Production Line at a Meatpacking Plant:
[See PDF for image]
[End of figure]
What GAO Recommends:
To strengthen its efforts to improve worker safety and health in meat
and poultry plants, GAO recommends that OSHA, among other things,
consider adjusting its criteria for selecting plants for inspection and
audits to include those that have had large reductions in their injury
and illness rates over time, and changing the way it collects data on
plants in order to make it easier to measure the impact of its
programs.
OSHA provided GAO with written comments on a draft of this report,
emphasizing its commitment to addressing the health and safety hazards
facing meat and poultry workers. It generally agreed with the report‘s
findings and recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-05-96.
To view the full product, including the scope and methodology, click on
the link above.,For more information, contact Bob Robertson at (202)
512-9889 or robertsonr@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Meat and Poultry Workers Tend to Be Young, Male, and/or Hispanic, and
Face Hazardous Working Conditions:
Meat and Poultry Workers Are Injured in a Variety of Ways, and Their
Injury and Illness Rates, though Declining, Remain among the Highest of
Any Industry:
While OSHA's Programs May Have Improved the Safety and Health of Meat
and Poultry Workers, Programmatic Weaknesses Make Determining
Effectiveness Difficult:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Interviews with Cleaning and Sanitation Companies:
Appendix III: OSHA's Study on Its Impact Using Establishment-Specific
Targeting of Interventions:
Appendix IV: Comments from the Occupational Safety and Health
Administration:
Appendix V: Comments from the U.S. Department of Agriculture:
Appendix VI: Comments from the U.S. Department of Health and Human
Services:
Appendix VII: Comments from the Bureau of Labor Statistics:
Appendix VIII: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgments:
Tables:
Table 1: Types of Potentially Hazardous Working Conditions in Meat and
Poultry Plants:
Table 2: OSHA Inspections in the Meat and Poultry Industry, 1995 to
2004:
Table 3: Survey Sample Sizes, Disposition, and Response Rates:
Figures:
Figure 1: Location of U.S. Meat and Poultry Plants, September 2004:
Figure 2: Production Line at a Poultry Plant:
Figure 3: Workers in the Meat and Poultry Industry, by Race, 2003:
Figure 4: Location of U.S. Meat and Poultry Plants with More than 500
Employees, September 2004:
Figure 5: Nature of Injuries Sustained by Meat and Poultry Workers and
Parts of the Body Affected:
Figure 6: Safety and Other Equipment Worn by Meat and Poultry
Production Workers:
Figure 7: Trends in Injury and Illness Rates in the Meat and Poultry
Industry, Compared with Trends in All U.S. Manufacturing, 1992 to 2001:
Abbreviations:
BLS: Bureau of Labor Statistics:
CPS: Current Population Survey:
HHS: U.S. Department of Health and Human Services:
NIOSH: National Institute of Occupational Safety and Health:
OSHA: Occupational Safety and Health Administration:
SST: site-specific targeting:
USDA: U.S. Department of Agriculture:
United States Government Accountability Office:
Washington, DC 20548:
January 12, 2005:
The Honorable Edward M. Kennedy:
Ranking Minority Member:
Committee on Health, Education, Labor, and Pensions:
United States Senate:
Dear Senator Kennedy:
According to data collected by the U.S. Department of Labor's Bureau of
Labor Statistics (BLS), in 2003, an estimated 527,000 workers were
employed in the animal slaughtering and processing industry.[Footnote
1] According to the U.S. Department of Agriculture (USDA), in 2004
there were about 5,700 meatpacking and processing plants in the United
States. The modern meatpacking and processing plant is a complex and
highly organized structure, developed for the streamlined slaughter and
progressive disassembly of animals. The industry includes plants in
which animals are slaughtered and cut into pieces, with some facilities
also cooking and packaging the meat for consumption, as well as plants
in which meat products, such as sausage and ham, are produced by adding
ingredients to the meat. The meat processed includes red meat such as
beef, veal, pork, and lamb, and poultry such as chicken and turkey.
Because meatpacking is one of the most dangerous industries in the
United States, you asked us to (1) describe the characteristics of
workers in meat and poultry slaughter and processing plants and the
conditions in which they work; (2) identify the types of injuries and
illnesses workers in meat and poultry slaughter and processing plants
incur, how the injury and illness rates have changed over the past
decade, and the factors that may affect these rates; and (3) determine
what is known about the effectiveness of the Occupational Safety and
Health Administration's (OSHA) efforts to improve safety and health at
meat and poultry slaughter and processing plants.
To respond to your request, we reviewed literature on the industry and
interviewed officials from OSHA and other federal agencies, such as
USDA and the Centers for Disease Control and Prevention's National
Institute for Occupational Safety and Health (NIOSH) within the
Department of Health and Human Services (HHS), as well as individuals
from contract cleaning and sanitation companies, unions, advocacy
groups, and key trade associations. We obtained and analyzed:
* data on worker demographics from BLS's Current Population Survey
(CPS),
* data on workplace injuries and illnesses from BLS's Survey of
Occupational Injuries and Illnesses,
* data on fatalities from BLS's Census of Fatal Occupational Injuries,
* data from OSHA's inspections database (the Integrated Management
Information System),
* worksite-specific injury and illness data that OSHA uses to target
specific worksites for inspection (the OSHA Data Initiative),
* data on the number and location of meat and poultry plants from
USDA's Performance Based Inspection System, and:
* lists of plants that participate in OSHA's cooperative
programs.[Footnote 2]
In addition, we visited six meat and poultry plants and two OSHA area
offices and interviewed inspectors at four additional area offices,
selected because the offices had performed the most inspections of meat
and poultry plants. Finally, we conducted a survey of meat and poultry
plants to obtain data on their workers, factors that affect their
injury and illness rates, plants' efforts to improve safety and health,
and plants' interactions with OSHA.[Footnote 3] See appendix I for
detailed information on the scope and methodology for our work. We
performed our work in accordance with generally accepted government
auditing standards between January 2004 and September 2004.
Results in Brief:
According to CPS data, in 2003, the largest proportions of workers in
the meat and poultry industry tended to be young (43 percent under age
35), male (65 percent), and/or Hispanic (42 percent), with meat and
poultry workers in general laboring in hazardous conditions involving
loud noise, sharp tools, and dangerous machinery. Although the data
show that the majority of workers were citizens, a large proportion, an
estimated 26 percent, were foreign-born noncitizens. Generally, meat
and poultry workers are employed in larger plants located in the South
and Midwest and earn a median salary of about $21,320 per year, much
less than the typical pay for workers in all manufacturing industries
of about $33,500 per year. The type of work performed and the plant
environment expose workers to many hazards. The work is physically
demanding, repetitive, and often requires working in extreme
temperatures--such as in refrigeration units that range from below zero
to 40 degrees Fahrenheit--and plants often have high turnover rates.
Workers often stand for long periods of time on production lines that
move very quickly, wielding knives or other cutting instruments used to
trim or remove portions of the carcasses. Conditions at the plant can
also be loud, wet, dark, and slippery. Workers responsible for cleaning
the plant must use strong chemicals and hot pressurized water to clean
inside and around dangerous machinery, and may experience impaired
visibility because of steam.
Meat and poultry workers sustain a range of injuries, including cuts,
burns, and repetitive stress injuries, and while, according to BLS,
injuries and illnesses in the meat and poultry industry declined from
29.5 injuries and illnesses per 100 full-time workers in 1992 to 14.7
in 2001, the rate was among the highest of any industry. Similarly,
though not comparable with these data because of recent changes in
OSHA's record-keeping requirements, statistics for 2002 indicate that
injury and illness rates in the meat and poultry industry remain high
in relation to those of other industries. While the most common
injuries are cuts, strains, cumulative trauma caused by repetitive
cutting motions, and injuries sustained from falls, more serious
injuries, such as fractures and amputation, also occur. For example,
according to OSHA data, a worker died when he attempted to replace his
knife in the scabbard hanging from his belt, missed the opening, and
pushed the knife into his leg, severing his femoral artery. In
addition, some workers become ill because of exposure to chemicals,
blood, and fecal matter, which can be exacerbated by poor ventilation
and extreme temperatures. Because of the many hazards inherent in meat
and poultry plants and the type of work performed, the dramatic decline
in the industry's injury and illness rates has raised a question about
the validity of the data on which these rates are based. Several
factors can affect the rates of injury and illness, such as an emphasis
on safety by employers or employees, the amount and quality of
training, employee turnover rates, and the speed of the production
line. However, the degree to which these factors affect injury and
illness rates is difficult to assess. Some experts believe, for
example, that faster line speeds increase workers' risk of injury. OSHA
officials told us that while they believed that slowing the speed of
the production line could help reduce the number of injuries to
workers, they do not have the data on the effect of line speed on
worker safety needed to question, in general terms, the process of
setting line speed or to assess the appropriate speed at which the
lines should operate.
Though certain weaknesses complicate assessments of OSHA's efforts to
improve safety and health at meat and poultry plants, some evidence
suggests that the agency's efforts have had a positive impact on the
injury and illness rates of workers in this industry. For example, in
2003, OSHA conducted inspections of almost 200 meat and poultry plants
that, according to the agency and some plant officials we interviewed,
resulted in many safety and health improvements. Similarly, some
evidence suggests that OSHA's cooperative programs have had a positive
impact on the safety and health of workers. For example, a program
initiated by OSHA's Omaha Area Office, in which it partnered with
several meatpacking plants in the state to share best safety practices,
has, according to OSHA, improved worker safety and health in plants in
Nebraska. The agency has not, however, implemented similar programs in
other areas with large concentrations of meatpacking plants or extended
the program to poultry plants. In addition, the criteria OSHA uses to
select plants for inspection, while reasonable, may not trigger
inspection of some at-risk plants. Currently, OSHA's selection criteria
target worksites in industries with high rates of injury and illness.
OSHA also selects a small number of worksites with low injury and
illness rates for inspection in order to ensure that they are not
underreporting injuries and illnesses, and randomly selects worksites
from high-hazard industries for audits that verify their injury and
illness rates. However, because OSHA's selection criteria do not
require the agency to examine trends in plants' injury and illness
rates over time--and the agency does not attempt to examine these
trends--OSHA may not detect dramatic decreases in these rates that
could raise questions as to the accuracy of the figures. Furthermore,
the injury and illness data on which OSHA bases its selection of plants
for inspection are incomplete, because they do not include injuries and
illnesses incurred by cleaning and sanitation workers not employed
directly by the plants. These workers are not classified by BLS as
working in the meat and poultry industry, although they labor in the
same plants and under working conditions that can be even more
hazardous than those of production workers. Finally, because OSHA does
not assign a unique identifier to each plant for which data are
collected, it is difficult to assess the success of its efforts by
comparing information about specific plants across its databases.
This report contains recommendations for strengthening OSHA's efforts
to improve the safety and health of workers at meat and poultry
slaughter and processing plants by, among other things, adjusting its
criteria for selecting plants for inspection and audits to include
those that have had large reductions in their injury and illness rates
over time, and changing the way it collects data on plants in order to
make it easier to measure the impact of its programs. The report also
makes a recommendation jointly to OSHA and USDA and another to HHS. In
their written comments on our report, OSHA, USDA, and HHS generally
agreed with the report's findings, conclusions, and recommendations.
BLS also provided us with written comments, suggesting several
technical corrections that were incorporated throughout the report, as
appropriate.
Background:
According to USDA, there were about 5,700 total meat and poultry plants
in the United States as of September 2004.[Footnote 4] Most of these--
about 4,400--had fewer than 40 employees, and about half of them are
even smaller, with fewer than 10 employees. Figure 1 shows the location
of all meat and poultry plants, regardless of size, in the United
States as of September 1, 2004.
Figure 1: Location of U.S. Meat and Poultry Plants, September 2004:
[See PDF for image]
[End of figure]
Over the past 25 years, the meat and poultry industry has consolidated,
as today's leading firms built very large plants and some independent
firms disappeared or were bought by larger firms. While many small
plants remain, a few large companies have gained control of the lion's
share of the market. Today, the top four meatpacking companies
slaughter, process, and package about 80 percent of the beef cattle in
the United States, and the top four pork producers control nearly 70
percent of the market. The poultry industry is nearly as concentrated,
with the top five companies maintaining a market share in excess of 50
percent. Consolidation of the various meat industries occurred, in
large part, because of innovations in technology and the relocation of
plants near the source of livestock.
Industry consolidation has been accompanied by significant changes in
the relations between organized labor and the management of meat and
poultry plants. According to a report by USDA's Economic Research
Service, in 1980, 46 percent of workers in the meat products industry
were union members, a figure that had remained stable since the
1970s.[Footnote 5] However, by the end of the 1980s, union membership
had fallen to 21 percent. Declining rates of unionization coincided
with increases in the use of immigrant workers, higher worker turnover,
and reductions in wages. Immigrants make up large and growing shares of
the workforces at many plants. Labor turnover in meat and poultry
plants is quite high, and in some worksites can exceed 100 percent in a
year as workers move to other employers or return to their native
countries. The frequent movement of immigrant workers among plants and
communities limits the opportunities of unions to organize meat and
poultry workers.
Most of today's facilities are designed for an orderly flow from point
of entry of the living animal into the plant to the finished food
product. The animal enters the production facility and proceeds
directly to the kill floor area, where slaughter occurs. The carcass is
beheaded, eviscerated, and chilled for several hours. It is then taken
to the cutting floor, where it is cut into smaller cuts of meat. The
new processing methods--breaking down carcasses into small, vacuum-
packed portions of meat that can be shipped directly to supermarkets--
have transformed the work into an assembly line operation requiring
workers to perform an increased number of repetitive motions.
While slaughterhouses have come to rely on greater mechanization over
the last several decades, much of the work is still done by hand,
particularly when animals vary in size, shape, and weight. The main
slaughtering steps of evisceration and cutting are generally done by
hand, using knives. Figure 2 shows a typical assembly line operation at
a poultry plant.
Figure 2: Production Line at a Poultry Plant:
[See PDF for image]
[End of figure]
OSHA, established after the passage of the Occupational Safety and
Health Act in 1970, is the federal agency within the Department of
Labor responsible for protecting the safety and health of workers in
meat and poultry plants.[Footnote 6] OSHA performs a number of
functions, including establishing safety and health standards,
conducting routine inspections, and conducting investigations in
response to complaints from workers and incidents such as fatalities.
Regional administrators in each of OSHA's 10 regional offices oversee
the enforcement of federal policies within their own regions. Each
region is composed of area offices--of which there are 80 in total--
overseen by area directors. The area directors oversee compliance
officers, who are responsible for conducting inspections and following
up on complaints, and compliance assistance specialists, who provide
assistance to organizations and employers that participate in OSHA's
cooperative programs. Compliance assistance specialists also help
employers correct hazards identified during inspections.
