NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH

 (NIOSH) RECOMMENDATIONS TO THE U.S. DEPARTMENT OF

LABOR FOR CHANGES TO HAZARDOUS ORDERS

May 3, 2002

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

Public Health Service

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health
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Table of Contents

Commonly Used Acronyms and Abbreviations ......................................... v

Data Sources, Coding Systems, and Outcome Measures Used Throughout Report ............. vii

EXECUTIVE SUMMARY ...................................................... xi

I. INTRODUCTION ............................................................ 1

II. YOUTH EMPLOYMENT, INJURIES, AND ILLNESSES ............................ 3

Employment ............................................................. 3

Unique Characteristics of Youth Workers ....................................... 6

Nonfatal Occupational Injuries and Illnesses ..................................... 6

Fatal Injuries ........................................................... 10

III. DEVELOPMENT OF RECOMMENDATIONS .................................. 15

Context for Recommendations .............................................. 15

Hazardous Orders Recommendations ......................................... 16

Recommendations for Apprentice/Student Learner Exemptions ...................... 18

IV. RECOMMENDATIONS PERTAINING TO CURRENT HAZARDOUS ORDERS ....... 21

Non-Agricultural Occupations .............................................. 21

HO 1: Manufacturing or Storage Occupations Involving Explosives ............. 21

HO 2: Motor Vehicle Occupations ..................................... 22

HO 3: Coal Mine Occupations ........................................ 26

HO 4: Logging and Sawmilling Occupations .............................. 27

HO 5: Power-Driven Woodworking Machine Operations .................... 31

HO 6: Occupations Involving Exposure to Radioactive Substances and to Ionizing

Radiation .................................................. 34

HO 7: Power-Driven Hoisting Apparatus Operations ....................... 35

HO 8: Power-Driven Metal Forming, Punching, and Shearing Machine

Operations ................................................. 39

HO 9: Occupations in Connection with Mining, Other Than Coal .............. 40

HO 10: Occupations in the Operation of Power-Driven Meat-Processing

Machines and Occupations Involving Slaughtering, Meat-Packing or

Processing, or Rendering ...................................... 41

HO 11: Power-Driven Bakery Machine Occupations ....................... 48

HO 12: Power-Driven Paper-Products Machine Occupations ................. 50

HO 13: Occupations Involved in the Manufacture of Brick, Tile, and Kindred

Products .................................................. 54

HO 14: Occupations in the Operation of Power-Driven Circular Saws, Band

Saws, and Guillotine Shears .................................... 56

HO 15: Occupations Involved in Wrecking, Demolition, and Shipbreaking

Operations ................................................. 58
ii

HO 16: Occupations in Roofing Operations .............................. 60

HO 17: Occupations in Excavation Operations ............................ 63

Agricultural Occupations .................................................. 67

HO 1: Operating a Tractor Over 20 PTO Horsepower or Connecting or

Disconnecting an Implement or Any of Its Parts To or from Such a

Tractor. ................................................... 67

HO 2: Operating or assisting to operate (including starting, stopping, adjusting,

feeding or any other activity involving physical contact associated with

the operation) any of the following machines: ........................ 72

Corn picker, cotton picker, grain combine, hay mower, forage harvester,

hay baler, potato digger, or mobile pea viner;

Feed grinder, crop dryer, forage blower, auger conveyor, or the unloading

mechanism of a nongravity-type self-unloading wagon or trailer,

or

Power post-hole digger, power post driver, or nonwalking-type rotary

tiller.

HO 3: Operating or assisting to operate (including starting, stopping, adjusting,

feeding, or any other activity involving physical contact associated with

the operation) any of the following machines: ........................ 72

Trencher or earthmoving equipment;

Fork lift;

Potato combine;

Power-driven circular, band, or chain saw

HO 4: Working on a Farm in a Yard, Pen, or Stall Occupied By a:

(i) Bull, boar, or stud horse maintained for breeding purposes; or

(ii) Sow with suckling pigs, or cow with newborn calf (with umbilical

cord present). .............................................. 76

HO 5: Felling, Bucking, Skidding, Loading or Unloading Timber with Butt

Diameter of More than 6 Inches. ................................ 77

HO 6: Working from a Ladder or Scaffold (Painting, Repairing, or Building

Structures, Pruning Trees, Picking Fruit, etc.) at a Height of Over 20 Feet.

......................................................... 79

HO 7: Driving a Bus, Truck, or Automobile When Transporting Passengers, or

Riding on a Tractor as a Passenger or Helper. ....................... 81

HO 8: Working Inside: .............................................. 86

A fruit, forage, or grain storage designed to retain an oxygen deficient or

toxic atmosphere

An upright silo within 2 weeks after silage has been added or when a top

unloading device is in operating position

A manure pit

A horizontal silo while operating a tractor for packing purposes

HO 9: Handling or Applying (including Cleaning or Decontaminating Equipment,

Disposal or Return of Empty Containers, or Serving as a Flagman for

Aircraft Applying) Agricultural Chemicals Classified Under the Federal

Insecticide, Fungicide, and Rodenticide Act (as Amended by Federal
iii

Environmental Pesticide Control Act of 1972, 7 U.S.C. 136 et seq.) as

Toxicity Category I, Identified by the Word “Danger” and/or “Poison”

with Skull and Crossbones; or Toxicity Category II, Identified by the

Word “Warning” on the Label .................................. 90

HO 10: Handling or Using a Blasting Agent, Including but Not Limited to,

Dynamite, Black Powder, Sensitized Ammonium Nitrate, Blasting Caps,

and Primer Cord ............................................ 96

HO 11: Transporting, Transferring, or Applying Anhydrous Ammonia ........... 97

V. RECOMMENDATIONS FOR NEW HAZARDOUS ORDERS ....................... 99

Commercial Fishing Occupations ............................................ 99

Construction Occupations ................................................ 101

Work in Refuse Occupations .............................................. 106

Water Transportation Industries ............................................ 108

Work in Scrap and Waste Materials Industry .................................. 110

Farm Product Raw Materials Wholesale Trade Industry .......................... 112

Railroad Industry ....................................................... 113

Work at Heights ........................................................ 114

Tractors .............................................................. 119

Heavy Machinery ....................................................... 122

Welding .............................................................. 124

Confined Spaces ....................................................... 127

Work Involving Powered Conveyors ........................................ 130

Pesticide Handling ...................................................... 132

Exposure to Lead ....................................................... 133

Exposure to Silica ...................................................... 135

Work Requiring the Use of Respiratory Protection .............................. 137

VI. AREAS REQUIRING FURTHER RESEARCH .................................. 139

VII. BARRIERS TO PREVENTING YOUTH DEATHS, SERIOUS INJURIES AND

ILLNESSES THROUGH REGULATION ................................... 143

VIII. APPENDIX. Listing of all SIC industry groups with fatality rates (for all workers) higher

than 10 per 100,000 workers (twice the average rate for all workers) by descending rate

and description of HO coverage. ........................................... 145

IX. REFERENCES ............................................................ 149
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Commonly Used Acronyms and Abbreviations

ANSI American National Standards Institute

ARDS Adult Respiratory Distress Syndrome

ATF Bureau of Alcohol, Tobacco, and Firearms

ATV All Terrain Vehicle

BLS Bureau of Labor Statistics

BOC Bureau of Census

CAIS Childhood Agricultural Injury Survey

CDC Centers for Disease Control and Prevention

CFOI Census of Fatal Occupational Injuries

CFR Code of Federal Regulations

COPD Chronic Obstructive Pulmonary Disease

CPS Current Population Survey

CWP Coal Workers’ Pneumoconiosis

DHHS Department of Health and Human Services

DOL Department of Labor

EPA Environmental Protection Agency

ESA Employment Standards Administration (Department of Labor)

FACE Fatality Assessment and Control Evaluation

FLSA Fair Labor Standards Act of 1938

FTE Full-time Equivalent Employees

GAO General Accounting Office

GDL Graduated Driving Licensure

HO Hazardous Order

IARC International Agency for Research on Cancer

MMWR Morbidity and Mortality Weekly Report

NEISS National Electronic Injury Surveillance System 
Abbreviations and Acronyms

vi

NHANES National Health and Nutrition Examination Survey

NIOSH National Institute for Occupational Safety and Health

NPRM Notice of Proposed Rule-Making

NRC National Research Council

NRC/IOM National Research Council/Institute of Medicine

NTOF National Traumatic Occupational Fatality Surveillance System

OIICS Occupational Injury and Illness Classification Structures

OLPPP Occupational Lead Poisoning Prevention Program (California)

OMB Office of Management and Budget

OSHA Occupational Safety and Health Administration

PL Public Law

PMR Proportionate Mortality Ratio

PTO Power Take-off

ROPS Roll-over Protective Structure

SIC Standard Industrial Classification

SOII Annual Survey of Occupational Injuries and Illnesses

TISF Traumatic Injury Surveillance of Farmers

U.S.C. U.S. Code

WHD Wage and Hour Division (Department of Labor)
vii

Data Sources, Coding Systems, and Outcome Measures Used Throughout Report

Data Sources

Current Population Survey (CPS): Data on employment and unemployment are collected

monthly through a survey of about 50,000 households, scientifically selected to be representative

of the civilian, noninstitutionalized population of the United States. Employment data are

collected for all household members aged 15 or older. The data are collected by the Bureau of

the Census for the Bureau of Labor Statistics (BLS). For this report NIOSH analyzed data files

purchased from BLS.