To determine which plants to inspect, OSHA relies on BLS data on
injuries, illnesses, and fatalities by industry. BLS surveys a sample
of employers annually (182,800 worksites were surveyed for 2002) and
asks them to report information on the number of work-related injuries
and illnesses that occur at their worksites. This information comes
from injury and illness records that most private industry employers
with more than 10 employees are required by OSHA to maintain. From this
information, BLS calculates industry-level injury and illness rates.
BLS also identifies fatalities from an annual census of all 50 states,
the District of Columbia, and New York City, which report on all work-
related fatalities within their jurisdictions. BLS requires the
reporting entities to corroborate reports of fatalities from multiple
sources, such as death certificates, medical examiners' reports, media
reports, and workers' compensation claims. BLS makes injury, illness,
and fatality data available at the national, as well as at the state,
level.
OSHA uses two approaches to ensure general employer compliance with
federal safety and health laws and regulations--enforcement and
cooperative programs. Enforcement, which represents the preponderance
of agency activity, is carried out primarily by using compliance
officers to inspect employer worksites. Worksites and employers that
fail to meet federal safety and health standards face sanctions, such
as paying penalties for violations of health and safety standards.
OSHA's cooperative approach invites employers to collaborate with the
agency through a number of different programs and uses a variety of
incentives to encourage employers to reduce hazards and institute
practices that foster safer and healthier working conditions.
OSHA's Enforcement Efforts:
OSHA selects worksites in selected industries for inspection through
its site-specific targeting (SST) program and through national and
local programs that focus on specific hazards. The SST program focuses
on employers with more than 40 employees, who are required to record
all injuries and illnesses on a log and make this information available
to OSHA.[Footnote 7] Of the almost 40,000 inspections OSHA conducted in
2003, about 2,000 were SST inspections, and about 25,000 were conducted
through national and local emphasis programs.[Footnote 8] The agency
also conducts inspections when fatalities or serious injuries occur and
when workers file complaints about serious safety and health hazards.
These inspections constitute nearly half of the total inspections OSHA
conducts annually.
For its SST program, OSHA obtains specific information--such as
employer names and addresses--for all worksites with 40 or more
employees, approximately 140,000 worksites each year. OSHA then selects
a portion of these worksites (approximately 80,000) in the industries
with the highest injury and illness rates,[Footnote 9] and sends them a
survey form that requires them to report (1) the average number of
employees who worked for them during the previous calendar year, (2)
the total hours the employees worked during the previous year, and (3)
summary injury and illness data from their OSHA logs. From this
information, OSHA computes the worksites' injury and illness rates and
sends those with relatively high rates a letter informing them that
they may be inspected. Finally, OSHA compiles SST inspection targeting
lists containing the names of worksites with relatively high injury and
illness rates for inspection[Footnote 10].
OSHA also has special emphasis programs that focus on a particular
safety or health hazard or the hazards of a specific industry, selected
by the agency's headquarters office for attention. While OSHA's
headquarters provides direction to its area offices in implementing
these national emphasis programs, the area offices have considerable
flexibility in selecting actual worksites for attention. In addition,
regional and area offices use regional and local emphasis programs to
highlight industries or hazards within their jurisdictions that they
believe are especially hazardous.
Because musculoskeletal disorders are prevalent in several industries-
-including the meat and poultry industry--but there is no specific
standard that allows OSHA to cite employers for hazards relating to
these injuries, the agency designed a four-pronged approach to address
these injuries that focuses on industries and employers with known high
injury and illness rates.[Footnote 11] The approach includes (1)
developing industry or task-specific guidelines for a number of
industries based on current incidence rates and available information
about effective and feasible solutions; (2) conducting inspections for
ergonomic hazards, issuing citations under the general duty clause of
the Occupational Safety and Health Act,[Footnote 12] and issuing
ergonomic hazard alert letters where appropriate; (3) providing
assistance to businesses, particularly small businesses, and helping
them to proactively address ergonomic issues in the workplace; and (4)
chartering an advisory committee authorized to, among other things,
identify gaps in research about the application of ergonomics and
ergonomic principles in the workplace.
OSHA's Cooperative Programs:
OSHA's cooperative programs provide incentives to employers, such as
free consultations, deferrals from SST inspections, and recognition for
exemplary safety and health management systems, for making improvements
to their safety and health management systems. OSHA has implemented
these programs incrementally to reach different employers and worksites
in various ways. OSHA has four primary programs: (1) the On-Site
Consultation Program, (2) the Voluntary Protection Programs, (3) the
Strategic Partnership Program, and (4) the Alliance Program.
The On-Site Consultation Program is a broad network of occupational
safety and health services primarily funded by federal OSHA, but is
delivered by the states. The service, which originated in 1974, focuses
on helping small employers comply with OSHA and state occupational
safety and health standards. The program assigns priority to companies
in high-hazard industries and is offered free of charge to eligible
employers.[Footnote 13] States provide consultation visits at
employers' requests in order to identify safety and health hazards and
discuss techniques for their abatement. Small employers receiving
consultation services may qualify for recognition in the Safety and
Health Achievement Recognition Program--part of the On-Site
Consultation Program--which exempts them from SST inspections during
the period that their certification is valid, either 1 or 2 years.
Participants in this program, who are considered models for good safety
and health practices in their field, must have, at a minimum, safety
and health management systems in place to prevent and control
occupational hazards, as well as illness and injury rates below the
national average for their industry.
The Voluntary Protection Programs, established in 1982, recognize
single worksites with exemplary safety and health management systems.
In calendar year 2003, the average participating worksite had
approximately 250 employees, and about 50 percent of the participating
sites had 200 employees or less. To participate in this program,
employers must have worksites that exceed OSHA standards and must
commit to a process of continual improvement. After receipt of a site's
application, OSHA conducts an onsite review of the site to verify the
effectiveness of its safety and health management system.
The Strategic Partnership Program, established in 1998, was designed to
address specific safety and health management systems in high-hazard
workplaces by promoting collaboration between employers, employees,
other affected organizations, and OSHA.[Footnote 14] Each partnership
has a written agreement that outlines goals (such as the reduction of
injuries), strategies, and measures, and identifies how the partners
will work together to achieve their desired results. Partnerships may
focus on specific hazards or industry issues, or may aim for broader
impact through focus on safety and health management systems. OSHA
verifies partner commitment and success in achieving goals, and while
the program does not offer employers exemption from inspection, it
offers other incentives, such as limiting SST inspections to only the
most serious prevailing hazards and reducing penalties for hazards
cited during inspections.
OSHA's Alliance Program targets trade, professional, and other types of
organizations to work collaboratively with OSHA to promote workplace
safety and health issues. In contrast to OSHA's other three cooperative
programs, which typically include safety and health management systems
at specific employer worksites, alliance agreements focus on goals such
as training, outreach, and increasing awareness of workplace safety and
health issues. Alliance participants and their members are not exempt
from OSHA inspections and do not receive any enforcement-related
incentives for being part of an organization participating in an
alliance. Instead, OSHA officials informed us that trade and
professional associations have used the program to address existing and
emerging workplace safety and health issues, such as ergonomics.
In addition to these formal programs, OSHA conducts other compliance
assistance activities, such as outreach and training activities, to aid
employers in complying with OSHA standards and to educate employers on
what constitutes a safe and healthy work environment.
Meat and Poultry Workers Tend to Be Young, Male, and/or Hispanic, and
Face Hazardous Working Conditions:
The meat and poultry workforce tends to be young (43 percent under age
35), male (65 percent), and/or Hispanic (42 percent). These
characteristics are more pronounced in the meat and poultry industry
than in the U.S. manufacturing sector overall. Meat and poultry workers
typically earn substantially less than workers in the U.S.
manufacturing sector as a whole. Most large plants are located in the
Midwest and South, and workers in the industry often work in difficult
and dangerous conditions.
Meat and Poultry Workers Are Predominantly Young, Male, and/or
Hispanic, and Most Large Plants Are Located in the Midwest and South:
Workers in the meat and poultry industry tended to be younger than
workers in the manufacturing sector as a whole, and almost all of the
workers are employed on a full-time basis. According to CPS data, in
2003, the median age of workers in the meat and poultry industry was 37
years.[Footnote 15] About 43 percent of all meat and poultry workers
were under age 35, compared with about 29 percent of all U.S.
manufacturing workers.[Footnote 16] These workers also tend to be male.
In 2003, men made up 65 percent of the workforce in the meat and
poultry industry. In 2003, in this industry and in U.S. manufacturing
overall, about 95 percent of the employees worked full-time.[Footnote
17]
The racial composition of the meat and poultry workforce is
disproportionately Hispanic. As shown in figure 3, according to the
CPS, in 2003, about 42 percent of meat and poultry workers were
Hispanic or Latino, 32 percent were white, and 20 percent were
black.[Footnote 18] These figures compare with those for U.S.
manufacturing as a whole, in 2003, where about 14 percent of the
workforce was Hispanic, about 70 percent was white, and about 9 percent
was black. Further, the percentage of Hispanic or Latino meat and
poultry workers in 2003 reflects a 17 percent increase from 1994, when
about 25 percent of meat and poultry workers were Hispanic or Latino.
In addition, in 1994, a larger percentage of the meat and poultry
workforce--46 percent--was white, and 25 percent was black.
Figure 3: Workers in the Meat and Poultry Industry, by Race, 2003:
[See PDF for image]
[End of figure]
Foreign-born noncitizens are more highly represented within the meat
and poultry workforce than in manufacturing as a whole. A significant
proportion--about 26 percent--of all workers in this industry are
foreign-born noncitizens, compared with only about 10 percent of all
manufacturing workers in the United States. An even larger percentage
of the production and sanitation workers in the meat and poultry
industry--38 percent--are foreign-born noncitizens.[Footnote 19] In
1994, 28 percent of production and sanitation workers were foreign-born
noncitizens.
In certain areas of the United States, a number of communities have
concentrated groups of immigrant workers--including groups from regions
such as Central America, Southeast Asia, and Eastern Europe--who are
employed in the meat and poultry industry.[Footnote 20] In such areas,
employees from these immigrant groups may make up a relatively large
percentage of the workforce and population in and around meat and
poultry plants. For example, in 2000, the population of one county in
Kansas (which, according to USDA, was one of the largest meat-producing
counties in the nation) was about 43 percent Hispanic, compared with
only 7 percent of the population in the state. According to some
industry officials, the increasingly fragmented nature of the tasks in
slaughtering and processing has diminished the need for a skilled and
more highly paid workforce, a fact that supports the industry's
recruitment and employment of unskilled immigrant labor.
While plants are distributed throughout the United States, larger
plants--those with more than 500 employees--tend to be concentrated in
particular regions and produce the majority of the meat. Of these
larger meat and poultry plants, about 87 percent are located in the
South and the Midwest, 54 percent and 33 percent, respectively. Another
9 percent are located in the West and 4 percent in the Northeast.
Figure 4 shows plants with more than 500 employees.
Figure 4: Location of U.S. Meat and Poultry Plants with More than 500
Employees, September 2004:
[See PDF for image]
[End of figure]
Meat and poultry workers tend to earn substantially less than
manufacturing workers in general. In 2003, meat and poultry workers
earned a median salary of about $21,320 per year, while manufacturing
workers earned about $33,500 per year. In addition, the rate of
employee turnover among meat and poultry workers can be high.[Footnote
21] A plant official with whom we spoke indicated that some workers who
are hired have no intention of staying for a long period of time and
approach employment at meat and poultry plants as a temporary
arrangement. According to some experts, high turnover may benefit
plants because they save on some costs, such as health benefits and
vacation pay, while others argue that high turnover is costly for
plants because they must constantly recruit and train new employees.
Workers Face Several Hazardous Conditions in Meat and Poultry Slaughter
and Processing Plants:
The work environment in meat and poultry plants can be risky because of
the current procedures used in the industry. Meat and poultry plants
present risks greater than those faced by workers in many other
manufacturing operations. For example, production lines can require
workers to stand close together while wielding tools necessary for
cutting pieces of meat. Final product processing involves a number of
packaging machines and conveyors that can present a wide range of
safety risks to workers. Workers are also frequently handling or in
close proximity to sources of infectious diseases, such as those
carried by animal tissues and organs. Pathogens can infect workers from
open abrasions or through inhalation. For example, hydrogen sulfide,
methane, and carbon dioxide can be released from decomposing animal
manure and waste. In addition, workers are exposed to many chemicals,
including a range of gases, such as ammonia, and Freon. Table 1
summarizes the hazardous working conditions in meat and poultry plants.
Table 1: Types of Potentially Hazardous Working Conditions in Meat and
Poultry Plants:
Type of hazard: Animal;
Description of hazard: Workers can be injured by animals when they are
unloaded and brought into the plant. Incorrect stunning and
slaughtering can result in unpredictable and violent reactions. The
movement of carcasses weighing up to half a ton or more also poses a
possible danger. Bodily fluids from carcasses, such as blood and fat,
can make floors wet and slippery.
Type of hazard: Chemicals and pathogens;
Description of hazard: Workers, especially cleanup crews, are exposed
to a number of products that have strong chemicals, including
disinfectants. In addition, workers are exposed to ammonia used for
refrigeration. Workers may also be exposed to viruses, blood, fecal
matter, and bacteria, such as Salmonella.
Type of hazard: Temperature;
Description of hazard: Some workers are exposed to very hot
temperatures, used to cook or cure meat. Workers are also exposed to
very cold temperatures used to preserve meat and facilitate processing.
Frozen meat and poultry products can require work in even colder
temperatures. These problems are compounded by wet conditions and high
humidity. Cleanup crews spray machinery, floors, and equipment with
very hot water, causing steam that can burn workers and impair vision
from fogged safety goggles.
Type of hazard: Machine and tool;
Description of hazard: Many meat and poultry jobs still require the
manual use of knives, particularly in meatpacking plants where animals
vary widely in size and shape. Increasing mechanization, while reducing
the number of workers exposed to injury on processing lines, can
increase the type and severity of injuries by machines that cut, slice,
saw, and grind. Large objects, such as forklifts, are also a hazard.
Type of hazard: Work stress;
Description of hazard: Workers on some production lines perform
identical motions for long periods of time. Increasing mechanization
can permit faster line speeds, which in turn can further stress
workers, who must keep up with mechanical equipment.
Type of hazard: Noise;
Description of hazard: Some workers are exposed to loud machinery for
prolonged periods. Earplugs are required and may reduce ability to
communicate warnings.
Source: GAO analysis.
[End of table]
Meat and Poultry Workers Are Injured in a Variety of Ways, and Their
Injury and Illness Rates, though Declining, Remain among the Highest of
Any Industry:
Meat and poultry workers suffer high rates of many types of injuries
and illnesses, including those affecting the back, trunk, arms,
fingers, and wrists. Although injury and illness rates have declined
over the last decade, according to BLS, those in meat and poultry
plants continue to be among the highest of any industry.