National Traumatic Occupational Fatalities (NTOF) Surveillance System: Data on

occupational injury deaths throughout the United States based on death certificates collected

from all 50 states and the District of Columbia. Death certificates are included in the system if

the decedent was at least 16 years of age, death was caused by an injury, and the death certificate

noted that the injury occurred at work. Death certificates alone are estimated to identify

approximately 80% of all work-related injury deaths. The NTOF system contains information

on deaths dating back to 1980, and is the most comprehensive and accurate data system for

work-related injury deaths prior to 1992. The NTOF system was developed and is maintained by

NIOSH.

Census of Fatal Occupational Injuries (CFOI): Data on occupational injury deaths throughout

the United States based on multiple sources of information, including death certificates, medical

examiner reports, workers’ compensation claims, and newspaper reports. Worker deaths are

verified by at least two sources. The CFOI system contains information on deaths dating back to

1992. Data are collected by the states, New York City and the District of Columbia, and

provided to BLS in a cooperative federal/state program. The CFOI system was developed and

is maintained by BLS. Through Letters of Agreement, BLS has provided NIOSH with CFOI

research files. For the years 1992 through 1997, NIOSH received two different types of files. 

The first was a standard research file provided to researchers who agree to comply with BLS

confidentiality requirements and reporting procedures. This standard research file helps ensure

the confidentiality of CFOI data by grouping certain variables, such as age and state. To better

meet the analytic needs of NIOSH, BLS provided NIOSH with a more detailed research file that

included data by individual year of age. Data from New York City are not included in this more

detailed research file because the New York City Department of Health did not agree to NIOSH

having New York City data in this more detailed format. Analyses of both research files are

included in this report. The standard research file was used for analyses of workers of all ages,

and the more detailed file (minus data from New York City) was to used to identify and describe

young worker injury deaths.

Survey of Occupational Injuries and Illnesses (SOII): Data on occupational injuries based on

an annual survey of a stratified random sample of employers in private industry. Excluded from

the sample are self-employed individuals, farms with fewer than 11 employees, private

household employees, and government workers. Information is collected on all injuries and

illnesses that meet OSHA reporting requirements. Rates of injury are calculated based on hours

of work. More information, including demographic information on the victim and nature of the
Data Sources, Coding Systems, and Outcome Measures

viii

injury, is collected for those injuries serious enough to require time away from work. The SOII

was developed and is maintained by BLS. Current survey methods have been employed since

1992. Estimates in this report are derived from BLS publications. 

National Electronic Injury Surveillance System (NEISS): Data on occupational injuries and

illnesses collected from a nationally representative sample of 67 hospital emergency

departments. The NEISS was developed and maintained by the Consumer Product Safety

Commission (CPSC) to identify consumer product-related injuries. Through an interagency

agreement between NIOSH and CPSC, the NEISS system was expanded to capture data on

work-related injuries and illnesses regardless of product involvement. NEISS data on workrelated injuries were collected from 1982 to 1986, then for different age groups beginning in

1992. In 1995, collection of work-related injuries and illnesses was expanded to all ages of

workers in a sample of NEISS hospitals. It is estimated that about one-third of occupational

injuries and illnesses are treated in hospital emergency departments. NIOSH maintains workrelated data collected through the NEISS system.

Traumatic Injury Surveillance of Farmers (TISF): Data on occupational injuries to farmers

and farm workers collected from a nationally representative sample of 50,000 farm operators in

each of three years: 1993, 1994, and 1995. Information was collected through a mail survey. 

The sample was drawn from a list of farm operators maintained by the National Agricultural

Statistics Service (NASS), U.S. Department of Agriculture. The survey was conducted by

NASS for NIOSH through an interagency agreement. 

Childhood Agricultural Injury Survey (CAIS): Data on childhood injuries on farms collected

from a nationally representative sample of 50,000 farm operators in 1998. Information was

collected through a telephone survey. Information was collected to differentiate work-related

injuries from non-work injuries, and to differentiate between youth who lived on the farm,

worked on the farm, and visited the farm. The survey was conducted by NASS for NIOSH

through an interagency agreement. 

Fatality Assessment and Control Evaluation (FACE): FACE is a NIOSH research program

focused on field evaluations of worker fatalities, including those of youth under 18 years of age. 

Through assessment of the incident site, employer and witness interviews, and administrative

records, NIOSH investigators develop case reports that provide detailed incident descriptions

and recommendations to employers and others for prevention of similar incidents. In this report,

FACE cases are used to illustrate the circumstances and risk factors associated with young

worker fatalities.

Coding Systems

Occupational Injury and Illness Coding Structures (OIICS): BLS data systems that collect

data on fatal and nonfatal injuries characterize incidents by primary and secondary source of

injury, event, nature of injury, and body part using the Occupational Injury and Illness Coding

Structures (OIICS) [National Safety Council 1995]. The source of injury is the object,

substance, element, or bodily motion that directly produced or inflicted the injury. The
Data Sources, Coding Systems, and Outcome Measures

1Office of Management and Budget. See OMB in references.

ix

secondary source is the object, substance, or person that generated the source, or that contributed

to the event. For example, in an incident in which a worker was struck by a crate that fell from a

forklift, the primary source of injury is the crate and the secondary source is the forklift. For

transportation-related events, the primary source is the vehicle occupied by the injured worker,

and the secondary source is the vehicle that collided with the worker’s vehicle. In the case of a

pedestrian injury or fatality, the primary source is the vehicle that struck the pedestrian.

Standard Industrial Classification (SIC): Occupational injury and fatality data systems such

as the CFOI and SOII categorize the industry in which a worker is employed using the 1987

Standard Industrial Classification (SIC) [OMB1 1987]. 

Bureau of the Census (BOC) Occupation and Industry Coding Systems: All sources of

injury and fatality data cited in this report classify occupation using BOC occupation codes used

for the 1990 census [Bureau of the Census 1992]. The CPS employment data used in calculation

of fatality rates also code occupation using the BOC system. However, CPS uses BOC industry

codes, while most sources of occupational injury and fatality data code industry using the SIC. 

In most cases, the SIC is more detailed. Generally, SIC codes can be collapsed to the less

specific BOC industry codes found in the CPS for calculation of rates. 

Outcome Measures

Injuries per 100 fulltime equivalents: Standard measure for reporting rates of nonfatal

occupational injuries. Calculated based on hours of work, assuming 2000 hours per fulltime

worker per year.

Median days away from work: A measure that provides an assessment of typical injury

severity. Fifty percent of injuries require less days away from work than the median, and 50%

require more days away from work than the median. 

Deaths per 100,000 workers: Standard measure for reporting rates of fatal occupational

injuries. Calculated based on average number of workers in a year.

Deaths per 100,000 fulltime equivalents (FTE): A measure for reporting rates of fatal

occupational injuries that accounts for hours of work. Assumes 2,000 hours per fulltime worker

per year. For most workers and occupations, rates per 100,000 workers are comparable to rates

per 100,000 fulltime equivalents. There are differences between these two measures, however,

for workers who do not work a standard 40-hour work week, such as youth workers. Accounting

for hours of work provides a more accurate assessment of risk for groups that tend to work parttime, and is important when comparing groups that on average work different numbers of hours

for the same period of time [Ruser 1998]. 

Deaths per 1,000 fulltime workers per 45-year work lifetime: A measure for reporting rates

of fatal occupational injury that averages fatality risk over a 45-year working life. This measure
Data Sources, Coding Systems, and Outcome Measures

x

is labeled “lifetime risk” and facilitates comparisons with standard measures of occupational

illness deaths. OSHA considers a lifetime risk of 1 death in 1,000 workers per 45-year work

lifetime to be high enough to justify standard development. 
xi

EXECUTIVE SUMMARY

An average of 67 workers under 18 years of age die annually from occupational injuries, and an

estimated 77,000 are treated in hospital emergency departments for nonfatal injuries. The Fair

Labor Standards Act (FLSA), largely unchanged in decades, defines work activities prohibited

for young workers through 28 Hazardous Orders (HOs) for nonagricultural and agricultural

occupations. The U.S. Department of Labor, NIOSH and others have identified the need to

assess the adequacy of existing HOs to protect working youth. Most recently, the following

recommendation was made in the National Research Council/Institute of Medicine Report

Protecting Youth at Work: 

“The U.S. Department of Labor should undertake periodic reviews of its hazardous

orders in order to eliminate outdated orders, strengthen inadequate orders, and develop

additional orders to address new and emerging technologies and working conditions. 

Changes to the hazardous orders should be based on periodic reviews by the National

Institute for Occupational Safety and Health of current workplace hazards and the

adequacy of existing hazardous orders to address them.” [NRC/IOM 1998]

The U.S. Department of Labor (DOL) provided funds for NIOSH to develop such a report based

on a review of data and the scientific literature. Primary data sources used by NIOSH were the

Census of Fatal Occupational Injuries, the Survey of Occupational Injuries and Illnesses, the

National Electronic Injury Surveillance System, and the Current Population Survey. Hundreds

of scientific articles and reports were reviewed. The report makes recommendations specific to

HOs that define prohibited occupations. The report does not address Child Labor Regulation No.

3 which sets hours restrictions and defines permissible work activities for 14- and 15-year-olds,

nor statutory issues such as the minimum age for work in HOs and exemptions from the FLSA. 

Recommendations in this report are consistent with the DOL commitment to facilitate

meaningful employment and training opportunities while protecting youth from the most

hazardous work activities. Recommendations are driven by information on high-risk activities

for all workers, not just patterns of fatalities and serious injuries among young workers. The

general rationale for recommending an HO is that the associated fatality rate be at least 10 per

100,000 workers, or twice the fatality rate for all U.S. workers. The number and severity of

nonfatal injuries are also considered, as well as research on health effects of workplace

exposures. In addition to making recommendations for revisions and additions to HOs, NIOSH

makes recommendations regarding apprentice/student learner exemptions in nonagricultural

occupations. Exemptions are recommended in those cases where supervision and training could

reasonably be expected to protect young workers from hazards on the job. 

NIOSH found justification for all of the existing HOs. Review of available data and scientific

evidence found that work currently prohibited by HOs continues to pose risks for death, serious

injury and disabling health conditions. NIOSH proposes several types of revisions to HOs:

better definition of prohibited activities, incorporation of associated legislative provisions, and in

some cases, removal of current exemptions. Additionally, NIOSH makes recommendations to

expand several HOs to include similar work with comparable or greater risk. In a couple of

cases, NIOSH concluded that revisions of existing HOs may be warranted, to allow use of
Executive Summary

xii

currently prohibited equipment which appears to be associated with relatively minor injuries. 

Tables 1 and 2 summarize recommendations for existing HOs in nonagricultural and agricultural

occupations, respectively. 
Executive Summary

xiii

Table 1. Summary of NIOSH Recommendations Pertaining to Existing Nonagricultural Occupation HOs

Existing Nonagricultural HO Retain Revise Training

exemption Specific recommendations

HO 1: Manufacturing or Storage Occupations Involving

Explosives X n/a Revise the definition to include the current ATF list of explosive materials.

HO 2: Motor Vehicle Occupations X n/a

1) Incorporate provisions of the Drive for Teen Employment Act; 2) Provide

guidance on “urgent, time-sensitive deliveries” and “incidental and occasional

driving”; 3) Delete exemption for school bus driving.

HO 3: Coal Mine Occupations X n/a

HO 4: Logging and Sawmilling Occupations X n/a

1) Expand to cover similar work in operation of timber tracts, tree farms and

forestry services; 2) Remove the current exemptions for construction work for

living or administrative quarters.

HO 5: Power-Driven Woodworking Machines X Retain Expand to include similar power-driven machines used to operate on materials

other than wood.

HO 6: Occupations Involving Exposure to Radioactive

Substances and to Ionizing Radiation X n/a Revise to reflect current risks to youth for occupational radiation exposures.

HO 7: Power-driven Hoisting Apparatus Operations X n/a

1) Expand to cover repairing, servicing, disassembling and assisting in tasks being

performed by the machine; 2) Expand to prohibit youth from riding on any part of

a forklift as a passenger, and from working from forks, platforms, buckets, or

cages attached to a moving or stationary forklift; 3) Expand to prohibit work from

truck-mounted bucket or basket hoists, commonly termed “bucket trucks” or

“cherry pickers”; 4) Expand to include commonly used manlifts that do not meet

the current definition, specifically aerial platforms. 

HO 8: Power-driven Metal Forming, Punching, and

Shearing Machine Operations X Retain Expand to include several types of metalworking machinery currently excludedfrom this HO, including milling, turning, grinding, and boring machines.
Executive Summary

Existing Nonagricultural HO Retain Revise Training

exemption Specific recommendations

xiv

HO 9: Occupations in Connection with Mining, Other

than Coal X n/a

1) Expand to include all work performed in connection with petroleum and natural

gas extraction; 2) Remove exemptions permitting repair and maintenance of

roads, and work on track crews.

HO 10: Occupations in the Operation of Power-driven

Meat-Processing Machines and Occupations Involving

Slaughtering, Meat Packing or Processing, or Rendering

X

Add partial

exemption

1) Expand to prohibit work in all meats products manufacturing industries,

including poultry slaughtering and processing; 2) Consider a revision* to allow

use of meat and food slicers in retail, wholesale and service industries; 3) Allow

apprentice/student learner exemptions in retail, wholesale or service industries.

HO 11: Power-driven Bakery Machine Occupations X n/a Consider a revision to allow the use of “counter-top models” of power-driven

bakery machines.

HO 12: Power-driven Paper- Products Machine

Occupations X Retain

1) Incorporate provisions of the Compactor and Baler Act; 2) Expand to include

similar power-driven machines used to operate on materials other than paper

products.

HO 13: Occupations Involved in the Manufacture of

Brick, Tile, and Kindred Products X n/a

HO 14: Occupations in the Operation of Power-Driven

Circular Saws, Band Saws, and Guillotine Shears X

Retain

partial

exemption

Revise definition to include other machines, such as chainsaws, which perform

cutting and sawing functions through direct contact between the cutting surface

and the material (the current definition is based on the presence of a continuous

series of notches or jagged teeth). 

HO 15: Occupations Involved in Wrecking, Demolition,

and Shipbreaking Operations X n/a

HO 16: Occupations in Roofing Operations X Remove 1) Expand to include all work performed on roofs; 2) Remove the exemption for

apprentices/student learners.

HO 17: Occupations in Excavation Operations X Remove Remove the exemption for apprentices/student learners.

* Any revisions of HOs that would allow work that was previously prohibited should be accompanied by a mandatory reporting period in which all serious youth injuries and deaths

resulting from previously prohibited activities are promptly reported to the U.S. Department of Labor. This would allow an assessment as to whether the revision should be

rescinded or further refined to best protect working youth, while not unnecessarily limiting job opportunities.
Executive Summary

xv

Table 2. Summary of NIOSH Recommendations Pertaining to Existing Agricultural Occupation HOs

Existing Agricultural HO Retain Revise Specific Recommendations

HO 1: Operating a Tractor Over 20 PTO Horsepower or

Connecting or Disconnecting an Implement or Any of Its

Parts To or From Such a Tractor

X

1) Revise to remove the 20 PTO (power take-off) horsepower threshold; 2) Revise

exemption for 14- and 15-year olds with tractor certification to require tractors to be

equipped with a rollover protective structure (ROPS) and mandate the use of seatbelts.

HO 2: Operating or Assisting to Operate (including starting,

stopping, adjusting, feeding or any other activity involving

physical contact associated with the operation) any of the

following machines: corn picker, cotton picker, grain

combine, hay mower, forage harvester, hay baler, potato

digger, or mobile pea viner; feed grinder, crop dryer, forage

blower, auger conveyor, or the unloading mechanism of a

nongravity-type self-unloading wagon or trailer, or power

post-hole digger, power post driver, or nonwalking-type

rotary tiller

X

Combine HO 2 and HO 3, and expand prohibition from lists of specific machines to

machines that perform general functions (e.g. harvesting and threshing machinery; mowing

machinery; plowing, planting and fertilizing machinery; other agricultural and garden

machinery; excavating machinery; loaders; wood processing machinery, such as wood

chippers and debarkers; sawing machinery, including chain saws; powered conveyors; and,

mobile equipment, including forklifts).

HO 3: Operating or assisting to operate (including starting,

stopping, adjusting, feeding, or any other activity involving

physical contact associated with the operation) any of the

following machines: trencher or earthmoving equipment;

fork lift; potato combine; power-driven circular, band, or

chain saw

X

See comments above pertaining to agricultural HO 2.

HO 4: Working on a Farm in a Yard, Pen, or Stall Occupied

By a: (i) Bull, boar, or stud horse maintained for breeding

purposes; or (ii) Sow with suckling pigs, or cow with

newborn calf (with umbilical cord present)

X

HO 5: Felling, Bucking, Skidding, Loading or Unloading

Timber with Butt Diameter of More than 6 Inches. X

Remove 6 inch diameter threshold.
Executive Summary

Existing Agricultural HO Retain Revise Specific Recommendations

xvi

HO 6: Working from a Ladder or Scaffold (Painting,

Repairing, or Building Structures, Pruning Trees, Picking

Fruit, etc) at a Height of Over 20 Feet

X

1) Expand to include work on roofs, on farm structures including silos, grain bins,

windmills, and towers; and, on vehicles, machines, and implements; 2) Reduce the

maximum height at which youth may work in these settings from 20 feet to 6 feet.

HO 7: Driving a Bus, Truck, or Automobile When

Transporting Passengers, or Riding on a Tractor as a

Passenger or Helper X

1) Expand to prohibit driving of all motor vehicles and off-road vehicles (including allterrain vehicles), with or without passengers, on or off the highway; 2) Expand to prohibit

work as an outside helper on a motor vehicle; 3) Retain the provision prohibiting riding on a

tractor as a passenger or helper, but move it under Agricultural HO 1.

HO 8: Working Inside: A fruit, forage, or grain storage

designed to retain an oxygen deficient or toxic atmosphere;

an upright silo within 2 weeks after silage has been added or

when a top unloading device is in operating position; a

manure pit; a horizontal silo while operating a tractor for

packing purposes

X

Expand to prohibit all work inside (i) a fruit, forage, or grain storage, such as a silo or bin;

(ii) a manure pit.

HO 9: Handling or Applying (including cleaning or

decontaminating equipment, disposal or return of empty

containers, or serving as a flagman for aircraft applying)

Agricultural Chemicals Classified Under the Federal

Insecticide, Fungicide, and Rodenticide Act (as amended by

Federal Environmental Pesticide Control Act of 1972, 7

U.S.C. 136 et seq.) as Toxicity Category I, Identified by the

Word “Danger” and/or “Poison” with Skull and Crossbones;

or Toxicity Category II, Identified by the Word “Warning”

on the Label

X

Revise to be consistent with EPA Worker Protection Standard for pesticides, encompassing

prohibitions against pesticides with chronic health effects as well as pesticides with

recognized acute toxicity. 