Workers Sustain Many Different Types of Injuries and Illnesses:
Workers in the meat and poultry industry, including contract cleanup
and sanitation workers, can suffer a host of serious injuries and
illnesses, most often musculoskeletal disorders. (See fig. 5 for an
illustration of the types of injuries workers suffer.) Many of the
injuries--such as those to the arms, hands, and wrists--are due to the
repetitive motions associated with the meat production process, such as
performing the same cutting motions over time, and can become
crippling. For example, carpal tunnel syndrome, caused by repetitive
motion or cumulative trauma, can severely damage a nerve running
through the wrist.[Footnote 22]
Workers can also be cut by their own knives during the butchering and
cutting processes. For example, according to an OSHA publication, one
worker in a meatpacking plant was blinded when the knife he was using
to pick up a ham prior to boning slipped out of the ham, striking him
in the eye.[Footnote 23] The report also described an incident in which
another worker's face was permanently disfigured when his knife slipped
out of a piece of meat and struck his nose, upper lip, and chin. In
another incident, according to OSHA, a worker who attempted to replace
his knife in the scabbard hanging from his belt missed the opening and
pushed the knife into his leg, severed his femoral artery, and died. In
addition, workers can be cut by the knives wielded by coworkers.
According to OSHA's report, these "neighbor cuts" are usually the
direct result of overcrowded working conditions.
Other injuries that workers can experience include respiratory
irritation and, in some instances, asphyxiation from exposure to
pathogenic respiratory substances. For example, workers have died from
being overcome by hydrogen sulfide gas and from drowning when they
entered manure waste pits or unknowingly worked near manure waste
"lagoons" without taking the proper precautions, such as conducting an
air test and wearing a safety harness and respirator; such precautions
are particularly critical when workers are in confined spaces.
According to OSHA, one worker died from chemical exposure after being
sprayed with 400 pounds of toxic liquid ammonia while attempting to fix
a pipe.
Workers may also suffer injuries and illnesses from contact with
animals. If the animals are still dying when they are hung on the line,
they may struggle and thrash about wildly, resulting in injuries that
range from broken arms to permanent disfigurement and--in the most
severe cases--death. Contact with different bacteria can cause fever,
headaches, vomiting, diarrhea, and kidney damage. In addition,
illnesses that can be contracted from diseased animals continue to
raise concerns. According to USDA officials, the transmission of
disease from animals to humans in the meat and poultry industry is
uncommon because of concerted efforts in the United States and abroad.
However, recent outbreaks of bovine spongiform encephalopathy among
cattle (commonly known as "mad cow disease") are related to incidences
of a disease that affects humans, according to the Centers for Disease
Control and Prevention. While beef consumption is recognized as a mode
of infection, it is unknown whether this disease can be transmitted in
other ways, such as exposure to waste or blood.
Workers can also suffer back injuries or other types of injuries from
overexertion, including sprains, strains, tears, hernias, and fatigue.
They can suffer injuries, and even death, from falling or being struck
by an object. For example, workers have been killed by falling ice and
forklift parts, and falls due in part to a lack of functioning safety
devices. In one incident, an employee was killed when a rack of sausage
fell from a manual overhead conveyor system and struck him.
Workers can be burned by heat sealant machines when they wrap meat.
Workers may also sever fingers or hands or even lose limbs on machines
that are either improperly locked or inadequately guarded. For example,
in 2002, a sanitation worker at an Alabama plant lost both legs when
another worker activated the meat grinder in which he was standing. In
another incident, an employee dropped his knife into a meat grinder,
reached in to retrieve it, and suffered the amputation of his arm. In
yet another incident, an employee's fingers were amputated when they
were caught in the mixing and blending machine he was operating.
Workers can be injured by falling on slippery floors and exposure to
extreme heat or cold. Such cold temperatures can stress joints and
exacerbate existing conditions such as arthritis and cardiovascular
illnesses. As shown in figure 5, workers may sustain many types of
injuries, and several different parts of the body may be affected.
Figure 5: Nature of Injuries Sustained by Meat and Poultry Workers and
Parts of the Body Affected:
[See PDF for image]
[End of figure]
As shown in figure 6, workers in the meat and poultry industry
typically wear several types of safety and other equipment in an effort
to protect themselves from injury and illness.
Figure 6: Safety and Other Equipment Worn by Meat and Poultry
Production Workers:
[See PDF for image]
[End of figure]
Injury and Illness Rates Have Declined but Remain among the Highest of
Any Industry:
Injury and illness rates in the meat and poultry industry fell steadily
from 1992 to 2001, according to BLS data (see fig. 7).[Footnote 24] The
meat and poultry industry's annual rate of incidence of illness and
injury in 2001, at an estimated 14.7 cases per 100 workers, was about
half its 1992 rate of 29.5 cases.[Footnote 25] The incidence rate
across all U.S. manufacturing dropped to about two-thirds of its former
rate over the same period, from 12.5 cases to 8.1 cases per 100 full-
time workers.
Figure 7: Trends in Injury and Illness Rates in the Meat and Poultry
Industry, Compared with Trends in All U.S. Manufacturing, 1992 to 2001:
[See PDF for image]
[End of figure]
Despite this decrease, injury and illness rates among meat and poultry
plants remain among the highest of any industry. According to BLS data
on injuries and illnesses, in 2002, meatpacking plants recorded an
average annual injury and illness rate of 14.9 cases per 100 full-time
workers; sausages and other prepared meats plants recorded a rate of
10.9 cases; and poultry plants recorded a rate of 9.7 cases. The
average annual injury and illness rate for all U.S. manufacturing was
7.2 cases.
Within the meat and poultry industry, the incidence rate for specific
injuries and illnesses, as reported by employers, dropped in recent
years. According to BLS data on injuries and illnesses, for example,
carpal tunnel injuries dropped from 24 cases per 10,000 workers in 1992
to 6.8 cases in 2001; strains and sprains dropped from 189.4 cases to
51.9 cases; tendonitis dropped from 23.6 cases to 3.5 cases; cuts and
punctures dropped from 76.2 cases to 17.9 cases; chemical burns dropped
from 9.6 cases to 4.4 cases; and amputations dropped from 5.3 cases to
3.2 cases.
Compared with workers in all U.S. manufacturing industries, meat and
poultry workers sustain a higher rate of certain injuries, such as
chemical burns, amputations, heat burns, tendonitis, and carpal tunnel
syndrome. In 2002, meatpacking workers suffered more of these types of
injuries, but relatively fewer sprains and strains and fractures. The
rate of injuries and illnesses involving repetitive motion in the meat
and poultry industry at 22.2 cases per 10,000 full-time workers was one
and a half times greater than the rate of 14.7 for all U.S.
manufacturing in 2002.
A number of injuries sustained by meat and poultry workers are fatal;
according to BLS fatality data, from 1992 to 2002, 229 workers died
from their injuries. Of the 229 worker deaths, almost one-quarter
occurred off plant property, rather than during production, in
transportation accidents. The deaths that occurred in plants over this
period included 60 that were caused by contact with objects and
equipment (37 of these by being caught in or compressed by equipment or
objects, including running machinery); 25 by falling; 35 from exposure
to harmful substances; 4 from fires and explosions; and 22 from
assaults and violent acts, including homicides.[Footnote 26]
BLS's data on injuries and illnesses, however, may not accurately
reflect plants' incidences of injury and illness. OSHA, researchers,
and union officials have all stated that the underreporting of injuries
and illnesses is a problem in the meat and poultry industry. In the
late 1980s, after observing what appeared to be underreporting of
worker injuries, OSHA's offices in region 7 focused their attention on
the meatpacking industry.[Footnote 27] Beginning with an exhaustive
review and reconstruction of a large Nebraska meatpacker's records,
OSHA documented dozens of cases of underreporting and assessed the
company more than $2.5 million in penalties. Because of OSHA's findings
during this inspection and others like it, Congress held hearings on
the underreporting of occupational injuries from March to September
1987.[Footnote 28] In 1987, after a National Academy of Sciences review
of the methods BLS used to collect employers' injury and illness data
highlighted several deficiencies, and in response to the congressional
hearings, BLS began a multi-year effort to redesign and test an
improved safety and health statistical system for collecting these
data, which was fully implemented in 1992.[Footnote 29] However, the
accuracy of employers' occupational injury and illness data remains a
concern. OSHA conducted a series of record-keeping inspections of meat
and poultry plants in region 7 throughout the late 1980s and 1990s. As
a result of these inspections, several plants were assessed penalties
for record-keeping violations, including five plants that were assessed
penalties ranging from $290,000 to $998,360. OSHA continues to find
some measure of underreporting of employers' injury and illness
information through the agency's record-keeping audits each year.
In addition, we reported in 1998 that the U.S. Immigration and
Naturalization Service (now the Citizenship and Immigration Services)
had often found illegal aliens employed in meatpacking plants; one
agency official estimated that up to 25 percent of workers in
meatpacking plants in Nebraska and Iowa were illegal aliens. As
recently as March 2004, as the result of an internal audit, one large
meatpacking company found 350 undocumented workers employed in one of
its plants in the Midwest. Because large numbers of meat and poultry
workers are immigrants--and perhaps employed illegally--they may fear
retaliation or loss of employment if they are injured and cannot
perform their work, and they may be hesitant to report an injury.
Furthermore, according to data from OSHA and academic researchers
published in a BLS periodical, some plants offer employees or groups of
employees incentives, such as money or other prizes, for maintaining
low injury and illness rates.[Footnote 30] According to the report,
while these incentives may improve safety, they also may discourage
workers from reporting injuries that could result in their not winning
the incentive prize or preventing an entire group of workers from
obtaining the prize. In addition, some plants judge the performance of
line supervisors based on the number of days their workers go without
an injury or illness. These supervisors, also influenced by performance
incentives, may underreport injuries or encourage workers not to report
injuries or illnesses.[Footnote 31] Several of the plant officials we
interviewed told us that they provide incentives and rewards to
employees or groups of employees who work for extended periods of time
without injury.
Many Factors Affect Injury and Illness Rates:
Injury and illness rates may be affected by many factors, such as
employer or employee emphasis on safety, the amount and quality of
training, employee turnover rates, and the speed of the production
line.
Officials from a company, union, or trade association may take steps
that affect worker safety and health. For example, a company may form a
plant safety committee that reviews incidents of injury and illness to
identify safety issues and take steps to address weaknesses. In
addition, company officials may influence worker safety and health by
showing their commitment to safety through actions such as establishing
medical safety management programs at the plants, providing personal
protective equipment to workers, and disciplining workers who do not
follow safety procedures.[Footnote 32] Unions can also play a role in
worker safety and health by negotiating with company officials to take
a more proactive approach to addressing work conditions. Trade
associations may offer training courses and conferences on safety
issues, guidance on meeting OSHA requirements, and other assistance to
companies in improving safety and health.
Both OSHA and industry officials noted that training is a critical
factor in worker safety and health. Companies provide employee training
in a number of forms, including classroom instruction, on-the-job
training, and written and video training materials (generally in
English and Spanish). Meat and poultry plants typically offer several
days of training at the beginning of a worker's employment covering
both job-specific and general safety training. Plants periodically
offer additional training classes or updates--many of which are
mandatory--such as annual refreshers on workplace safety and health.
Many plants also offer or require annual specialized training on safety
issues, such as knife sharpening, which can reduce strain on line
workers, and accident prevention such as "lock-out/tag-out" procedures
that ensure that machinery is manually locked or disconnected from a
power source when not in use and tagged to note that it has been locked
or should not be used. In addition, one plant assigns mentors, or
buddies, to new workers to help them work more safely in an
introductory period.
Turnover rates can also affect the safety and health of workers.
Turnover tends to be high in the meat and poultry industry and,
according to a report by USDA's Economic Research Service, turnover
rates of 100 percent a year or more are not uncommon.[Footnote 33] High
turnover can affect safety and health at meat and poultry plants,
according to one plant safety official, because new employees are more
likely to sustain an injury or illness than more experienced workers.
In the first few months of employment, an employee may take shortcuts-
-because of the lack of familiarity with proper procedures--that
increase his or her vulnerability to injury or illness. Plant officials
often attribute high turnover to difficult working conditions, extreme
temperatures, and the fact that many of the industry's jobs are
physically demanding and stressful.
The speed at which production employees are expected to work, often
determined by the speed of the production line, or line speed, may also
be an important factor influencing their safety and health. The faster
the pace at which the production line moves, the less able workers may
be to perform tasks needed for safety. For example, according to
industry research, at certain line speeds workers may be unable to take
the seconds required to perform certain critical tasks, such as the
frequent sharpening of knives, to ensure that their jobs can be
conducted safely. Some respondents to our survey also noted that line
speed is an important factor affecting worker safety and health. While
some trade association representatives and plant officials told us that
the risks associated with line speed can be mitigated by adding more
workers to the line or rotating workers to other jobs, advocacy group
and union representatives have discounted that argument, stating that
some plants may not have either the additional employee resources to
add to the line or the additional space in the line configuration
needed to add more workers.
Line speed is regulated by USDA to permit adequate inspection by food
safety inspectors. According to USDA, when the maximum speeds were
originally set and when they are adjusted by the agency, the safety and
health of plant production workers is not a consideration. OSHA has
made recommendations to companies to slow their line speed, as well as
to make other safety improvements when citing companies for repetitive
motion injury issues, according to an OSHA official. Research is
lacking, however, on the full effects of line speed on worker safety
and health. Industry and OSHA officials told us that the differences
across slaughter and cutting lines prevent systematic comparison,
analysis, and regulation of line speed. According to these officials,
because machinery is arrayed differently on each line, research that
might isolate ergonomic limits and improvements, or examine the
incidence of other line-related injuries, is difficult to accomplish.
However, a memorandum issued in 2000 by Nebraska's Lieutenant Governor
recommended that OSHA "undertake a legitimate study of the speed of the
line in meatpacking plants" and that "the industry should work
cooperatively on that study."[Footnote 34] NIOSH officials and
nongovernmental ergonomic experts told us that line speed should be
further researched in order to understand its impact on worker safety
and health.
While USDA has established regulations on line speed, the purpose of
the agency's authority is not to protect workers, but to protect
consumers. USDA sets maximum line speeds based on how quickly its
inspectors can properly inspect the carcasses to ensure the safety of
the meat. According to trade association officials we interviewed,
plants set their line speeds at a rate at or below the maximum while
considering such factors as (1) the speed at which employees can work
and still produce a quality product and (2) the number of animals that
need to be processed. While a high-ranking OSHA official we spoke to
stated that he believed that the agency has the regulatory authority to
set its own line speed maximums, he also said that it would be a
difficult area to regulate.
While OSHA's Programs May Have Improved the Safety and Health of Meat
and Poultry Workers, Programmatic Weaknesses Make Determining
Effectiveness Difficult:
OSHA has several efforts that target the meat and poultry industry, and
there is some evidence that these efforts have had a positive effect on
worker safety and health. However, the criteria OSHA uses to select
worksites for inspection may allow some plants with high injury and
illness rates to avoid inspection. OSHA's selection criteria do not
require the agency to examine trends in worksites' injury and illness
rates in order to select plants for inspection that have recently
reported significant changes in their rates. In addition, some of the
data on which OSHA bases its selection may be underreported and are
incomplete. Furthermore, OSHA's data collection efforts make
determining program results difficult.
Some of OSHA's Enforcement Efforts Target Compliance in the Meat and
Poultry Industry:
Some of the inspections of employer compliance with federal safety and
health standards that OSHA conducts are of meat and poultry worksites.
As shown in table 2, OSHA conducted about 1,900 inspections of plants
in the meat and poultry industry from 1995 to September 15,
2004.[Footnote 35] These inspections represented less than 1 percent of
OSHA's total inspections.
Table 2: OSHA Inspections in the Meat and Poultry Industry, 1995 to
2004:
Year: As of Sept. 15, 2004;
Number of inspections in the meat and poultry industry: 154;
Number of inspections in all U.S. manufacturing: 6,489;
Total number of inspections: 29,229.
Year: 2003;
Number of inspections in the meat and poultry industry: 193;
Number of inspections in all U.S. manufacturing: 8,777;
Total number of inspections: 39,718.
Year: 2002;
Number of inspections in the meat and poultry industry: 169;
Number of inspections in all U.S. manufacturing: 8,913;
Total number of inspections: 39,076.
Year: 2001;
Number of inspections in the meat and poultry industry: 160;
Number of inspections in all U.S. manufacturing: 8,145;
Total number of inspections: 36,500.
Year: 2000;
Number of inspections in the meat and poultry industry: 179;
Number of inspections in all U.S. manufacturing: 8,425;
Total number of inspections: 35,110.
Year: 1999;
Number of inspections in the meat and poultry industry: 252;
Number of inspections in all U.S. manufacturing: 8,985;
Total number of inspections: 36,018.
Year: 1998;
Number of inspections in the meat and poultry industry: 289;
Number of inspections in all U.S. manufacturing: 8,957;
Total number of inspections: 34,080.
Year: 1997;
Number of inspections in the meat and poultry industry: 212;
Number of inspections in all U.S. manufacturing: 9,886;
Total number of inspections: 35,916.
Year: 1996;
Number of inspections in the meat and poultry industry: 158;
Number of inspections in all U.S. manufacturing: 7,281;
Total number of inspections: 25,850.
Year: 1995;
Number of inspections in the meat and poultry industry: 168;
Number of inspections in all U.S. manufacturing: 7,727;
Total number of inspections: 26,399.
Year: Total;
Number of inspections in the meat and poultry industry: 1,934;
Number of inspections in all U.S. manufacturing: 83,585;
Total number of inspections: 337,896.
Source: OSHA's inspections database.
[End of table]
OSHA also has efforts that focus on solutions to injuries prevalent in
the meat and poultry industry, such as repetitive stress disorders. For
example, OSHA's current ergonomics inspection plan uses its worksite-
specific injury and illness database to identify workplaces in
industries with higher than average injury rates. OSHA focuses its
ergonomics inspection resources on industries with relatively high
rates of injuries that appear to be related to ergonomic hazards. In
addition, OSHA's regional or area offices may implement local emphasis
programs in industries with high musculoskeletal disorder or repeated
trauma rates and known ergonomic hazards.[Footnote 36] The agency also
responds to employee complaints about ergonomic hazards.
OSHA Has Involved the Meat and Poultry Industry in Its Cooperative
Programs:
In 2002, OSHA formed an alliance with the American Meat Institute to
promote safe and healthful working conditions for meat industry
workers.[Footnote 37] The alliance is meant to help reduce ergonomic
hazards in the workplace. It sets specific goals and priorities; key
among them is for both OSHA and the institute to develop and
disseminate information and guidance, particularly through their Web
sites. The goal is to provide the institute's members and others in the
meat industry with information to help protect workers' health and
safety, with a focus on reducing and preventing exposure to ergonomic
hazards. The alliance also calls for both organizations to provide
training on ergonomics techniques, program structure, and applications
in the meat industry. Another goal is for OSHA and the American Meat
Institute to promote and encourage the institute's members to
participate in OSHA's cooperative programs such as the Voluntary
Protection Programs and mentor other members in helping them qualify
for participation.
The American Meat Institute also assists OSHA in maintaining and
updating information on safety and health in the meat industry on its
Web site. The institute, along with other stakeholders, provided
information to OSHA for the safety and health topics page on the
agency's Web site entitled "OSHA Assistance for the Meat Packing
Industry," and the agency's Web-based training tool ("eTools") for
ammonia refrigeration.[Footnote 38] OSHA provides information on eTools
on many topics pertinent to the meat and poultry industry, including
ammonia refrigeration, machine guarding, lock-out/tag-out procedures,
poultry processing, confined space, and ergonomic hazards.
Through its Strategic Partnerships Program, OSHA has established
national and regional partnerships within the meat and poultry
industry. OSHA has partnered with companies such as:
* Tyson Foods. Initiated in 2001, this partnership covers two poultry
processing facilities. The 5-year agreement has a goal of improving and
strengthening the company's safety and health management systems,
reducing injuries and illnesses, and serving as a model for improved
worker protection throughout the company.
* ConAgra Refrigerated Foods. This multiregional partnership, which
ended in January 2002, was meant to improve safety and health programs
and improve the relationship among OSHA, ConAgra, and the United Food
and Commercial Workers union and to prepare plants working toward
participation in OSHA's Voluntary Protection Programs.
* Odom's Tennessee Pride Sausage Inc. Through its regional partnership
with OSHA's region 6, Odom's has committed to reducing its illness and
injury rates and working toward participation in OSHA's Voluntary
Protection Programs.
OSHA's Omaha area office has implemented the following two
partnerships:
* Nebraska's meat processing industry. In February 2000, members of
Nebraska's meat processing industry and OSHA initiated a voluntary
partnership program intended to address the high fatality, injury, and
illness rates that have plagued the industry. The group meets bimonthly
to learn about current safety and health practices, share safety-
related best practices that have proven successful in their facilities,
and discuss safety issues of concern to participants. Company
representatives provide injury and illness data to OSHA for tracking
purposes on a semiannual basis.
* Nebraska cleaning and sanitation companies. Citing the hazardous
working conditions encountered by employees of companies that provide
contract cleaning and sanitation services to meat and poultry plants,
in 2003, OSHA's Omaha Area Office decided to establish a partnership
with these companies in order to help reduce injuries and illnesses.
Representatives of five companies have committed to a regional
partnership with OSHA's region 7 in an effort to work cooperatively and
collaboratively to reduce workplace fatalities, injuries, and illnesses
common to cleaning contractors such as strains, lacerations,
contusions, burns, fractures, amputations, dermatitis, and crushing
injuries. The goals of the partnership are to reduce days away from
work by 4 percent and to improve existing safety and health management
programs.
OSHA has not, however, implemented programs similar to the Omaha Area
Office's partnerships in other areas of the country with large
concentrations of meatpacking plants or extended this type of program
to poultry plants. A high-ranking OSHA official told us that each area
office develops its own initiatives, which may be directed at other
industries or hazards than those in the meat and poultry industry. In
addition, according to the official, there were individuals in the
Omaha office who had a keen interest in the partnering approach used in
the meatpacking industry and had the entrepreneurial spirit to start
these programs. The office has presented its approach to at least one
other office in an effort to share its experience.
Several of OSHA's Special Efforts Target the Meat and Poultry Industry:
OSHA has other special compliance efforts that target the meat and
poultry industry. For example, several pages of OSHA's Web site are
dedicated to the meat and poultry industry; they list the standards the
agency uses to combat hazards prevalent in this industry.[Footnote 39]
OSHA also has several directives specific to the industry, such as
guidance on the acceptable methods for guarding meat-cutting saws. In
addition, OSHA issues interpretations and compliance letters on issues
specific to the meat and poultry industry.
Ergonomic Guidelines for the Meat and Poultry Industry:
OSHA has also produced the following two sets of ergonomic guidelines
for the meat and poultry industry:
* Ergonomic Program Management Guidelines for Meat Packing Plants. This
document, jointly developed by OSHA and the American Meat Institute,
was developed in 1990 and contains advisory information on management
commitment and employee involvement, including preventive program
elements and detailed guidance.
* Guidelines for Poultry Processing. This document, published by OSHA
in September 2004, offers practical recommendations for employers to
reduce the number and severity of musculoskeletal disorders throughout
the industry. In developing the guidelines, OSHA reviewed existing
ergonomics practices and programs, state OSHA programs, as well as
available scientific information. OSHA also consulted with
stakeholders, such as the National Turkey Federation, to gather
information on the ergonomic problems present in the poultry-processing
environment and the practices that have been used successfully in the
industry.
Memorandum of Understanding with USDA:
Because USDA inspectors are a constant federal presence in plants, OSHA
has established agreements with USDA, the latest of which is meant to
improve compliance in meat and poultry plants. In 1994, USDA and OSHA
jointly revised an existing memorandum of understanding between the
agencies that established a process and framework for (1) training USDA
meat and poultry inspection personnel to improve their ability to
recognize serious workplace hazards within the meat and poultry
industry, (2) reinforcing procedures for meat and poultry inspection
personnel to report unsafe and unhealthy working conditions to which
they are exposed to the appropriate authorities, (3) instituting new
procedures for USDA's meat and poultry inspection personnel to refer
serious workplace hazards affecting plant employees to OSHA, and (4)
coordinating possible inconsistencies between OSHA's job safety and
health standards and USDA's sanitation and health standards.
According to the agreement, OSHA's training of USDA inspectors would
not be expected to supplant OSHA expertise in identifying serious
workplace hazards. In addition, USDA inspectors would not be trained to
recognize and refer serious workplace hazards affecting plant employees
that tend to arise only after protracted, cumulative exposure, such as
those related to repetitive motion and noise.
According to USDA officials, the memorandum was revised after a
devastating poultry plant fire in 1991 that killed 25 workers.
According to reports about the fire, the plant's fire doors had been
padlocked from the outside by the factory owner, who had locked the
doors as a "loss control technique" to prevent workers from stealing
product. A USDA poultry inspector was often present at the plant and
testified at a congressional hearing on the fire that he knew the doors
were regularly locked in violation of safety codes and had reported
this to plant officials.[Footnote 40] He did not, however, contact
OSHA.
Although the purpose of the revised memorandum of understanding was to
educate USDA inspectors on recognizing and referring workplace hazards,
the agencies' efforts to implement the agreement, such as providing
training to USDA inspectors and evaluating the effectiveness and impact
of the training, have lapsed. According to OSHA officials, although the
agency put together training materials for USDA inspectors, only one
training session was held, and only a small number of individuals were
trained. USDA officials we spoke to confirmed this, and stated that not
a lot of effort was made to train inspectors.[Footnote 41] USDA
officials told us that OSHA had proposed a week's worth of training and
that it would be very difficult to pull inspectors from their line
duties and send them to training for that length of time. In their
comments on a draft of this report, USDA officials noted that in-plant
inspectors routinely receive training on topics such as wellness,
awareness of infectious diseases, and worker health and safety.
Evidence Suggests OSHA's Programs Have a Positive Impact on Worker
Safety and Health:
Some positive outcomes have resulted from OSHA's efforts directed at
the meat and poultry industry. For example, in 2003, OSHA inspected 193
meat and poultry plants to determine their compliance with federal
safety and health standards. These inspections produced safety
improvements in several of the plants inspected, according to OSHA,
trade association officials, and some plant officials we interviewed.
In addition, according to OSHA and trade association officials, the
widespread use of the agency's ergonomic guidelines for meatpacking
plants has contributed to a decline in worker illness and injury rates
in the last decade.
OSHA's partnerships have also, according to the agency, had positive
outcomes. For example, according to information on its Web site, as a
result of OSHA's partnership with ConAgra Refrigerated Foods, many of
the company's facilities have formed new safety and ergonomics
committees with both management and union participation. According to
OSHA, five of the company's nine participating facilities experienced
significant decreases in workers' compensation costs ranging from 42
percent to 93 percent (with an average reduction of 62 percent),
suggesting a reduction in the injury and illness rates for these five
participating facilities.
Another of OSHA's partnerships, with meatpacking plants in Nebraska,
has shown some positive outcomes. According to officials from OSHA's
Omaha Area Office and some plant officials who participate in the
partnership, the group has made progress toward the goal of making the
industry safer. In addition, according to the participants, the
relationship between OSHA and Nebraska's meatpackers, which had been
strained, if not antagonistic, has improved significantly, and the
group has made tremendous progress in building cooperative, trusting
relationships. These relationships have developed not only between OSHA
and the plants, but also among the plant officials themselves.
According to officials at OSHA's Omaha Area Office, over the 4-year
existence of the partnership, the members have realized a 23 percent
reduction in injuries and illnesses resulting in days away from work or
restricted work activities. There has also been a 39 percent reduction
in total recordable injury and illness cases, a total that includes
cases resulting in days away from work, cases resulting in restricted
work, and cases requiring medical treatment. OSHA officials told us
that they consider these to be noteworthy improvements over a
relatively short period of time in an extremely hazardous industry.
Furthermore, the partnership has allowed OSHA to reach out directly to
meatpacking plants too small to meet the agency's criteria for
inspection (those with fewer than 40 employees) and provide them with
information about improving safety and health at their plants.
OSHA's memorandum of understanding with USDA has also resulted in some
positive outcomes. According to a high-ranking OSHA official, since the
revised memorandum was signed in 1994, USDA inspectors have made 31
referrals to OSHA, 26 of which resulted in an OSHA inspection. USDA
does not track this information and could not verify the number of
referrals made by its inspectors to OSHA. However, we were told by USDA
officials that the department's inspectors rarely make referrals
because workplace hazards are not the focus of their inspections. In
addition, we were told that USDA inspectors are more likely to discuss
observed hazards with plant management before referring them to OSHA,
since they have established relationships with the plants and because
the hazards could affect them as well as plant employees. Finally, OSHA
officials said that because a referral may cause OSHA to inspect the
plant, some USDA inspectors may be reluctant to make such referrals
because it could mean that OSHA would include them in the inspection
and cite them for violations, such as not wearing their personal
protective equipment.
Several meat and poultry plants have taken advantage of OSHA's various
cooperative programs. Since 1996, 391 meat and poultry worksites have
received consultation services through OSHA's On-Site Consultation
Program.[Footnote 42] In addition, OSHA has also recognized some meat
and poultry plants as having exemplary safety and health management
systems, although the relatively low numbers of participants from this
industry indicates the difficulty in meeting program requirements. As
of September 30, 2004, only 8 of the 1,180 Voluntary Protection
Programs worksites were in the meat and poultry industry. Similarly, as
of September 1, 2004, only 8 of the 844 worksites participating in
OSHA's Safety and Health Achievement Recognition Program were in the
meat industry, and no poultry plants participated in the program.