HO10: Handling or Using a Blasting, Including but Not

Limited to Dynamite, Black Powder, 

Sensitized Ammonium Nitrate, Blasting Caps, and Primer

Cord

X
Executive Summary

Existing Agricultural HO Retain Revise Specific Recommendations

xvii

HO 11: Transporting, Transferring, or Applying Anhydrous

Ammonia X
Executive Summary

xviii

NIOSH recommends the development of several new HOs to protect youth from especially

hazardous work not adequately addressed in the existing regulations. The recommended HOs

encompass work associated with deaths and severe injuries of youth, work with especially high

fatality rates, and work associated with disabling health conditions. In several instances, NIOSH

recommends extending prohibitions now in place for agricultural occupations to similar tasks in

nonagricultural occupations, e.g. pesticide handling, work in confined spaces, and tractor

operation. New HOs are recommended for the following types of work: 

• Commercial Fishing Occupations

• Construction Occupations

• Work in Refuse Occupations

• Water Transportation Industries

• Work in Scrap and Waste Materials Industry

• Farm Product Raw Materials Wholesale Trade Industry

• Railroad Industry

• Work at Heights

• Tractors (in nonagricultural occupations)

• Heavy Machinery

• Welding

• Confined Spaces (in nonagricultural occupations)

• Work Involving Powered Conveyors (in manufacturing industries)

• Pesticide Handling (in nonagricultural occupations)

• Exposure to Lead

• Exposure to Silica

• Work Requiring the Use of Respiratory Protection

Recommendations in this report are limited to changes to HOs which fall within the regulatory

authority of DOL. It is expected that changes recommended in this report would help to reduce

the incidence of fatal and serious youth work-related injuries and illnesses each year. However,

it must be recognized that considerable numbers of youth work-related deaths and serious

injuries would not be impacted by these recommended changes. Many deaths and serious

injuries occur among youth not covered by the FLSA, or in situations that would be difficult to

regulate under the current framework of the FLSA. Additionally, revisions or additions of new

HOs alone will not save lives. Efforts are needed to raise awareness and compliance with HOs

to ensure youth are not inappropriately employed in recognized hazardous work settings.

In reviewing available data and scientific information, NIOSH identified several areas that merit

additional research prior to future rule-making. Research into risk factors for work-related

homicide– a leading cause of young worker injury death– is one such research area. Further

research is needed to characterize youth worker exposures to health hazards, such as chemical

substances, biologic agents, and repetitive motion, and to determine if such exposures result in

negative health outcomes in later years. Research is needed on the effectiveness of youth

training programs to help ensure exemptions for apprentice and student-learner programs are

effective in facilitating a safe training environment. Finally, research on employer best
Executive Summary

xix

practices, and knowledge and attitudes about HOs among employers, parents, youth, and other

stakeholders could be used to increase the effectiveness of outreach and educational campaigns.

NIOSH recognizes the need to better protect the health and safety of working youth, and

provides this report to assist DOL in aligning child labor regulations with current knowledge

about occupational safety and health. NIOSH offers its continued support to work closely with

DOL to ensure that child labor regulations provide adequate protections for working youth and 

to initiate research into those areas of risk where insufficient data currently exist to guide rulemaking. 
xx

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2United States Code.

3Federal Register. See Fed. Reg. in references.

1

I. INTRODUCTION

The Fair Labor Standards Act of 1938, as amended [29 USC2 201 et seq.] authorizes the U.S.

Department of Labor (DOL) to establish rules which prohibit “oppressive child labor” in

commerce. Regulations implementing the Act permit the Secretary of Labor to prohibit the

employment of youth in occupations declared “particularly hazardous for the employment of

children... or detrimental to their health or well-being” [29 USC 201 Sec. 3(l)]. These prohibited

activities are referred to as Hazardous Orders (HOs). The minimum age, by statute, for HOs in

nonagricultural occupations is 18; the minimum age in agricultural occupations is 16. 

The HOs in nonagricultural occupations were established between 1939 and 1963. The

agricultural HOs were established in 1970. There have been significant changes in the

workplace and advancement in knowledge about occupational safety and health hazards that are

not reflected in the existing HOs. The need to update the HOs has been recognized by the

Department of Labor [59 Fed. Reg.3 25164 (1994); 64 Fed. Reg. 67130 (1999)], NIOSH [NIOSH

1994a, 1997a], and numerous researchers and advocates. Most recently, the following

recommendation was made in the National Research Council/Institute of Medicine (NRC/IOM)

report Protecting Youth at Work:

“The U.S. Department of Labor should undertake periodic reviews of its hazardous

orders in order to eliminate outdated orders, strengthen inadequate orders, and develop

additional orders to address new and emerging technologies and working conditions. 

Changes to the hazardous orders should be based on periodic reviews by the National

Institute for Occupational Safety and Health of current workplace hazards and the

adequacy of existing hazardous orders to address them.” [NRC/IOM 1998]

The DOL responded to the above charge by requesting that NIOSH prepare this review and

provided funding in support of this effort. This report updates and expands upon previous

NIOSH comments provided to the Department of Labor in response to proposed rule-making

[NIOSH 1994a, 2000a]. The report makes recommendations specific to HOs that define

prohibited occupations for youth under age 18 in nonagricultural occupations and youth under 16

in agricultural occupations. The report does not address Child Labor Regulation No. 3 which

sets hour restrictions and defines permissible work activities for 14- and 15-year-olds. The report

also does not address statutory issues, such as minimum age for work in HOs and exemptions

from the FLSA. Because the report was written specifically for DOL, existing Hazardous Orders

are referenced, but not described in detail. 

In addition to making recommendations specific to HOs, NIOSH identifies areas requiring

further research to guide future DOL prevention efforts– regulatory and nonregulatory. Finally,

NIOSH notes issues beyond the scope of DOL regulatory authority that will impede progress on

reducing deaths, severe injuries and illnesses of young workers. 
Introduction

2

The following sections are included in the report:

• Youth Employment, Injuries and Illnesses - Summary of data on youth employment,

injuries and illnesses.

• Development of Recommendations - Precepts used by NIOSH in recommending

changes and additions to HOs, with discussion of limitations of available data.

• Recommendations Pertaining to Current Hazardous Orders - Includes a summary of

data and research findings used in recommending retention and/or suggested

amendments to HOs 

• Recommendations for New Hazardous Orders - Includes a summary of data and

research findings used in recommending each new HO

• Areas Requiring Further Research - Identifies research that should be undertaken to

guide future DOL prevention efforts– regulatory and nonregulatory.

• Barriers to Preventing Youth Deaths, Serious Injuries and Illnesses through

Regulation - A summary of issues outside the regulatory authority of DOL which have

substantial implications for the potential for child labor regulations to adequately protect

working youth.

• Summary - NIOSH goals in providing these recommendations.

• References - A list of all referenced materials.
Youth Employment, Injuries, and Illnesses

3

II. YOUTH EMPLOYMENT, INJURIES, AND ILLNESSES

Employment

The Current Population Survey (CPS), a monthly survey of employment conducted by the

Bureau of Labor Statistics (BLS), provides data on employment for youth 15 years of age and

older (see page vii for more information about this and other data sources). Although BLS

collects employment data for 15-year-olds, official published estimates of employment exclude

15-year-olds. Data on youth less than 15 years of age are not routinely collected. Data on the

prevalence of youth employment, including those less than 15 years of age, have been reported

from periodic surveys, such as the National Longitudinal Survey of Youth [Rothstein and Herz

2000]. Surveys of youth suggest that 80% have worked for pay at some time prior to leaving

school [Light 1995; Steinberg and Cauffman 1995]. 

Young workers typically are employed in part-time, low paying jobs, and they move in and out

of the work force. When employed, they spend substantial numbers of hours at work. In a

recent nationwide survey, 17.9% of high school students reported working more than 20 hours

per week during school [Resnick et al. 1997].

The Bureau of Labor Statistics (BLS) estimated that 2.78 million 16- and 17-year-olds were

employed during 2000 [BLS 2001]. Analysis of unpublished data from the Current Population

Survey suggests that over 450,000 15-year-olds were employed in 1999 [NIOSH 2001a]. Figure

1 provides data on the distribution of youth employment by industry, based on hours of work, for

the 7-year period, 1992 to 1998. Sixty percent of work by 15- to 17-year-olds was in the retail

sector – the majority in eating and drinking establishments and grocery stores. Eating and

drinking places, or restaurants, accounted for more work by youth than any other industry (35%). 

Eighteen percent of youth work time was in services industries. 
Youth Employment, Injuries, and Illnesses

4

Figure 1. Distribution of Working Youth Ages 15-17 by Industry, Based on Hours Worked,

1992-1998

Source: Current Population Survey [NIOSH 2001a]

Retail: Eating and drinking places

Retail: Grocery stores

Retail: Department stores

Other retail

Professional/related services

Entertainment/recreation services

Personal services

Business/repair services

Agriculture/forestry/fishing

Manufacturing

Construction

All other industries

Industry

0 5 10 15 20 25 30 35

Percentage

This includes work in schools, theaters, and nursing homes. Agriculture, forestry and fishing 

industries accounted for 8% of work by 15- to 17-year-olds. These patterns vary somewhat by

age. A previous analysis of CPS data demonstrated that the percentage of 15-year-olds working

in agriculture was more than twice that of 16- and 17-year-olds [NRC/IOM 1998]. 

The types of jobs that adolescents hold are varied. Figure 2 provides data on the distribution of

youth employment by occupation, based on hours of work, for the seven-year period, 1992 to

1998. The most common jobs held by 15- to 17-year-olds were cashier and cook. Occupation

groups that accounted for substantial amounts of work by 15- to 17-year-olds were: food

preparation and service jobs; handlers, equipment cleaners, helpers, and laborers; farming,

forestry and fishing occupations, and administrative support occupations. However, job titles

may not reflect the actual nature of tasks performed by youth [Bowling et al. 1998; Dunn et al.