Selection Criteria May Not Trigger Inspection of At-Risk Plants, and
Data Collection Makes Assessing Effectiveness Difficult:
While the criteria OSHA uses to select worksites for inspection focuses
its limited resources mainly on plants with relatively high injury and
illness rates, the agency does not consider trends in worksites' injury
and illness rates over time. As a result, OSHA may not detect dramatic
decreases in these rates that could raise questions as to the accuracy
of the figures. This is of particular concern given the allegations of
underreporting in the industry and weaknesses in the data used to
select plants for inspection. OSHA does, however, select some worksites
with low injury and illness rates in an attempt to ascertain whether
worksites with low rates are underreporting injuries and illnesses. It
also randomly selects some worksites from high-hazard industries for
record-keeping audits designed to verify the injury and illness rates
reported to OSHA. For both of these efforts, however, OSHA selects few
meat and poultry plants. Furthermore, the data it collects on specific
worksites--kept in multiple databases--are not easily tracked, because
OSHA does not assign a unique identifier to each worksite. Therefore,
it is difficult to assess the effectiveness of OSHA's efforts to
improve safety and health.
Selection Criteria:
The criteria OSHA uses to select meat and poultry plants for inspection
target worksites that report high injury and illness rates. However,
OSHA's selection criteria do not allow it to detect anomalies in
worksites' reported injury and illness rates, because the agency does
not analyze data on plants' injury and illness rates over time.
Although OSHA surveys meat and poultry plants annually to obtain
worksite-specific data on their injury and illness rates and uses these
data to select plants for inspection, it does not review the data
collected from previous years in order to examine changes in their
injury and illness rates. In addition, these data are incomplete,
because OSHA's survey sample varies from year to year, and because OSHA
only asks employers for 1 year of injury and illness data. In 2002, we
reported the problem with OSHA collecting only 1 year's worth of data,
concluding that this limited the agency's ability to effectively
identify hazardous worksites for inspection.[Footnote 43] Area office
officials we interviewed for that report said that, in some cases, the
1-year rate was an outlier that did not reflect general worksite
operations.
The data on which OSHA bases it selections are also incomplete because,
when it surveys worksites in the meat and poultry industry, OSHA does
not ask employers to report injuries and illnesses incurred by contract
cleaning and sanitation workers who work at the plant. Because these
workers are not employees of the plant, their injuries and illnesses
are recorded by the companies for whom they work rather than on the
plants' injury and illness logs.[Footnote 44] As a result, OSHA does
not consider all injuries and illnesses in selecting meat and poultry
plants for inspection. This is a significant oversight because,
according to OSHA officials, experts, and researchers, these workers
incur high rates of injury and illness and often sustain more serious
injuries than production workers. According to information in OSHA's
inspections database, between 1998 and 2003, at least 34 contract
cleaning and sanitation workers employed in meat and poultry plants
sustained serious injuries or were killed. However, because these
injuries were recorded as occurring in another industry, none of the
injuries were reflected in the meat and poultry industry's injury and
illness rates.[Footnote 45]
A large number of workers perform this work under contract for meat and
poultry plants; we interviewed three cleaning and sanitation companies
that employ more than 5,000 workers at 140 plants across the
country.[Footnote 46] One contract cleaning company representative
reported that the biggest risk factor affecting the safety of these
workers was workers' decisions to take shortcuts, such as not properly
performing lock-out/tag-out procedures for machinery before cleaning
it. Another representative said he felt that the biggest risk factor
was the difficulty in communicating how hazardous the complex and
intricate machinery is because of language or cultural differences.
OSHA inspects the cleaning and sanitation shift during its inspections
of meat and poultry plants, whether the workers are employees of a
contract company or the plant. However, plants whose contract workers
have high injury and illness rates may not be selected for inspection
because these injuries are not included in the data OSHA uses to select
meat and poultry plants for inspection.
Because there are allegations of underreporting in the meat and poultry
industry, OSHA attempts to counter such incidences by verifying the
injury and illness rates of worksites it inspects as part of its SST
program. In addition to reviewing employers' logs during SST
inspections, OSHA also randomly selects for inspection 200 worksites
each year that report low injury and illness rates in high-hazard
industries to ensure that these worksites are not underreporting
injuries and illnesses.[Footnote 47] In 2003, 5 of the 200 worksites
selected were meatpacking plants; in 2004, 10 were meatpacking plants.
The sausage and other prepared meats industry and the poultry industry
did not have injury and illness rates that met the criteria for this
effort. Therefore, OSHA did not select any worksites in these
industries for inspection that reported low rates.
In a separate effort designed in part to combat underreporting of
injuries and illnesses, OSHA annually conducts a number of
comprehensive record-keeping audits intended to verify the accuracy of
the data on injuries and illnesses that employers submit to
OSHA.[Footnote 48] However, the selection criteria it uses allow the
agency to audit the records of only a few meat and poultry plants.
While OSHA's limited resources allow it to select few worksites in any
industry for a record-keeping audit, OSHA is not doing enough to verify
the accuracy of the data that meat and poultry plants report,
considering the dramatic decreases in this industry's reported injury
and illness rates. Of the 250 worksites OSHA selected for the audits of
2001 and 2002 data, only 3 each year were in the meat and poultry
industry.
While the criteria it uses to select worksites for inspection are
rarely altered, according to OSHA officials, in 2004, they adjusted the
criteria used to select the 200 worksites with low injury and illness
rates for inspection in order to focus on worksites with a large number
of employees. Previously, OSHA selected worksites in high-hazard
industries with a minimum of 40 employees for these inspections;
currently, it selects worksites with a minimum of 200 employees. This
change will likely have the effect of OSHA selecting even fewer meat
and poultry plants that report low injury and illness rates for
inspection, because the majority of plants have fewer than 200
employees. In addition, we were told by a high-ranking OSHA official
that the agency is considering adjusting the criteria further to double
the number of worksites with low illness and injury rates for
inspection. However, according to OSHA officials, adjusting the
criteria further--for example, to enhance the agency's focus on a
particular industry such as meat or poultry--would require additional
resources and a consideration of the effect on other industries.
Data Collection:
OSHA's data do not allow the agency to determine the impact of its
enforcement and cooperative programs on the meat and poultry industry.
To determine the impact of its efforts, OSHA could match the injury and
illness data it collects from employers to data on inspections and
employer participation in its cooperative programs. However, such
matching, which would allow the agency to better relate reductions in
injury and illness rates to its interventions, cannot be easily
performed. The data it collects on specific worksites--recorded in
multiple databases--are not easily tracked because OSHA does not assign
a unique identifier to each worksite. Without such an identifier that
can be tracked across databases, the agency is unable to easily
consolidate all the information associated with each worksite. Without
the ability to compare this information across databases, it is
difficult to assess the success of its efforts.
We attempted to assess the impact of OSHA's programs on the meat and
poultry industry by comparing worksite-specific data across its various
databases to determine an association between changes in a plant's
injury and illness rates and the agency's efforts. However, we
encountered problems because of the lack of a unique identifier for
each worksite. To match data on specific worksites without such an
identifier, we relied on other identifiers--such as the name of the
company, address, or zip code--to find the data associated with a
company over time. However, because of differences in how these
identifiers appeared in each of OSHA's databases, we could not reliably
track data for specific companies. For example, from one year to the
next, a company's name may appear differently in the various databases,
or a match on address may not produce a match for the company name.
OSHA officials we spoke to acknowledged the difficulties involved in
this type of effort. In fact, they recently encountered similar
problems in their attempts to evaluate the impact of the SST program in
2004 (see app. III for more information).[Footnote 49] OSHA's inability
to assess the effectiveness of its efforts has been a recurring
finding.
In November 2002, we recommended that OSHA take steps to assess the
impact of its SST program on workplace injuries and illnesses.
Similarly, in March 2004, we reported that OSHA's lack of comprehensive
data on its cooperative programs--such as their relative impact on
worksites' safety and health--makes it difficult to fully assess the
effectiveness of these programs.[Footnote 50] OSHA agreed with our
recommendation but pointed out that the agency's variety of strategies
reach out to different types of industries, employers, and workers,
making it difficult and costly to compare their relative effects.
Conclusions:
The dangerous and repetitive nature of the work in the meat and poultry
industry results in a variety of injuries and illnesses to workers.
Although the efforts by government, employers, and advocacy groups have
helped improve worker safety and health in this industry, and according
to BLS the number and rate of injuries and illnesses have decreased
substantially over the last decade, additional improvements could be
made. For example, the criteria that OSHA uses to select plants for
inspection, while reasonable, do not incorporate consideration of
dramatic or sudden decreases in injury or illness rates in selecting
plants for inspection. In addition, because OSHA lacks complete data on
the injuries and illnesses of meat and poultry workers, particularly
those employed by cleaning and sanitation companies, plants in need of
inspection may not be identified and selected. Further, because OSHA
does not track changes in individual plants' injury and illness rates,
or have a method for comparing these rates with data collected on
inspections or plants' participation in its cooperative programs, it
lacks a means of understanding the impact its programs have on workers
in this industry.
OSHA also lacks some of the information needed to participate more
fully in improving worker safety and health. For example, until the
effects of line speed are studied from a worker safety and health
perspective to better understand its effect on injury and illness
rates, it will be difficult for OSHA to provide meaningful input with
regard to the process of regulating the speed of the production line.
In addition, OSHA has been slow in expanding its successful efforts.
Because its most successful program aimed at improving safety and
health has not been replicated in other areas of the country, OSHA is
not allowing workers in its other jurisdictions to realize the
benefits, such as the potential for a reduced number of injuries and
illnesses, of this program. Finally, the memorandum of understanding
between USDA and OSHA is not being utilized to the full extent
possible. The efforts called for by the memorandum of understanding to
reinforce and supplement the training of USDA inspectors so they are
able to recognize and refer serious workplace hazards in meat and
poultry plants have lapsed.
Recommendations for Executive Action:
In order to strengthen the agency's efforts to improve safety and
health of workers at meat and poultry plants, the Secretary of Labor
should direct the Assistant Secretary for Occupational Safety and
Health to consider:
* adjusting OSHA's criteria for selecting worksites for SST inspections
and for record-keeping audits to consider worksites that have had large
reductions in their injury and illness rates over time;
* requiring worksites that are surveyed by OSHA to obtain worksite-
specific data on injuries and illnesses to include (1) multiple years
of data, so that trends in their rates may be analyzed and (2) data on
injuries and illnesses to workers employed by cleaning and sanitation
companies that provide workers to the plant under contract so that
these data can be included in the rates OSHA uses to select plants for
inspection;
* requiring that a common identifier for each plant be used in all of
its enforcement and cooperative program databases so that these
different data sets can be more easily compared in an effort to measure
the agency's impact on worker safety and health; and:
* expanding successful partnerships, such as the Omaha Area Office's
partnership with meatpacking plants in Nebraska to other area offices
with high concentrations of meat and poultry plants.
The Secretary of Labor should direct the Assistant Secretary for
Occupational Safety and Health and the Secretary of Agriculture should
direct the Acting Administrator of the Food Safety and Inspection
Service to:
* revisit and update their memorandum of understanding to ensure that
USDA inspectors receive training in recognizing and referring workplace
hazards and that the agreement remains current.
In addition, the Secretary of Health and Human Services should:
* direct the Director of the Centers for Disease Control and Prevention
to have NIOSH conduct a study of the effect of the speed of the
production line on workers in the meat and poultry industry, a study
that would also include other job-specific features that interact with
line speed to increase the risk of injuries and illnesses to these
workers.
Agency Comments:
OSHA, USDA, HHS, and BLS provided us with written comments on a draft
of this report, which are reproduced in appendixes IV, V, VI, and VII,
respectively. The agencies generally agreed with all of the
recommendations that applied to them.
OSHA noted that it has solicited public comments on its SST program and
will consider our suggestion to expand its selection criteria for SST
inspections. The agency also commented that it will cooperate with USDA
to encourage the revitalization of USDA inspector training and will
work with NIOSH and others to investigate the relationship between line
speed and the risk of injury. Finally, OSHA pointed out that some of
the remaining recommendations, such as expanding its data collection
efforts, could have significant impact on the agency's resources and
that it would consider these recommendations in conjunction with
decisions on how best to allocate the resources it has available.
USDA noted that, because its in-plant employees are a federal presence
in meat and poultry plants, they can help detect and report serious
workplace hazards to OSHA. The agency also noted its responsibility to
enforce the Humane Methods of Slaughter Act, emphasizing that, if in-
plant inspectors witness egregious violations of the act--such as
hoisted animals struggling or thrashing--they have the authority to
take immediate enforcement action against such firms including stopping
the production line. USDA commented that compliance with the act
indirectly improves workplace safety.
HHS agreed that there is a need to study the relationship between line
speed and musculoskeletal disorders and other injuries in the meat
industry, and stated that it would direct NIOSH to conduct such a
study. The agency noted, however, the difficulty its staff have had in
the past in gaining access to meatpacking plants to conduct research.
HHS also commented on the resource commitment that would likely be
involved for such a large and detailed, but necessary, study.
BLS noted that, although it conducted a major redesign of its annual
survey of occupational injuries and illnesses in 1992, (in part because
of concerns about the completeness of employer reporting,) there is
still some concern about underreporting of injuries and illnesses among
users of the data. The agency also noted several technical corrections
to the report, as did OSHA, USDA, and HHS, which we incorporated as
appropriate.
As arranged with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after the date of this report. At that time, we will send copies of
this report to the Secretary of Labor, the Assistant Secretary of Labor
for Occupational Safety and Health, the Secretary of Agriculture, the
Acting Administrator of the Food Safety and Inspection Service, the
Secretary of Health and Human Services, and the Director of the Centers
for Disease Control and Prevention. We will also make copies available
to others upon request. In addition, the report will be available at no
charge on GAO's Web site at http://www.gao.gov.
Please contact me or Revae Moran on (202) 512-7215 if you or your staff
have any questions about this report. Other contacts and staff
acknowledgments are listed in appendix VIII.
Signed by:
Robert E. Robertson:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Scope and Methodology:
For this report, we attempted to (1) describe the characteristics of
workers in meat and poultry slaughter and processing plants and the
conditions in which they work; (2) identify the types of injuries and
illnesses workers in meat and poultry slaughter and processing plants
incur, how the injury and illness rates have changed over the past
decade, and the factors that may have affected these rates; and (3)
determine what is known about the effectiveness of the Occupational
Safety and Health Administration's (OSHA) efforts to improve safety and
health at meat and poultry slaughter and processing plants. To address
these objectives we:
* obtained and analyzed relevant data from the Bureau of Labor
Statistics (BLS) on worker demographics and workplace injuries,
illnesses, and fatalities; OSHA's inspection database; the data OSHA
uses to target specific worksites for inspection; and information on
plants that participate in OSHA's cooperative programs;
* conducted a survey of meat and poultry plants to obtain data on their
workers, factors that affect their injury and illness rates, plants'
efforts to improve safety and health, and plants' interactions with
OSHA;
* interviewed officials from OSHA and other federal agencies, such as
the U.S. Department of Agriculture (USDA) and the Centers for Disease
Control and Prevention's National Institute for Occupational Safety and
Health (NIOSH) within the Department of Health and Human Services
(HHS), as well as individuals from contract cleaning and sanitation
companies, unions, advocacy groups and key trade associations; and:
* visited six meat and poultry plants.