1998; Massachusetts Department of Public Health 1998a]. For example, a youth hired as a

cashier may also clean and perform other tasks not associated with operating a cash register.

This makes it difficult to estimate the kinds of hazardous exposures adolescents may experience

on the job. In addition, inaccurate job titles can obscure the fact that adolescents are performing

tasks prohibited by child labor laws [NRC/IOM 1998]. 
Youth Employment, Injuries, and Illnesses

5

Figure 2. Distribution of Working Youth Ages 15-17 by Occupation, Based on Hours Worked,

1992-1998

Source: Current Population Survey [NIOSH 2001a]

Cashiers

Other sales occupations

Cooks

Food counter/fountain/related

Other food preparation and service

Other service occupations

Stock handlers/baggers

Other laborers

Farming/forestry/fishing

Administrative support

Precision production/craft/repair

Machine operators/assemblers/inspectors

All other occupations

Occupation

0 2 4 6 8 10 12 14 16

Percentage

Although nationally representative data are not available, there have been a number of surveys

that provide information on tasks, exposures, training, and supervision of working youth. In a

North Carolina survey, 36% of youth 14-17 years of age reported working on ladders or

scaffolding, 31% reported using forklifts, tractors, or riding mowers, and 31% reported working

around very loud noises [Dunn et al. 1998]. In surveys conducted at a Massachusetts high

school, about half of the students who had worked used cleaning chemicals, over one-third used

ladders, 19% used food slicers, and 13% used box crushers [Massachusetts Department of Public

Health 1998a]. Only 50% of the Massachusetts youth reported receiving any safety and health

training. Pooled survey results from high schools in 4 geographic areas (Philadelphia,

Pennsylvania; Brockton, Massachusetts; Oakland and South Central Los Angeles, California)

found that 15-20% of youth worked often or always without supervisors present at the worksite

[Bowling et al. 1998].

Adolescents’ type of employment appears to vary by family income. Youth from low income

families, while less likely to be employed [Johnson and Lino 2000; GAO 1991a], are more likely

to be engaged in high risk occupations. An analysis by the U.S. General Accounting Office

(GAO) found that 20% of employed 15- to 17-year-olds from low income families worked in
Youth Employment, Injuries, and Illnesses

6

hazardous industries, such as agriculture, construction, and manufacturing [GAO 1991a]. 

Analysis of adolescent employment and contributions to family expenditures has suggested that

most youth do not work out of economic necessity [Johnson and Lino 2000]. Though youth

from low income families appear to make more contributions to family expenditures than their

peers from wealthier families, these contributions appear to be modest– approximately 9% of

family income.

Unique Characteristics of Youth Workers

Several youth characteristics raise special concern about the health and safety of adolescents in

the workplace. Youth are at increased risk of injury from lack of experience. Inexperienced

workers are unfamiliar with the requirements of work, are less likely to be trained to recognize

hazards, and are commonly unaware of their legal rights on the job [Castillo et al. 1999a;

NRC/IOM 1998]. 

Developmental factors – physical, cognitive, and psychological – may also place them at

increased risk [NIOSH 1997a; NRC/IOM 1998]. There is great variability in the size of

adolescents during this period of rapid growth. Smaller youth may be at greater risk because of

mismatches between their size and strength and the dimension and design of equipment or

machinery designed for adults. Some organ systems, such as the musculoskeletal, reproductive,

and endocrine systems, undergo periods of rapid growth and development during adolescence

[NRC/IOM 1998, Bearer 1995]. Initiation of reproductive function depends on the development

of a complex system of hormones and feedback mechanisms. In addition to adverse effects of

occupational exposures of concern for all workers of childbearing age, this period of

development in adolescence may introduce added risk of future fertility problems and

gonadotoxic and mutagenic effects. Hypothetically, the period of rapid cell growth that occurs

during adolescence could increase susceptibility to carcinogens, but little data exist to support or

refute this [NRC/IOM 1998]. In a large case-control study of German workers, authors found

evidence to support the contribution of occupational risk factors and early age at first exposure to

early age of onset of lung cancer [Kruezer et al. 1999].

Nonfatal Occupational Injuries and Illnesses

Data on nonfatal occupational injuries and illnesses of workers are available at the national level

from the National Electronic Injury Surveillance System (NEISS) and the BLS Survey of

Occupational Injuries and Illnesses (SOII). NEISS is based on a sample of emergency

departments in the United States, and is presumed to capture injuries among all workers,

regardless of the size or type of employer. NEISS tends to capture acute injuries requiring

immediate attention, such as lacerations and fractures. The SOII is based on a survey of a

sample of employers. Not all types of employers are represented in the survey. For example,

government agencies and the self-employed are not included. The SOII provides data specific

to youth for those injuries and illnesses serious enough to require at least one day away from

work. The SOII includes injuries treated in emergency departments as well as other settings,
Youth Employment, Injuries, and Illnesses

7

such as physician offices and clinics. It is recognized that illnesses and injuries, especially those

where the association with work may be unclear, are understated in occupational surveillance

systems such as the SOII and NEISS [NRC 1987]. NEISS and the SOII are used to describe the

incidence and risk for nonfatal occupational injuries and illnesses among youth, with an

emphasis on more severe injuries. Cases identified in each of these systems overlap. Statespecific data from analyses of worker’s compensation claims are also cited. 

An estimated 77,000 youth less than 18 years of age were treated in hospital emergency

departments for work injuries and illnesses in 1998 [NIOSH 2001b]. It has been estimated that

about 34% of occupational injuries are treated in hospital emergency departments; therefore, the

total number of youth work injuries may exceed 200,000 each year. Employment data for the

calculation of rates were derived from the CPS [NIOSH 2001a]. Youth 15-17 years of age were

among the groups at greatest risk for injuries and illnesses treated in emergency departments

(Figure 3) [CDC 2001a]. An analysis of workers’ compensation data in Washington state found

similar patterns of injury rates by age [Miller and Kaufman 1998]. Analyses of emergency

department data and workers’ compensation data have suggested that youth work injuries

incurred in agriculture tend to be more severe than injuries in other sectors [Hard and Layne

1995; Heyer et al. 1992]
Youth Employment, Injuries, and Illnesses

8

6.0 3.7 7.7 3.9 6.3 3.2 4.5 2.3 2.9 1.8 2.0 1.5 1.7 1.4 1.3 1.3 3.4 2.1

0

2

4

6

8

10

15-17 18-19 20-24 25-34 35-44 45-54 55-64 65 & older All ages

Age group (years)

Rate per 100 full-time workers

Male Female

Figure 3. Estimated Rates Per 100 Full-Time Worker Equivalents of Occupational Injuries and

Illnesses Treated in Hospital Emergency Departments, by Sex and Age Group of Worker –

United States, 1998

Note: Error bars indicate 95% confidence interval.

Source: National Electronic Injury Surveillance System (NEISS) [CDC 2001a]
Youth Employment, Injuries, and Illnesses

9

Occupational injuries and illnesses of youth

are costly— on a personal and societal level. 

In 1993, the cost of injuries and illnesses to

young workers less than 18 years of age was

estimated to exceed 800 million dollars. This

includes direct costs (medical and emergency

services, legal and administrative costs

arising from workers’ compensation, sick

leaves, insurance programs, and the cost of

workplace disruption caused by occupational

injury) and indirect costs (loss of earning and

fringe benefits as a result of wage work loss

associated with injuries). [Miller and

Waehrer 1998].

The SOII estimated 15,000 injuries and

illnesses resulting in days away from work

among youth in 1996 [Windau et al. 1999]. 

These included nonagricultural wage and

salary workers only. The distribution of

injuries by industry was about the same as

employment; that is, about 80% occurred in

retail trades and services [Windau et al. 1999;

Barkume et al. 2000]. The SOII data

indicated that the group including sprains,

strains and tears was the most frequent type

of injury resulting in lost work time among

youth, accounting for 33% of all injuries

(Table 1). Common causes of these injuries

were overexertion in lifting heavy or bulky

objects, and attempts to break falls on

slippery or uneven surfaces.

Table 1. Work Injuries Resulting in Days Away from Work Among Youth Less than 18 Years

of Age, United States, 1996 

Nature of Injury or Illness Percent

Sprains and Strains 33

Bruises, contusions 14

Cuts, lacerations 13

Heat burns 9

Fractures 8

Fractures and other injuries 4

Other 19

Source: Survey of Occupational Injuries and Illnesses (SOII), Bureau of Labor Statistics [Windau et al. 1999]

The median number of days away from work for youth was 4, compared to a median of 5 for all

workers. It is important to note, however, that because youth tend to work part-time, recovery

from injuries and illnesses may frequently include unscheduled work days which would not be

reflected in “days away from work.” There were two types of events in 1996 that resulted in

injuries with median days away from work exceeding 10— generally representing two fulltime

work weeks [Windau et al. 1999]. Young workers being struck by vehicles resulted in a median

of 10 days away from work. An estimated 183 youth less than 18 years of age were struck by a

vehicle at work in 1996. Falls to a lower level, of which there were an estimated 630 cases in

1996, had median days away from work of 11. Analysis of pooled data for a 6-year period,

1992-1997, identified two types of injury events that resulted in at least 400 cases and had

median lost workdays exceeding 10. For the 6-year period, there were 419 cases of falls from

ladders that resulted in bruises and contusions requiring a median of 20 lost workdays. There
Youth Employment, Injuries, and Illnesses

10

were 460 cases of youth sustaining fractures from being caught in or compressed by objects or

equipment, with median lost workdays of 14 [Barkume et al. 2000]. 

Fatal Injuries

Data from the BLS Census of Fatal Occupational Injuries (CFOI) are used to describe injury

deaths of youth less than 18 years of age, calculate fatality rates, and make limited comparisons

with data for older workers. Results are primarily from two publications authored by BLS staff;

the first summarized young worker deaths for the years 1992 to 1997 [Windau et al. 1999], the

second data for the years 1992 to 1998 [Barkume et al. 2000]. Rates were calculated based on

hours of work rather than number of workers because of data demonstrating that on average,

workers less than 18 years of age work fewer hours than adults. Failure to adjust for fewer hours

worked by youth overestimates their exposure to workplace hazards and underestimates their

risk for injury death [Castillo and Malit 1997; Ruser 1998; Castillo et al. 1994]. Rates for youth

are compared to rates for all workers [Windau et al. 1999], and in limited cases to rates for

workers 25-44 years of age [Barkume et al. 2000]. Previous research has demonstrated that

fatality rates increase dramatically beginning at age 45; it has been hypothesized that decreased

tolerance for injuries may account for a part of the rate increase. Limiting the rate comparison to

workers 25-44 years of age allows a comparison with workers who more closely resemble youth

physically [Castillo and Malit 1997]. 

CFOI identified 468 youth less than 18 years of age killed while working during 1992-1998, an

average of 67 deaths per year [Barkume et al. 2000]. About 30% of the deaths were in family

businesses [Windau 1999; Barkume et al. 2000]. The rates for 16- and 17-year-olds for the years

1992-1997 were about three-fourths of the rates for all workers combined (Table 2) [Windau et

al. 1999]. The rates for the youngest workers for which rates can be calculated, 15-year-olds,

were the same as those for all workers. The lack of employment data precludes the ability to

calculate rates for the 109 youth less than 15 years of age who died during this 6-year period. 

The rate for 15- to 17-year-olds, for the period 1992 to 1998, was about five-sixths of the rate for

workers 25-44 years of age [Barkume et al. 2000]. 

Table 2. Number and Rate of Work Injury Deaths by Age, United States, 1992-1997

Age Number of

Deaths

Rate per 100,000

Fulltime

Equivalents

Total, all ages 37,875 5.0

Under 15 years 109 ---

15 years 46 5.1

16 years 91 3.4

17 years 157 3.7

Source: Census of Fatal Occupational Injuries, Bureau of Labor Statistics [Windau et al. 1999]. Dash indicates that

a rate could not be calculated because employment data are not available for this age group
Youth Employment, Injuries, and Illnesses

11

Young worker injury deaths were concentrated in agriculture, retail trade, and construction

(Table 3) [Windau et al. 1999; Barkume et al. 2000]. These patterns varied somewhat from

those seen for workers in general. Proportionately greater numbers of youth were killed in

agriculture and retail than was seen in the general population of workers of all ages.

Table 3. Work Injury Deaths by Industry, Youth and All Workers, United States, 1992-1997

Industry Division Youth < 18 Workers of

All Ages

(no.) (%) (%)

Agriculture, Forestry, and Fishing 162 40 13

Mining --- --- 3

Construction 53 13 16

Manufacturing 21 5 12

Transportation and Public Utilities 12 3 15

Wholesale Trade 14 3 4

Retail Trade 87 22 12

Finance, Insurance and Real Estate --- --- 2

Services 32 8 12

Government 13 3 11

Other or unspecified industries 7 2 1

Total 403 100 100

Source: Census of Fatal Occupational Injuries (CFOI), Bureau of Labor Statistics [Windau et al. 1999]. Dashes

indicate that BLS reporting requirements were not met.

The types of events leading to death of youth workers, for the most part, mirrored those of older

workers. The leading types of fatal events for youth were homicide, highway transportation

incidents, non-highway transportation incidents, being struck by objects or equipment, being

caught in objects or equipment, being struck by vehicles, electrocutions, and falls (Table 4)

[Windau et al. 1999; Barkume et al. 2000]. Transportation incidents included incidents

involving motor vehicles as well as industrial vehicles, such as tractors and forklifts, in which at

least one vehicle was in operation. Highway incidents included events on public roadways,

while non-highway incidents included events on industrial premises, farms and parking lots. 

Table 4. Work Injury Deaths of Youth Less than 18 Years of Age by Event or Exposure, United

States, 1992-1997

Event or exposure Number Percent

Transportation 163 40

 Highway Incidents 70 17

 Nonhighway incidents 47 12

 Worker struck by vehicle 25 6

 Water Vehicle 9 2
Youth Employment, Injuries, and Illnesses

Event or exposure Number Percent

12

 Railway 8 2

Assaults and Violent Acts 82 20

 Homicide 72 18

 Other 10 3

Contact with Objects and

Equipment

82 20

 Struck By 36 9

 Caught in Objects or Equipment 25 6

 Collapsing Materials 17 4

 Running Machinery 17 4

Falls 23 6

Exposure to harmful substances

and environments

44 11

 Electric current 25 6

 Exposure to caustic, noxious, 

 allergenic substances

9 2

 Oxygen deficiency 10 2

Fires and Explosions 8 2

Total 403 100

Source: Census of Fatal Occupational Injuries, Bureau of Labor Statistics [Windau et al. 1999]

Agriculture – More than half of the 162 deaths in agriculture occurred on family farms [Windau

et al. 1999]. Youth killed on farms tended to be younger than youth killed in other industries. 

Farm workers accounted for about three-fourths of the 109 deaths of youth less than 15 years of

age for the 6-year period 1992-1997. Youth 15 to 17 years of age working in agriculture

appeared to have over four times the risk for fatal injury of youth workers in other industries,

and about the same risk as workers 25-44 years of age working in agriculture [Barkume et al.

2000]. An analysis of CFOI data for the period 1992-1996 demonstrated that fatality rates were

highest in the crop production sector (22 deaths/100,000 fulltime equivalent 15- to 17-year-olds),

followed by the agricultural services sector (13.5), and the livestock production sector (9.4)

[Castillo et al. 1999b]. Of the 162 deaths of youth less than 18 years of age in agriculture for the

period 1992-1997, nearly a third (51) were associated with tractors [Windau et al. 1999]. These

deaths occurred from tractor rollovers, youth falling from tractors and being struck by attached

equipment, nonoperators being run over by tractors, and youth being caught in power take-offs. 

In 38 of the 51 tractor-related deaths, the fatally injured youth was operating the tractor. Young

worker deaths in agriculture also resulted from animal attacks, drowning, lightning, falling trees,

and grain engulfments. 

Retail trade – Table 5 provides information on types of events among the 87 youth who died in

the retail trades industry from 1992-1997 [Windau et al. 1999]. Homicide was the leading cause

of death [Windau et al. 1999]. (Suicide and animal attacks were also included in the categories

of assaults and violent acts.) Robberies accounted for at least 41 percent of the homicides, and
Youth Employment, Injuries, and Illnesses

13

possibly up to 79% (motive was unknown for 38% of the cases). Highway crashes also

accounted for a substantial number of deaths in retail trades. 

Table 5. Work Injury Deaths of Youth Less than 18 Years of Age in Retail Trades by Event or

Exposure, United States, 1992-1997

Event or exposure Number Percent

Assaults or Violent Acts 59 68

Homicides 56 64

Transportation 16 18

Highway crashes 13 15

Other 12 14

Total 87 100

Source: Census of Fatal Occupational Injuries, Bureau of Labor Statistics [Windau et al. 1999]

Construction – The events or exposures leading to youth deaths in the construction industry

were diverse (Table 6) [Windau et al. 1999]. Falls and electrocutions were most common. 

Youth 15- to 17-years of age working in construction appeared to have over seven times the risk

for fatal injury of youth workers in other industries, and over 2 times the risk of workers 25-44

years of age working in construction [Barkume et al. 2000]. 

Table 6. Work Injury Deaths of Youth Less than 18 Years of Age in the Construction Industry

by Event or Exposure, United States, 1992-1997

Event or exposure Number Percent

Falls 12 23

Electrocution 11 21

Struck by Object 9 17

Excavation and trenching 5 9

Struck by Vehicle 4 8

Other 6 11

Total 53 100

Source: Census of Fatal Occupational Injuries, Bureau of Labor Statistics [Windau et al. 1999]
14

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15

III. DEVELOPMENT OF RECOMMENDATIONS

Our society places special value on young people and has adopted various social policies,

including protection from hazardous working conditions. Implicit in these policies is the belief

that youth should not be exposed to the same risks as adults. “The vulnerable, formative, and

malleable nature of childhood and adolescence requires a higher standard of protection for young

workers than that accorded to adult workers” [NRC/IOM 1998]. 

Recommendations made in this report are consistent with the DOL commitment to facilitate

meaningful employment and training opportunities while protecting youth from the most

hazardous work activities. In addition to making recommendations for revisions and additions to

HOs, NIOSH makes recommendations for exemptions for apprentices/student learners. 

Information from surveillance, published literature and expertise within NIOSH form the basis

for the recommendations. 

Context for Recommendations

NIOSH recognizes that federal child labor laws are an additional layer of protection afforded to

young workers, supplementing OSHA protections and other regulatory programs. The

requirements for training and personal protective equipment under specific OSHA standards

should mitigate occupational health and safety hazards for young workers. Not all young

workers are covered by OSHA standards, however. For example, OSHA standards cannot be

enforced on small farms. In addition, compliance with OSHA standards is not universal. 