Reliability of USDA's, BLS's, and OSHA's Data:
To determine the number, location, and regional distribution of plants,
we examined USDA's Food Safety and Inspection Service's Performance
Based Inspection System database. This management system integrates
weekly schedules of inspection tasks; documents inspection findings
including deviations, deficiencies, and corrective actions; and
provides a database for the automatic data-processing support system.
To describe the characteristics of workers employed in the meat and
poultry slaughter and processing industries, we obtained demographic
estimates for meat and poultry workers and for the manufacturing
industry as a whole from BLS's Current Population Survey (CPS) March
supplement for 2004 and 1995. The CPS is a monthly survey of households
conducted by the U.S. Census Bureau for BLS. The CPS, a sample of
60,000 households, provides a comprehensive body of information on the
employment and unemployment experience of the nation's population,
classified by age, sex, race, and a variety of other characteristics.
Because the CPS estimates are based on probability samples, they are
subject to sampling error. Slightly different estimates could result
from different samples. We express our confidence in the precision of
our particular sample's results as a 95 percent confidence interval.
This is the interval that would contain the actual population value for
95 percent of the samples we could have drawn. As a result, we are 95
percent confident that each of the confidence intervals in this report
will include the true values in the study population.
For the CPS estimates in this report, we estimated sampling error and
produced confidence intervals using the methods provided in the
technical documentation for the 2004 and 1995 March supplements. All
CPS percentage estimates contained in this report have 95 percent
confidence intervals within plus or minus 8 percentage points of the
estimate itself. All other CPS estimates contained in this report have
95 percent confidence intervals within plus or minus 14 percent of the
estimate itself, unless otherwise noted.
We also reviewed data on injuries and illnesses, collected and
published by BLS through its Survey of Occupational Injuries and
Illnesses, for calendar years 1992 to 2002, as they related to workers
in the meat and poultry industry. BLS's Survey of Occupational Injuries
and Illnesses provides estimates of the number and frequency (incidence
rates) of workplace injuries and illnesses based on logs kept by
private industry employers during the year. Survey estimates are based
on a scientifically selected sample of worksites, some of which
represent only themselves but most of which also represent other
employers of like industry and workforce size that were not chosen in a
given survey year. Besides providing injury and illness counts, survey
respondents also are asked to provide additional information for a
subset of the most serious nonfatal cases logged, namely, those that
involved at least 1 day away from work, beyond the day of injury or
onset of illness. Employers answer several questions about these cases,
including the demographics of the worker disabled, the nature of the
disabling condition, and the event and source producing that condition.
BLS calculates relative standard errors for all estimates it tabulates
(see BLS's Web site for more information). These relative standard
errors were used to develop 95 percent confidence intervals for each
estimate. In this report, all estimates of incidence rates have 95
percent confidence intervals of within plus or minus 14 percent of the
estimated incidence rate. For example, the estimated rate for
tendonitis in 1992 was 23.6 cases per 10,000 full-time meat and poultry
workers. Since 14 percent of 23.6 is 3.3, the confidence interval for
this interval is within 20.3 to 26.9 cases per 10,000 full-time
workers.[Footnote 51]
We also reviewed data on fatalities, collected and published by BLS
through its Census of Fatal Occupational Injuries for calendar years
1992 to 2003 as they related to workers in the meat and poultry
industry. BLS's Census of Fatal Occupational Injuries is a federal-
state cooperative program that has been implemented in all 50 states
and the District of Columbia since 1992. To compile fatality counts
that are as complete as possible, the census uses multiple sources to
identify, verify, and profile fatal worker injuries. Information about
each workplace fatality--occupation and other worker characteristics,
equipment involved, and circumstances of the event--is obtained by
cross-referencing the source records, such as death certificates,
workers' compensation reports, and federal and state agency
administrative reports. To ensure that fatalities are work-related,
cases are substantiated with two or more independent source documents
or a source document and a follow-up questionnaire. Data compiled by
the program are issued annually for the preceding calendar year. We
report the 2003 data in a footnote because the data are not comparable
with data from previous years. According to BLS, the new industry and
occupational classifications the agency is required to use may, in some
instances, have different definitions than the classification system
used previously.
To analyze the extent to which OSHA interacts with meat and poultry
plants through its enforcement programs, we analyzed inspections data
for fiscal years 1996 to 2004 from OSHA's Integrated Management
Information System and worksite-specific injury and illness data
collected by OSHA. We assessed the completeness of these data by
reviewing OSHA's documentation on how the data were collected and
performed electronic tests to look for outliers, missing values, and
duplicate records. On the basis of these reviews and tests, we found
the data sufficiently reliable for our purposes. In addition, for
OSHA's inspections data, we obtained and reviewed documentation of
internal controls.
We analyzed the data that OSHA uses to target specific worksites for
inspection through its SST program. These data are collected by OSHA
through its annual Data Initiative, which is a nationwide collection of
worksite-specific injury and illness data from approximately 80,000
worksites. OSHA collects data from worksites by using the OSHA Work-
Related Injury and Illness Data Collection Form.
To report on the extent that meat and poultry plants participate in
OSHA's various cooperative programs, we analyzed OSHA's consultation
database, its lists of Voluntary Protection Programs and Safety and
Health Achievement Recognition Program sites, and its lists of current
alliances and strategic partnerships.
We interviewed USDA, OSHA, and BLS officials to establish the
reliability of the data. We found the data to be sufficiently reliable
for our purposes.
Analysis of BLS's CPS and Injury and Illness Data:
We explored, for this report, different ways in which the CPS and BLS's
injury and illness data could be used to track changes in injury and
illness rates for various groups of workers and discovered several
limitations. For example, we analyzed CPS data on worker demographics
by industry and data on injuries and illnesses sustained by workers.
Using the two data sets, we attempted to determine whether workers in
certain demographic groups--such as males and females, whites and
minorities, and younger and older employees--were sustaining more
injuries or illnesses now than would be expected, taking into account
the number of individuals in these demographic groups. We also
attempted to estimate differences in injury rates, or in the likelihood
of being injured, between certain worker demographics, such as gender,
race, and age. However, a large percentage of cases in the meat and
poultry industry that were reported to BLS--24 percent in 2002--lacked
data on the race of the injured worker since race is not a required
reporting item.[Footnote 52] Because of this lack of data, it was not
possible to determine whether workers of a certain race were
disproportionately injured.
First, BLS's data on injuries and illnesses cannot be used by
themselves to estimate injury rates or the likelihood of being injured,
since those data include only information on workers who were injured,
but not on workers who were not injured. While BLS's injury and illness
data could be used to estimate the numbers of workers in the meat
products industry at risk of being injured, overall and in each of the
subgroups of interest to us, its injury and illness data do not provide
demographic information (e.g., data on race, sex, or age) on all
workers who were injured, but only those workers whose injuries were
serious enough to have resulted in the workers requiring time off from
work. While we might have merged information from BLS's injury and
illness data and information from the CPS in order to estimate rates of
injuries requiring time off, and differences in those rates across
subgroups, that task was complicated by the fact that there was
considerable information missing on race, which was one of the factors
of greatest interest to us. Because BLS does not require the various
states and industries surveyed to disclose the race of employees
injured, some choose not to, and ultimately race is unknown for roughly
one in every four persons injured.
In addition, we could have estimated differences in the rates of injury
and illness requiring time off across sex and age categories. However,
the lack of detailed information in the CPS on the types of jobs held
by workers employed in the meat products industry would not have made
it possible for us to determine whether differences in injury and
illness rates across age and sex categories was a result of differences
in these demographic characteristics or the result of women and older
employees having different types of jobs than men and younger workers.
Survey of Meat and Poultry Plants:
To obtain information about safety and health and the characteristics
of their workforce, we administered a survey to a sample of meat and
poultry plants. Our survey population consisted of plants represented
in OSHA's worksite-specific injury and illness database for years 1999
to 2002. This database contains annual information on occupational
injuries and illnesses at the worksite (plant) level. The data on
worksites, operating in what are considered high-hazard industries,
have been collected since 1995. Since the data for approximately one-
third of all existing plants above a certain size are updated in the
database in any particular year, we included in our sample, all plants
included in the database during the most recently available 4-year
period (1999 to 2002). The specific industries on which we focused were
meat and poultry plants in Standard Industrial Classification code 201-
-the meat products industry--including those in meatpacking plants,
code 2011; the sausages and other prepared meat products industry, code
2013; and the poultry slaughtering and processing industry, code 2015.
Sample Design:
Our survey sample included all plants from the database with more than
1,250 employees. The remaining plants were stratified by industry,
using the three Standard Industrial Classification codes for each of
the three industries that encompass the meat products industry. We drew
a random sample from each of these three industries.
From our total sample of 420 plants, 24 were eliminated for various
reasons, including the fact that the plant had gone out of business,
the plant was not a meat or poultry plant, or the plant was duplicated
elsewhere in our sample.
Survey Administration and Response Rates:
To develop our questionnaire, we consulted with officials at the
American Meat Institute and the United Food and Commercial Workers
union, and experts at GAO. We pretested a draft of the questionnaire
with six companies in the meat products industry. We mailed the
questionnaire, addressed to the plant safety director (or other
appropriate management personnel), requesting information on the
demographic characteristics of the plant's workforce, the working
conditions of the plant, the safety training and related efforts
undertaken within the plant, and the plant's interaction with (and
respondent's opinions on) OSHA. The survey was conducted between July
2004 and September 2004.
The overall response rate of 23 percent compromises our ability to
generalize the findings across the population of plants and to present
statistically valid results. While the sample was designed to draw
inferences from the study population, we did not produce estimates of
the population of meat producers based on our sample results. We
arrived at this decision both because the response rate was low and
because it is likely that certain key characteristics of respondents
differ from those of nonrespondents. For example, since two major
companies refused to participate, our responses did not include the
responses of any plants from these companies; the experiences of our
respondents may differ from those of plants from these companies. Table
3 summarizes the sample sizes by industry, their disposition, and our
response rates.
Table 3: Survey Sample Sizes, Disposition, and Response Rates:
Industry sector: Meatpacking plants with 1,250 employees or fewer;
Population[A]: 393;
Sample: 101;
Out of scopes[B]: 4;
Responses received: 26;
Refused to participate: 26;
Response rate: 27%.
Industry sector: Sausage and other prepared meat products plants with
1,250 employees or fewer;
Population[A]: 407;
Sample: 121;
Out of scopes[B]: 5;
Responses received: 42;
Refused to participate: 12;
Response rate: 36%.
Industry sector: Poultry slaughtering and processing plants with 1,250
employees or fewer;
Population[A]: 397;
Sample: 100;
Out of scopes[B]: 11;
Responses received: 19;
Refused to participate: 20;
Response rate: 21%.
Industry sector: All large meat and poultry plants with more than 1,250
employees;
Population[A]: 98;
Sample: 98;
Out of scopes[B]: 4;
Responses received: 8;
Refused to participate: 25;
Response rate: 9%.
Industry sector: Total;
Population[A]: 1,295;
Sample: 420;
Out of scopes[B]: 24;
Responses received: 95;
Refused to participate: 83;
Response rate: 23%.
Source: GAO analysis.
[A] The population values represent the number of plants in OSHA's
worksite-specific injury and illness database between 1999 and 2002.
[B] "Out of scopes" include plants that did not slaughter or process
meat or poultry or that were no longer in operation at the time of
survey administration.
[End of table]
Because of our low response rate, we did not use the data obtained from
the survey to draw conclusions about the meat and poultry industry.
Instead, we used the responses to illustrate some of the information
provided from other sources in our report, such as opinions about OSHA
as a factor in the safety and health of workers. We also used the data
to provide examples about the range of responses we found. For example,
we reported that one plant had an employee turnover rate that could
reach 200 percent from data obtained from our survey.
Interviews with OSHA Area Offices:
To describe the variety and extent of OSHA efforts within the meat and
poultry industry, we interviewed officials from four OSHA regional
offices. We selected these regional offices based on information from
OSHA's inspections database, which contains data on inspections and
fines levied by OSHA. We examined the inspections data to determine the
regional offices that had conducted the highest number of inspections
from January 2003 to July 2004 for plants in Standard Industrial
Classification codes 2011, 2013, and 2015. From these interviews, we
obtained information about their activities in the meat and poultry
industry within their respective regions, including any regional and
local emphasis programs, their perspectives on factors affecting the
safety and health of workers in this industry, and coordination efforts
between their offices and USDA.
Visits to Meat and Poultry Plants:
During the course of this review, we visited six meat and poultry
plants. Of the six plants, we visited four (two beef, one pork, and one
poultry slaughter and processing plant) to obtain a better
understanding of the work performed by workers in meat and poultry
plants and the conditions in which they work. During these visits, we
toured the plants and spoke to plant officials about worker
demographics, plant operations, injury and illness history, and their
experiences with and opinions of OSHA. Three of these four plants were
selected because they were located in an area of the country where meat
production is high; the other was close to our headquarters office. We
visited two additional plants for the purpose of pretesting our survey
instrument; we did not tour these two plants.
[End of section]
Appendix II: Interviews with Cleaning and Sanitation Companies:
We interviewed three cleaning and sanitation companies that provided
contracted services to meat and poultry plants. In total, these three
companies employed over 5,000 non-union workers and operated in 140
different plants across the country. One company representative told us
the company had contracts to operate in plants owned by some of the
largest companies in the meat and poultry industry.
In general, all three cleaning and sanitation companies employed
workers who tended to be young and Hispanic. The companies supplied
small plants with crews as small as 1 or 2 employees and large plants
with crews as large as 150 employees. According to representatives from
these companies, cleanup shifts at plants can range from only 2.5 hours
to 12 hours, but typically shifts lasted less than 8 hours. While the
majority of time is spent cleaning the slaughter and process areas, at
many plants the crews are responsible for also cleaning bathrooms and
office space. At the end of the cleanup shift each day, the slaughter
and process areas must pass a USDA inspection in order for the plant to
restart its operations. All three companies' representatives reported
that if the plant is not cleaned within the time allotted for USDA
inspection, they must pay some type of monetary penalty to the plant.
The companies reported providing their workers with all safety and
health training. In addition, the companies employed safety auditors
who travel to various plants to examine safety issues. These
examinations may include interviewing contract workers to see if they
are aware of certain safety regulations or procedures, such as "lock-
out/tag-out" procedures, the issue cited as most important by the
companies.
With regard to the incidence of repetitive motion injuries, one company
representative stated that these types of injuries among their workers
are limited because sanitation workers perform tasks that are different
from those performed by plant workers in that they are constantly
moving around and not performing repetitive tasks. He said, however,
that conditions such as working at night, sweating from the steam,
freezing from the cold, and being wet all the time contribute to the
high turnover for his employees.
[End of section]
Appendix III: OSHA's Study on Its Impact Using Establishment-Specific
Targeting of Interventions:
In November 2002, we recommended that OSHA take steps to assess the
impact of its SST program on workplace injuries and illnesses.[Footnote
53] OSHA has since conducted its first major evaluation of the
effectiveness of the SST program and, in 2004, issued a report
detailing the results of its evaluation.[Footnote 54] The report states
that worksites experienced statistically significant cumulative 3-year
reductions in the number of injuries and illnesses as a result of
OSHA's efforts.[Footnote 55] However, while these results indicate
positive outcomes, the study did not attempt to isolate the impact of
OSHA's efforts from other factors--such as employers' own safety
programs--that may have as much or more of an influence on injuries and
illnesses. In fact, several employers who responded to our survey
stated that the reduction in their injury and illness rates could be
attributed to other factors that they claimed worked in addition to, or
in place of, OSHA's efforts, and that these other factors were as
important in achieving safety and health improvements.
In performing this evaluation of its SST program, OSHA encountered
difficulties in identifying worksites across databases and dealing with
the incompleteness of certain data fields.[Footnote 56] While not
invalidating the conclusions in its report, the difficulties OSHA
encountered suggest that the data collection for its worksite-specific
injury and illness database could be improved. In particular, OSHA did
not consistently assign a unique identifier to each plant, which made
it difficult to compare information across databases. This issue,
combined with a lack of information in the 2004 report concerning how
the model was developed and tested, points to a need to use caution in
interpreting the report's results.
[End of section]
Appendix IV: Comments from the Occupational Safety and Health
Administration:
U.S. Department of Labor:
DEC 15 2004:
Assistant Secretary for Occupational Safety and Health:
Washington, D.C. 20210:
Mr. Robert E. Robertson:
Director, Education, Workforce and Income Security Issues:
U.S. Government Accountability Office:
441 G Street NW, Room 5930:
Washington, DC 20548:
Dear Mr. Robertson:
Thank you for this opportunity to respond to the Government
Accountability Office's (GAO) report on safety and health in the meat
and poultry industries. GAO's acknowledgement of the Occupational
Safety and Health Administrations (OSHA) efforts to address workplace
safety and health issues in this important sector is appreciated.
OSHA recognizes the benefits of the data collection and analysis
conducted by GAO for this report and the findings resulting from GAO's
analysis. The study notes a decrease in injuries and illnesses for the
meat and poultry industry between 1992 and 2001, which OSHA has also
noted in many other high-hazard industries. GAO's study notes the
possibility of the under-reporting of injuries and illnesses as a
possible factor in the decline of injury and illness rates in the meat
and poultry industries. OSHA recognizes the central importance of
accurately reported injury and illness data for meeting its mission,
and will continue to monitor and carefully analyze data from the full
spectrum of high-hazard industries to appropriately allocate its
resources.
As GAO has further noted, there has been a shift in worker demographics
in this industry. This shift has resulted in impacts on the traditional
workforce with regard to, among other things, organized representation,
the increasingly large role of contract cleaning workers, training
challenges for this transient workforce, and the competitive business
pressures that have permanently affected the future of the industry.
OSHA has expanded its mix of traditional and new initiatives to address
these challenges. Some of OSHA's responses include cooperative programs
like the one in Omaha, Nebraska, recognized in the report. While OSHA
has experienced success with national and local meatpacking
partnerships, these remain voluntary initiatives. Partnership
agreements, evaluation results, and successes are shared through our
public web site, and through internal communications among the
national, regional and area offices. Some offices build on these
successes by duplicating the initiative within their jurisdiction;
other offices elect to focus on other priorities, such as those
identified in OSHA's Strategic Management Plan.
OSHA's responses to the dynamic nature of today's workplaces are not
limited to cooperative and other voluntary programs, but also consist
of new enforcement initiatives such as site-specific targeting (SST)
and local-and national-emphasis programs.
The Agency has solicited public comments on its SST program; we are
currently reviewing comments from industry associations, employers and
safety and health professionals. As we complete this review, we will
consider your suggestion to expand the criteria for SST inspections in
this industry. OSHA would also like to note that the analysis of the
SST program at the top of page 10 includes the construction-industry
sector in the inspection total. Since construction is not part of SST,
the proportion of inspections comprised of SST inspections is greater
than reported.
GAO's other recommendations --to expand data-collection efforts for
multiple years for trend analysis, inclusion of recordkeeping
submittals to capture contract workers illness and injuries, linking
the IMIS and other data processing systems to come up with unique
identifiers --all have a significant impact on OSHA's resources. We
will consider GAO's recommendations as we consider the appropriate
allocation of resources to get the most out of what is available to the
Agency.
OSHA will cooperate with the Department of Agriculture to encourage the
revitalization of the USDA-inspector training. With respect to the
recommendation for further study on line speed, there have been a large
number of studies examining the relationship between repetitive motion,
which is indirectly related to line speed, and the risk of injury.
However, additional study may be useful, particularly because
repetition acts in combination with other factors (e.g., awkward
postures, force and cold temperatures) that impact an employee's risk
of injury. Therefore, OSHA will continue to work with its partners in
NIOSH, academia and with other stakeholders to investigate these
complex multifactorial interactions.
OSHA looks forward to working with you to continue to address the
health and safety hazards for meat and poultry workers. If you have any
questions, please feel free to call Keith Goddard, Director,
Directorate of Evaluation and Analysis at (202) 693-1935.
Sincerely,
Signed by:
John L. Henshaw:
[End of section]
Appendix V: Comments from the U.S. Department of Agriculture:
United States Department of Agriculture:
Food Safety and Inspection Service:
Washington, D.C. 20250:
Robert E. Robertson:
Director:
Education, Workforce, and Income Security Issues:
United States Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Robertson:
In your letter dated November 18, 2004, you requested the U.S.
Department of Agriculture (USDA) written comments on the Draft report
GAO-05-96 "WORKPLACE SAFETY AND HEALTH: Safety in the Meat and Poultry
Industries, While Improving, Could Be Further Strengthened." Thank you
for the opportunity to provide comments on the draft report.
In general, we agree with the findings and conclusions of the report.
Since in-plant employees of the Food Safety and Inspection Service
(FSIS) are a federal presence in meat and poultry plants, they can help
detect and report serious workplace hazards to the Occupational Safety
and Health Administration (OSHA).
General Comments:
1. The full week of workplace safety training for FSIS in-plant
employees as proposed by OSHA was not implemented, but it is important
to note that in-plant FSIS employees do receive training on wellness,
awareness of zoonotic diseases, and worker health and safety. FSIS
employees may not have the expertise of OSHA employees, but, as the
report noted, FSIS employees are not expected to supplant the safety
expertise of OSHA in identifying serious workplace hazards.
2. The report indicates that some USDA inspectors may be reluctant to
make referrals to OSHA because it could mean that OSHA would include
them in the inspection and cite them for violations. Although there may
be some inspectors in the field that believe this, OSHA does not reveal
the name of an employee that files a complaint to the employer. Neither
does OSHA reveal the identity of FSIS employees that file complaints or
make referrals to OSHA. It also does not issue notices or citations to
individual Federal employees as a result of an inspection.
3. As the report noted, most workplace hazards affect FSIS and plant
employees. The referrals to OSHA from FSIS mentioned in the report
(page 39) are limited only to those referrals that affect plant
employees. In accordance with 29 CFR 1960-Elements for Federal Employee
Occupational Safety and Health Programs, Federal employees are
encouraged to report hazards to their employer. However, FSIS employees
have the right to a report a hazard to FSIS, the Department of
Agriculture or OSHA. FSIS employees may also report problems directly
to plant management, and are encouraged to do so to rectify dangerous
situations immediately. FSIS employees have several methods for
reporting workplace hazards, and the referrals to OSHA mentioned in the
report likely only represent a fraction of those reported by FSIS
employees.
4. Slaughter establishments are expected to be fully compliant with the
Humane Methods of Slaughter Act (HMSA). The situation you describe on
page 21 of the draft report of hoisted animals struggling and thrashing
wildly would be an egregious violation of the HMSA. In-plant inspectors
that witness egregious violations of the Act have the authority to take
immediate enforcement action against such firms including stopping the
production line until the slaughter process is brought under control.
Compliance with the HMSA, although related to the humane treatment of
food animals, indirectly improves workplace safety.
Please find enclosed additional specific USDA comments on the draft
report.
Sincerely,
Signed for:
Ronald F. Hicks:
Assistant Administrator:
Office of Program Evaluation, Enforcement and Review:
Enclosure:
[End of section]
Appendix VI: Comments from the U.S. Department of Health and Human
Services:
DEPARTMENT OF HEALTH & HUMAN SERVICES:
Office of Inspector General:
Washington, D.C. 20201:
DEC 13 2004:
Mr. Robert E. Robertson:
Director, Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr. Robertson:
Enclosed are the Department's comments on the U.S. Government
Accountability Office's (GAO's) draft report entitled, "Workplace
Safety and Health-Safety in the Meat and Poultry Industries, While
Improving, Could Be Further Strengthened" (GAO-05-96). The comments
represent the tentative position of the Department and are subject to
reevaluation when the final version of this report is received.
The Department provided several technical comments directly to your
staff.
The Department appreciates the opportunity to comment on this draft
report before its publication.
Sincerely,
Signed by:
Daniel R. Levinson:
Acting Inspector General:
Enclosure:
The Office of Inspector General (OIG) is transmitting the Department's
response to this draft report in our capacity as the Department's
designated focal point and coordinator for U.S. Government
Accountability Office reports. OIG has not conducted an independent
assessment of these comments and therefore expresses no opinion on
them.
COMMENTS OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES ON THE U.S.
GOVERNMENT ACCOUNTABILITY OFFICE'S DRAFT REPORT, "WORKPLACE SAFETY AND
HEALTH-SAFETY IN THE MEAT AND POULTRY INDUSTRIES, WHILE IMPROVING,
COULD BE FURTHER STRENGTHENED" (GAO-05-96):
The Department of Health and Human Services (HHS) appreciates the
opportunity to review the U.S. Government Accountability Office's
(GAO's) draft report on a serious occupational safety and health
hazard. Although the rates of work-related musculoskeletal disorders
and other injuries in the meatpacking industry have dropped in the last
decade, they continue to be high. Past attempts to reduce the hazard
through engineering and administrative controls have been met with
limited success. Typically, these attempts have not specifically
addressed the potential role of line speed as an independent risk
factor.
HHS agrees with GAO regarding the need to study the relationship
between line speed and musculoskeletal disorders and other injuries in
the meatpacking industry. As recommended, the Secretary will direct the
Centers for Disease Control and Prevention's (CDC) Director to have the
National Institute for Occupational Safety and Health (NIOSH) conduct
this study.
However, there are a few factors that need to be considered in
conducting such a study. In the past, CDC/NIOSH has had difficulty
gaining access to meatpacking plants for the purpose of conducting
research. In order to conduct this study as directed by GAO, this
barrier will need to be overcome. Also, to adequately address the "job-
specific features" that affect the risk of injuries and illnesses to
workers as GAO recommends, the study would need to take into account
other known physical hazards present in these plants (e.g., forceful
exertion and awkward postures), as well as individual factors (e.g.,
age, obesity) and work organizational factors that can impact the
occurrence of musculoskeletal disorders.
Finally, it would be necessary to consider the costs needed for such an
important study. Based on experience, undertaking this large, detailed,
and necessary study would require a commitment of resources. HHS
appreciates the recommendation of GAO and is committed to high quality
useful research that can be translated into improving worker health and
safety.
[End of section]
Appendix VII: Comments from the Bureau of Labor Statistics:
U.S. Department of Labor:
Bureau of Labor Statistics:
2 Massachusetts Ave. N.E.:
Washington, D.C. 20212:
DEC 15 2004:
Robert E. Robertson:
Director:
Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
441 G. Street, N.W.:
Washington, D.C. 20548:
Dear Mr. Robertson:
The Bureau of Labor Statistics (BLS) would like to thank the Government
Accountability Office (GAO) for the opportunity to comment on the draft
report entitled "Workplace Safety and Health: Safety in the Meat and
Poultry Industries, While Improving, Could be Further Strengthened"
(GAO-05-96). The BLS is pleased that the GAO found its data helpful in
writing this report, and the BLS would like to add the following
comments.
The BLS is very concerned that readers may incorrectly conclude that
the BLS provided confidential data to the GAO for the purpose of this
report because the data it has received from OSHA is not clearly
attributed to OSHA. In particular, information on individual injury,
illness, or fatality cases, or individual firm's safety and health
record from OSHA is not clearly separated from information that cites
BLS data on overall industry numbers, rates, or types of injuries or
illnesses. If the OSHA data are not clearly footnoted, readers might
assume both the industry statistics and the specific examples are from
the BLS.
The BLS conducted a major redesign of the annual survey of occupational
injuries and illnesses in 1992, in part due to concerns about the
completeness of employer reporting. While there is still some concern
about underreporting of injuries and illnesses among users of the data,
citing the 1987 congressional testimony seems inappropriate given the
changes in the program since that time. We urge the GAO to eliminate
these references from the report.
The GAO aggregated fatality numbers for the meat product industry for
the years 1992-2003. Beginning in 2003, when the BLS fatal workplace
injuries census began using the North American Industry Classification
System (NAICS), the definition of this industry changed. Previous
years' data were classified according to the Standard Industrial
Classification (SIC) structure. The BLS regards this as a break in
series. The data should not be aggregated across this break. We prefer
that the GAO cite the 2003 data separately if it wishes to include it
in the report.
The BLS is concerned that the citations of our data be as accurate as
possible. There are a number of different injury and illness rates
(total recordable cases, cases with days away from work, cases with
days away from work, job transfer, or restriction) and a range of
detailed statistics for different components of the meat products
industry. It is incumbent on the GAO and other data users to be sure
the data used are cited appropriately so that readers of this draft do
not make inferences that are incorrect. The BLS and the GAO staff are
working to address this problem in the draft report.
Finally, BLS requests that the GAO continue to contact the BLS through
its GAO liaison or the point-of-contact designated at the Entrance
Conference. By doing so, confusion regarding the verification of data
requests or validation of data provided may be minimized.
The BLS looks forward to continuing its work with the GAO regarding
this report. Should you require further assistance, please contact the
GAO liaison, Lisa Nolte, at (202) 691-5104.