Unlike OSHA standards which prescribe the necessary protections for work (including personal

protective equipment and clothing, training, medical surveillance, and exposure limits), HOs

prohibit employment in certain jobs and industries deemed as too hazardous. NIOSH recognizes

the importance of proposing HOs that are easily understood and enforced by Wage and Hour

inspectors (who may have minimal training in control technology and safety and health

practices), as well as employers, youth, parents and schools who require this information to

make informed decisions about appropriate youth employment. 

Recommendations were driven by information on high-risk activities for all workers, not just

patterns of fatalities and serious injuries seen among young workers. It is prudent to revise or

rescind HOs if current data on occupational injuries and deaths provide compelling evidence that

certain work activities no longer pose a danger to young workers. At the same time, it remains

critical to limit young workers’ exposure to activities which are known to be especially

hazardous to workers of all ages. The absence of deaths, injuries and illnesses among youth at

the current time does not necessarily mean that those activities do not pose serious risks to youth

now or in the future, for a number of reasons:

• By design, current HOs limit youth employment in a number of especially hazardous

activities. The absence or small numbers of injuries and illnesses does not mean the HOs are

no longer needed, and may in fact testify to their effectiveness.

• There are some especially hazardous activities that are conducted by a small workforce. 

Although there may be small numbers of deaths and injuries, risks of fatalities and

debilitating injuries and illnesses can be quite high. Given relatively low employment of
Development of Recommendations

16

youth in such activities, expected numbers of fatalities would be quite low despite high risks.

• Current low levels of youth employment in a hazardous activity would minimize youth

deaths and injuries. The workforce is constantly changing. Forces that limit youth

employment in such work today may not exist in the future.

• Long latency periods for some occupational illnesses mean that resultant diseases may not be

detected for years and even decades after exposure as a youth worker, and the association

with work exposures may not be recognized.

Hazardous Orders Recommendations

Current HOs include a mix of industry, occupation, and equipment and task prohibitions, with

some overlap. That is, certain types of work are encompassed under multiple HOs. In making

recommendations for new HOs or expansion of HOs, NIOSH also used a mix of defining

characteristics (e.g. industry, occupation, equipment or exposure). An effort was made to

propose as parsimonious a list of HOs as possible, recognizing and minimizing overlap between

proposed HOs, while at the same time encompassing work and work settings that pose the

greatest risks for young workers. This was done for purposes of economy and to make the HOs

as simple as possible for employers, parents, and youth. In addition, several recommendations

were made to consolidate existing HOs and to modify definitions to better match current

classification systems. In examining possible new HOs, NIOSH considered whether the risks for

that industry, occupation, or task were already encompassed under existing or proposed HOs

sufficiently to address the hazardous activity or setting. For example, if the majority of fatal and

severe injuries in a high risk industry sector were associated with work prohibited by existing or

proposed HOs, NIOSH would not propose a new HO for that industry sector. 

Existing HOs include detailed definitions or descriptions of work encompassed and excluded in

each HO. For the most part, this report addresses each of the HOs broadly, not addressing each

detailed provision of the HO. Where fatality and injury data and/or the scientific literature

provided sufficient detail, specific provisions of HOs were addressed. As well, some changes to

exemptions are suggested, where the current exemption may be in conflict with

recommendations made elsewhere in the report. Because NIOSH recommendations were

dictated by the limits of available data and research, some recommended prohibitions may

include work that poses little risk to young workers, e.g., clerical tasks at a construction

contractor’s office. NIOSH encourages DOL to consider research as a tool for the identification

of less risky activities that could be exempted in industry- and occupation-wide HOs.

Industries, occupations, or specific work activities that have a high risk for death or severe injury

should clearly be prohibited for young workers. The ability to calculate a risk for death or injury

is dependent on the availability of data both on injuries (numerator) as well as employment or

exposure (denominator). Fatality data are generally more prevalent than data on severe injuries

(although data are available on nonfatal injuries, minor injuries predominate). In considering

fatality data, it should be recognized that for every injury death there are numerous nonfatal

injuries, many resulting in severe disability— the proverbial tip of the iceberg.
Development of Recommendations

17

Information on both frequency of fatal injuries and the number of employed workers is generally

available for Bureau of the Census occupation and industry categories. Fatality rates for specific

occupation or industry sectors provide a more focused assessment of risk than do rates based on

data across all industries or occupations. In many cases the industry and occupation codes are

compatible with existing HOs, but in some cases they are not.

In considering a specific industry of occupation for a HO, NIOSH used the criterion that the risk

of death was more than twice the risk for all workers, measured by a summary rate published by

BLS for multiple years. The risk for work-related injury death for all workers for the period of

1992 to 1997 was 5.0 deaths per 100,000 workers [BLS 1999a]. Therefore, industries or

occupations with a fatal injury rate more than 10 per 100,000 workers were considered for HOs. 

A list of all industry groups meeting this criteria and a summary of current or recommended HO

coverage is presented in the Appendix of this report (page 145). It is important to note that this

threshold rate is per 100,000 workers rather than fulltime equivalents (FTE). Although it is

important to account for hours of work when looking at youth rates specifically and contrasting

youth rates with those of adults, fatality rates are typically presented by 100,000 workers in the

published literature. An analysis by Ruser demonstrated that with the exception of some

population groups, such as youth and older workers, rates per 100,000 workers are generally

equivalent to those per 100,000 FTE [Ruser 1998]. As noted above, in addition to examining the

fatality rate for industries and occupations, the circumstances of fatalities in those sectors were

also considered. If the hazardous exposures were diverse and not well addressed in existing or

proposed HOs, and industry- or occupation-wide HO was proposed. If the types of hazardous

activities were relatively limited and encompassed under existing or proposed HOs, a new HO

was not proposed. In general, the evaluation of HOs defined by occupation and industry were

straightforward given the ability to evaluate fatality rates. 

Less straightforward were evaluations of HOs defined by specific machines or tasks. While

assessment of risk is typically feasible for industries and occupations, in general, data are seldom

available for specific machines or tasks. Data are available on the number of deaths and injuries

associated with specific types of machines or events, however, the level of detail varies. In some

cases, information is available for a specific machine (such as a forklift), while in other cases,

specific machinery are grouped in ill-defined categories such as “paper production machinery,

unspecified” or paper production machinery, not elsewhere classified.” More problematic,

however, is the virtual absence of data and the numbers of specific machines in use. Thus the

data that would be needed to assess level of risk for use of machines or specific tasks are not

available. Evaluating the total numbers of fatalities and injuries was often the only available

means of assessing the need for these types of HOs. It is not valid to compare the number of

deaths involving a machine found in numerous work settings with the number of deaths

involving a machine used in a small number of specialized manufacturing operations. For this

reason, no frequency threshold was used as a basis for recommending HOs related to machinery

use. There are substantial numbers of fatalities associated with some machines addressed by

certain HOs, and in those cases NIOSH is confident in recommending that the HOs be

continued. In a few select cases, the data are less compelling and a cautious removal of the HO

may be considered. For example, a small number of deaths or injuries associated with a

specialized machine presumed to be used in a small number of workplaces would indicate a
Development of Recommendations

4Code of Federal Regulations. See CFR in references.

18

higher rate, which would be considered more compelling that a small number of deaths and

injuries associated with machinery presumed to be prevalent in many workplaces. There are

clearly less data available on machinery and task, and the degree of confidence in this data is

lower than that for industries and occupations. NIOSH used professional judgement and

available data to make reasonable judgements as to level of risk.

In addition to fatality data, data on severe or potentially disabling nonfatal injuries and illnesses

were also considered. Injuries were generally considered severe if they resulted in 15 or more

days away from work (three times the average median days away from work for all workers)

[BLS 1999b]. Amputations were considered to be an especially disabling type of injury. Data

on severe or disabling injuries alone were not considered sufficient to recommend an HO. 

Information on severe or potentially disabling injuries were considered in addition to other data

on fatal injuries and/or serious health risks.

In addition to activities with a high risk for fatal and severe nonfatal injuries, the HOs should

protect youth from exposures that lead to chronic and debilitating illnesses, seriously impacting

the quality and potential of their adult lives. Youth should be protected from exposures where

there is evidence that young workers are more susceptible to harm than adults. However, the

greatest gaps in knowledge to guide regulation of youth employment are in the area of

occupational illness. Little is known about the extent to which work exposures at a young age

lead to acute of chronic illness. Additionally, there are little data on the extent of disability and

impact on quality of life for specific illnesses. Models used to estimate risk for adult workers,

which rely on an 8 hour workday and 40 year working lifetime, cannot be used to estimate risks

for youth who frequently work less than 8 hours a day and move in and out of jobs with different

exposures. Data demonstrating strong associations between workplace exposures and serious

illnesses are cited as justification for HOs to limit or prohibit youth exposures to workplace

health hazards. Data on unique youth susceptibility are cited when available. In some cases,

theoretical risks suggesting a possible unique susceptibility of adolescents are cited for

especially serious hazards, such as exposure to radioactivity in a period of increased cell growth

and a developing reproductive system. Finally, a number of health areas requiring further

research are included in the section “Areas Requiring Further Research” (page 139).

Recommendations for Apprentice/Student Learner Exemptions

NIOSH has made recommendations for apprentice/student learner exemptions (29 CFR4 570)

within the current and recommended new HOs. These recommendations are specific to the

nonagricultural HOs because of their stringent requirements for training and ongoing close

supervision of a qualified and experienced person. The agricultural HOs do not mandate such

standards, and thus would not provide adequate assurance of protection. Exemptions are

recommended in those cases where supervision and training could reasonably be expected to

protect young workers from hazards on the job. However, where there are external factors that

are not under the control of a supervisor, where lines of authority are unclear, or where there are
Development of Recommendations

19

multiple hazards not confined to a specific task, an exemption is not recommended. When

available, data on the effectiveness of training in specific industries, occupations, or tasks were

taken into consideration in recommending apprentice/student learner exemptions.