Sincerely,
Signed by:
KATRINA W. REUT:
Associate Commissioner for Compensation and Working Conditions:
[End of section]
Appendix VIII: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Revae E. Moran, (202) 512-3863:
Monika R. Gomez, (202) 512-9062:
Staff Acknowledgments:
David G. Ehrlich and Friendly M. Vang-Johnson made significant
contributions to this report throughout the review. In addition, Luann
M. Moy helped develop our data collection instrument and our overall
design and methodology; Margaret L. Armen and Richard P. Burkard
provided legal support; Avrum I. Ashery, Jennifer R. Popovic, and Melba
Edwards designed our graphics; Paula J. Bonin, Mark F. Ramage, Douglas
M. Sloane, and Beverly A. Ross provided technical assistance; and
Corinna A. Nicolaou assisted in report and message development.
FOOTNOTES
[1] This estimate has a 95 percent confidence interval from 470,783 to
584,003. All demographic estimates for the meat and poultry industry in
this report are based on the March 2004 or the March 1995 Current
Population Survey (CPS) and refers to workers in the animal
slaughtering and processing industry. Unless otherwise noted, CPS
percentage estimates have 95 percent confidence intervals of plus or
minus 8 percentage points of the estimate, and all other estimates have
confidence intervals of within plus or minus 14 percent of the estimate
itself. See appendix I for more information.
[2] We focused on the three-digit Standard Industrial Classification
code 201--the meat products industry. When we refer to the "meat and
poultry industry," we are referring to companies in the meat products
industry, code 201. When we refer to the meatpacking industry, we are
referring to companies in the four-digit code 2011; when we refer to
the sausages and other prepared meat products industry, we are
referring to companies in code 2013; and when we refer to the poultry
slaughtering and processing industry, we are referring to companies in
code 2015.
[3] Our survey sample was designed so that we would be able to draw
inferences from the study population. However, because we received an
overall response rate to our survey of only 23 percent, we cannot
generalize the responses we received to the entire population of meat
and poultry producers. See appendix I for more detailed information on
the survey.
[4] USDA's primary responsibility in meat and poultry plants is to
administer a comprehensive system of inspection laws designed to ensure
that meat and poultry products moving in interstate and foreign
commerce for use as human food are safe, wholesome, and accurately
labeled.
[5] Consolidation in U.S. Meatpacking, by James M. MacDonald, Michael
E. Ollinger, Kenneth E. Nelson, and Charles R. Handy. Food and Rural
Economics Division, Economic Research Service, U.S. Department of
Agriculture. Agricultural Economic Report No. 785, Washington, D.C.:
February 2000.
[6] Under the terms of the act, states may assume responsibility for
occupational safety and health enforcement through the mechanism of an
OSHA-approved state plan. Twenty-one "state-plan states" operate such
programs with responsibility for most private sector OSHA enforcement
in their states. State plans operate under authority of state law,
adopt and enforce their own standards (which must be "at least as
effective" as federal OSHA's), and set their own goals and priorities
for enforcement and compliance assistance.
[7] The SST program also focuses on industries outside of
manufacturing, with lost workday case rates above a certain level (5.0
or greater for its 2004 SST program), as reported by BLS. The
nonmanufacturing industries included in the survey for OSHA's 2004 SST
program were within the major industry categories of Agriculture,
Transportation, Wholesale and Retail Trade, and Health Services.
[8] Worksites in the construction industry are not selected for
inspection under OSHA's SST program. However, through its other
inspection initiatives, 22,724 of OSHA's 39,720 total inspections were
of construction worksites in 2003.
[9] All manufacturing industries are considered as having high injury
and illness rates.
[10] OSHA sends primary and secondary lists to its area offices in
federal OSHA states. These offices are expected to visit all worksites
identified on the primary list and inspect worksites on the secondary
list as resources allow. OSHA sends information on additional worksites
in state-plan states to the appropriate state agencies, which are
expected to have an effective high hazard inspection targeting system.
All but 4 of the 21 state-plan states participate in the data gathering
program that would make establishment-level SST-type data available to
them for efforts such as targeting and program evaluation.
[11] Musculoskeletal disorders include conditions such as tendonitis,
carpal tunnel syndrome, and lower back injuries. Symptoms of these
disorders can include swelling in the joints, limited range of motion,
numbness or tingling sensations, and loss of strength. Events or
exposures that can lead to the injury or illness are bodily reaction/
bending, climbing, crawling, reaching, twisting, overexertion, and
repetition.
[12] 29 U.S.C. § 654(a)(1). This clause is used to cite serious hazards
where no specific OSHA standard exists to address the hazard, as is the
case with ergonomic stressors. According to OSHA, when it uses this
clause to cite an employer, the agency must demonstrate that (1) the
employer failed to keep the workplace free of a hazard to which
employees were exposed, (2) the hazard was causing or likely to cause
death or serious physical harm, (3) the hazard was recognized, and (4)
a feasible means of abatement for the hazard exists.
[13] The On-Site Consultation Program defines a small business as one
with fewer than 250 workers at the workplace where the consultation is
conducted and no more than 500 workers companywide.
[14] While OSHA had partnership agreements prior to 1998, the Strategic
Partnership Program was not formalized until that year.
[15] The 95 percent confidence interval for this median age is from 35
to 39 years old.
[16] All percentage estimates describing the workforce in this section
are CPS estimates, and have a 95 percent confidence interval of within
plus or minus 8 percentage points of the estimate itself.
[17] The percentage estimates for this industry and U.S. manufacturing
are 96 and 95 percent, respectively. These percentages are not
significantly different at the 95 percent confidence level.
[18] In addition, about 2 percent were Asian or other Pacific Islander
and 3 percent were American Indian or Alaska native. The CPS is a joint
product of the U.S. Census Bureau and BLS.
[19] Production and sanitation workers make up about 304,000 of the
527,000 total workers in the meat and poultry industries. The remaining
workers in the industry work in administrative, managerial,
engineering, health care, and transportation-related positions.
[20] GAO, Community Development: Changes in Nebraska's and Iowa's
Counties with Large Meatpacking Plant Workforces, GAO/RCED-98-62,
(Washington, D.C.: Feb. 27, 1998).
[21] The turnover rate is typically calculated by dividing the total
number of employees who left the plant during the most recent year by
the total number of employees.
[22] Cumulative trauma can be caused by forceful exertions, repetitive
finger or wrist motions, tool vibrations, awkward wrist positions, or
specific repeated motions, and it can be exacerbated by extreme cold or
humidity.
[23] Safety and Health Guide for the Meatpacking Industry, U.S.
Department of Labor, Occupational Safety and Health Administration,
1988, OSHA 3108.
[24] Injury and illness rates for 2002 are not comparable with 2001 and
previous years' rates because of changes to OSHA's record-keeping
requirements and changes in the way that OSHA requires companies to
categorize injuries and illnesses. These changes took effect January 1,
2002.
[25] All estimates of injury incidence rates in this report are based
on BLS data and have 95 percent confidence intervals of within plus or
minus 14 percent of the estimated incidence rate. Confidence intervals
for most estimates in this report are narrower (more precise) than
this. However, rather than report confidence intervals for every
incidence rate estimate in this report, a broad conservative confidence
interval is used to cover all BLS incidence rate estimates. Additional
information about these estimates is contained in appendix I.
[26] In 2003, 18 additional deaths were reported as sustained by meat
and poultry workers. BLS and other federal statistical agencies are now
required to use new industry and occupational classifications designed
to reflect the most recent industries and occupations in the economy.
Therefore, the 2003 data are not comparable with prior years' fatality
data and are reported separately because, in some instances, the
occupational definitions in the new classification system are different
from those used previously.
[27] OSHA's region 7 covers Iowa, Kansas, Missouri, and Nebraska.
[28] Underreporting of Occupational Injuries and Its Impact on Workers'
Safety, (Parts 1, 2, & 3) Hearings Before a Subcommittee of the
Committee on Government Operations, House of Representatives, 100th
Congress, Washington, D.C., March 19, 1987; May 6, 1987; and September
21, 1987.
[29] E.S. Pollack and D.F. Keimig, eds., Counting Injuries and
Illnesses in the Workplace: Proposals for a Better System, Washington,
National Research Council, National Academy Press, 1987. Beginning in
1992, survey information on nonfatal incidents involving days away from
work was expanded to profile (1) the occupation and other demographics
(e.g., age and gender) of workers sustaining such injuries and
illnesses, (2) the nature of these disabling conditions and how they
occurred, and (3) the resulting time away from work.
[30] Hugh Conway and Jens Svenson, Occupational Injury and Illness
Rates, 1992-96: Why They Fell, Monthly Labor Review, BLS, November
1998.
[31] During inspections, OSHA compliance officers ask plant officials
if they utilize incentive programs to reward their employees. An OSHA
compliance officer we spoke to told us that as part of her education
and outreach during an inspection, she suggests alternative ways of
rewarding employees that could minimize underreporting but still reward
safe and healthy work environments, such as providing rewards for
consistently wearing personal protective equipment or using safe work
practices.
[32] A medical safety management program is one that addresses plant
safety and security, emergency management, fire prevention, and the
proper training of employees on the handling and safeguarding of
hazardous materials and medical equipment. It also includes guidelines
for creating and using an incident reporting system, as well as the
steps necessary to educate employees on issues like infection control,
personal protective equipment, ergonomics, and workplace violence.
[33] Agricultural Economic Report No. 785, Washington, D.C., February
2000.
[34] Memorandum from Nebraska's Lieutenant Governor Dave Maurstad to
Nebraska's Governor Mike Johanns entitled, "Review of Working
Conditions in Nebraska Meatpacking Plants," January 24, 2000.
[35] An additional 189 inspections were made by state occupational
safety and health agencies in state-plan states. In state-plan states,
program safety and health standards, and the enforcement of such
standards, must be at least as effective as federal OSHA programs. See
29 U.S.C. § 667(c)(2).
[36] In 2003, OSHA implemented local emphasis programs in meatpacking
and three other industries: hospitals, warehousing, and automotive
parts manufacturing.
[37] The American Meat Institute represents the interests of packers
and processors of beef, pork, lamb, veal, and turkey products and their
suppliers throughout North America. Together, its members produce 95
percent of the beef, pork, lamb, and veal products and 70 percent of
the turkey products in the United States. Headquartered in Washington,
D.C., the institute provides legislative, regulatory, public relations,
technical, scientific, and educational services to the industry.
[38] Through its Web site, OSHA offers eTools on several subjects that
provide stand-alone, interactive, training tools on occupational safety
and health topics.
[39] Some of these standards include process safety management of
highly hazardous chemicals, general requirements for all machines, and
guarding of portable power tools.
[40] Review of U.S. Department of Agriculture's Food Safety and
Inspection Service Workplace Safety Regulations, Hearing Before the
Subcommittee on Department Operations, Research, and Foreign
Agriculture of the Committee on Agriculture, House of Representatives,
102nd Congress, Washington, D.C., November 12, 1991.
[41] USDA trains its employees on safety and health issues that affect
them personally.
[42] The number of visits is actually higher because some worksites
have received multiple visits or an employer can make one request that
requires services at several worksites.
[43] GAO, Workplace Safety and Health: OSHA Can Strengthen Enforcement
through Improved Program Management, GAO-03-45, (Washington, D.C.:
Nov. 22, 2002).
[44] Injuries and illnesses sustained by cleaning and sanitation
workers who are not employees of the plant are recorded in the general
industry category of "Services," which includes maids, janitors, and
other workers employed in cleaning services. Because this industry is
not considered high hazard, OSHA does not collect data from worksites
in the industry to use in selecting worksite for inspection.
[45] These injuries included fractures, severe chemical exposure, fatal
falls, incidents of crushed or severed limbs or heads, and injuries
necessitating amputation.
[46] See appendix II for more information on our interviews with the
contract cleaning and sanitation companies.
[47] OSHA uses BLS's aggregate industry data to determine which
industries are high-hazard. The worksites OSHA selects report a days
away from work, restricted, or transferred rate between 0.0 and 4.0 and
a days away from work injury and illness rate between 0.0 and 2.0, and
are selected from industries that have a days away from work,
restricted, or transferred rate of 8.0 or greater or a days away from
work injury and illness rate of 4.0 or greater. OSHA began this effort
to inspect 200 low-rate reporting worksites from high-rate industries
in 2002.
[48] The major difference between the records audits conducted as part
of this program and records reviews performed during other inspections
is the attainment of a medical access order by the OSHA compliance
officer prior to the audit. A medical access order allows OSHA to
obtain documents such as, medical records, state workers' compensation
forms, insurer's accident reports, company safety incident reports, and
first aid logs.
[49] Evaluation of OSHA's Impact on Workplace Injuries and Illnesses in
Manufacturing Using Establishment-Specific Targeting of Interventions,
Prepared for OSHA by ERG, Lexington, Mass.: July 23, 2004.
[50] GAO, Workplace Safety and Health: OSHA's Voluntary Compliance
Strategies Show Promising Results, but Should Be Fully Evaluated before
They Are Expanded, GAO-04-378, (Washington, D.C.: Mar. 19, 2004).
[51] All the rates of occupational injury and illness in this report
are based on BLS data. BLS calculates a relative standard error for
each estimate it tabulates, and the 95 percent confidence intervals for
the detailed rates cited in this report are all within plus or minus
14 percent of the estimated rates. Rather than report confidence
intervals for every incidence rate estimate in this report, a broad
conservative confidence interval is used to cover all BLS incidence
rate estimates. For this particular estimate, the confidence interval
is plus or minus 2.5 percent of the estimated tendonitis incidence rate
estimate used in this report.
[52] Because OSHA does not require employers to record race data on its
case reporting form, BLS cannot require employers to report it as part
of the detailed data it collects for these serious cases. Instead it is
a voluntary item and BLS does not receive the race data for roughly one
in four of the injured or ill workers.
[53] See GAO-03-45.
[54] Evaluation of OSHA's Impact on Workplace Injuries and Illnesses in
Manufacturing Using Establishment-Specific Targeting of Interventions,
Prepared for OSHA by ERG, Lexington, Mass.: July 23, 2004.
[55] We did not evaluate documentation related to the development of
the models presented, so we did not determine whether the work was done
correctly. As described, however, we believe that OSHA's approach was
reasonable and in line with current methodological approaches.
[56] OSHA used complex data cleaning and matching algorithms to prepare
and combine information within its establishment-specific injury and
illness database and between it and other databases. The establishment-
specific injury and illness database, in particular, presented many
challenges since it is derived from annual surveys of business
establishments. For instance, some of the surveys received were
rejected from the analysis because of missing information, some were
duplicate entries, and about half were rejected because they could not
be matched to an establishment in the prior year. OSHA used similar
matching procedures to combine the injury and illness data with the
intervention records housed within OSHA's inspections database. We
believe that OSHA's description of analysis difficulties with
enterprise-level data is fair and, as described, OSHA's efforts to work
through such difficulties seemed thorough. The analysis file OSHA
constructed, though, most likely contains some unknown measure of
mismatch.
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