Format for Recommendations

The discussion of each HO begins with a recommendation to retain or revise, followed by a brief

rationale in support of the recommendation. The remainder of the discussion is dependent upon

the nature and amount of data available. In most instances, a table showing data on fatal and

nonfatal injuries among workers of all ages is provided. Where available, data on fatal and

nonfatal injuries among workers under age 18 (for nonagricultural occupations) or under age 16

(for agricultural occupations) are displayed. Case reports of fatalities and serious injuries to

young workers, appearing in text boxes, are used to illustrate circumstances in which these

injuries occur. Recommendations are further supported by references to relevant scientific

literature.

For each HO recommendation, the summaries include all data NIOSH considered in making the

recommendation, and are not limited to data supporting the NIOSH recommendation. This was

done recognizing that judgements about justification for HOs are value-laden. 

Recommendations in this report are based on judgement and expertise of NIOSH staff. 

Summaries of data are provided to allow DOL to make their own judgements and interpretations. 

Suggestions for further evaluation are provided for a few select machine-based HOs given

limitations in the available data as described earlier in this section.
20

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21

Two youth were killed in 1999 when the

trailer they were in exploded when hit by a

malfunctioning firework. Though it is not

known if the youth were working, fireworks

were being stored and assembled in the trailer

for an ongoing fireworks show approximately

1/4 mile away. An adult working in the trailer

was also killed. [Associated Press 1999]. 

IV. RECOMMENDATIONS PERTAINING TO CURRENT HAZARDOUS ORDERS

Non-Agricultural Occupations

HO 1: Manufacturing or Storage Occupations Involving Explosives

Recommendation — Revise the definition of “explosives and articles containing explosives” to

delete the reference to the Interstate Commerce Commission, which is now obsolete, and to

include the current “List of Explosive Materials,” published by the Bureau of Alcohol, Tobacco

and Firearms (ATF). NIOSH encourages DOL to retain more general terminology (e.g.,

ammunition, fireworks, primers, and smokeless powders) within the text of HO 1, since these

terms are not contained in the “List of Explosive Materials,” yet have meaning for employers,

parents, and youth. These recommendations are consistent with the 1999 Notice of Proposed

Rule-Making (NPRM) published by DOL and with previous NIOSH comments in support of the

proposed rule [64 Fed. Reg. 67130 (1999); NIOSH 2000a].

Rationale — NIOSH review of occupational fatal and nonfatal injury data supports the continued

need to restrict minors from working in establishments that manufacture and store explosives

and explosive components. The most current “List of Explosive Materials” that ATF maintains

on its website appears to be appropriate for DOL use in specifying which materials are relevant

to HO 1. This list has two distinct advantages: the list is periodically updated, and

establishments that manufacture explosives are licensed by ATF and are likely to know about the

list [National Fire Protection Association 1997].

Hazards of Working in Establishments that Manufacture or Store Explosive Materials

The primary hazard that is unique to

establishments that manufacture or store

explosive materials is the potential for

catastrophic fires and explosions resulting

from the mishandling of the explosive

materials. Data from CFOI for the years

1992 through 1997 demonstrated that fires

and explosions killed an average of 194

workers per year [NIOSH 2001c]. Over the

same 6-year period, 8 workers under the age

of 18 died as a result of fires and explosions [Windau et al. 1999]. It is estimated, based on data

from the SOII, that 4,146 workers sustained lost workday injuries and illnesses as a result of

fires and explosions in 1996, with 19 of the injuries occurring among workers less than 18 years

of age [Windau et al. 1999]. In 1997, explosives and blasting agents (OIICS code 075) caused

205 occupational injuries and illnesses resulting in lost workdays, with a median of 20 lost

workdays per injury [BLS 1999b].

Assessment of the risk of fatal injury for workers in establishments which manufacture or store

explosives is greatly hampered by the classification of these establishments in categories that

include related establishments that do not manufacture or store explosive materials. Risks

specific to industries that manufacture or store explosives may be diluted by the inclusion of
Hazardous Orders in Non-Agricultural Occupations

22

fatality and employment numbers for lower risk establishments. For this reason, and because of

the risk for catastrophic fires and explosions in establishments which manufacture and store

explosives, available fatality rates were considered sufficient to justify prohibitions for youth

workers. Fatality data were examined for two industries: 1) Industrial and Miscellaneous

Chemicals (Bureau of the Census Industry Code 192) and 2) Ordnance and Accessories (Bureau

of the Census Industry Code 292). These two industries include establishments that manufacture

explosive materials, but they also include establishments that manufacture a variety of other

chemical products (e.g., adhesives). From 1992 through 1997, Industrial and Miscellaneous

Chemicals had 96 occupational fatalities, representing a work-related fatal injury rate of 3.1 per

100,000 workers [NIOSH 2001c, NIOSH 2001a]. The annual number of deaths was fairly

stable, averaging 16 deaths per year. During the same time frame, six workers died in the

Ordnance and Accessories industry.

Of the 96 deaths in the Industrial and Miscellaneous Chemicals industry, 30 resulted from fires

or explosions and 12 from inhalation or contact with the skin [NIOSH 2001c]. Forty deaths

occurred in the sub-industry of Miscellaneous Chemical Products (this group includes the

“explosives industry”). Thirty-eight deaths occurred in the sub-industry of Industrial Inorganic

Chemicals and another 18 deaths occurred in the sub-industry of Industrial Organic Chemicals.

NIOSH reviewed narrative injury descriptions of the 96 deaths occurring in the Industrial and

Miscellaneous Chemicals Industry [NIOSH 2001c] and determined that these establishments

have the potential for multiple-death incidents resulting from fires and explosions, especially the

Explosives (Standard Industrial Classification [SIC] Code 2892) and Chemical and Chemical

Preparations (SIC Code 2899) industries. Of the 30 deaths resulting from fires and explosions,

five involved fireworks.

HO 2: Motor Vehicle Occupations

Recommendation— 1) Revise the HO to incorporate the provisions of the Drive for Teen

Employment Act, enacted in 1998 as a subsection of the Fair Labor Standards Act, into the HO 2

regulation. 2) Provide guidance on what constitutes “urgent, time-sensitive deliveries” and

“incidental and occasional driving.” 3) Delete from the regulation the now expired exemption for

school bus driving. These recommendations are consistent with the 1999 NPRM published by

DOL and with previous NIOSH comments in support of the proposed rule [64 Fed. Reg. 67130

(1999); NIOSH 2000a].

Rationale— Motor vehicle statistics show that teenagers have extremely high rates of motor

vehicle crashes, deaths, and injuries. Furthermore, occupational injury fatality data demonstrate

that motor vehicle driving is associated with high numbers of occupational deaths among

workers of all ages, and adolescents specifically. The revisions to HO2 are proposed for the

following reasons: 

• By continuing to prohibit 16-year-olds from driving on the job and limiting the amount and
Hazardous Orders in Non-Agricultural Occupations

23

nature of driving permitted for 17-year-olds, the Drive for Teen Employment Act appears

consistent with the approach and intent of Graduated Driving Licensure (GDL) systems

which are heavily supported by the traffic safety community. The Act provides broad

protection for 16-year-olds, the group with the highest crash risk. Extending limited driving

privileges increases employment opportunities for 17-year-olds, yet places restrictions to

allow gradual development of driving skills among these young workers. 

• Formal inclusion of clearer definitions for terms such as “incidental and occasional driving”

and “urgent, time-sensitive deliveries” will help employers comply with the Act as they

assign driving tasks to young workers. Clarification of such terms will aid Wage and Hour

compliance staff as they enforce the Act. 

• Given the low seat belt use among adolescents, it is critical to protection of young workers

that mandatory seat belt use be an employer policy. Since law enforcement policies and

commitment to enforcement vary by state, mandatory seat belt laws alone should not be relied

upon for protection of young workers. 

Teenagers Have Extremely High Rates of Motor Vehicle Crashes, Deaths, and Injuries

Traffic crashes have long been the leading cause of death among persons ages 16 through 20

years. Persons in this age group have the highest fatality and injury rates due to traffic crashes of

any age group. For these adolescents, the 1997 fatality rate was approximately twice that of the

total population (30.4 per 100,000 population vs. 15.7), and the injury rate nearly 2.5 times

higher (3,116 per 100,000 population vs. 1,270) [NHTSA 1998a]. The total crash involvement

rate for 16-year-olds was nearly ten times that of drivers ages 35 to 64 (43 crashes per million

miles driven vs. 4). For 17-year-olds, the rate was 7.5 times higher (30 vs. 4) [Transportation

Research Board 1996]. Numerous risk factors have been implicated in the elevated traffic

injury and fatality rates among youth: lower seat belt use, night driving, risk-taking,

inexperience, distractions from teen passengers, immaturity, speeding, driver inattention, driver

error, failure to adjust to road and weather conditions, incorrect interpretation of traffic signs and

signals, and alcohol use [Ford and Picha 2000; NHTSA 1998b; Phebo and Dellinger 1998]. 

Motor Vehicle Driving Is Associated with High Numbers of Occupational Deaths among

Workers of All Ages, and Adolescents Specifically

Highway crashes continue to be the leading cause of fatalities among workers of all ages,

accounting for 7,822 (20.7%) of all occupational fatalities between 1992 and 1997. Further,

while the total number of occupational fatalities remained fairly consistent over the 6-year

period, occupational fatalities on the highway increased 19.8%, from 1,158 in 1992 to 1,387 in

1997 [NIOSH 2001c]. Given the crash experience of young drivers in the general population

and the additional pressures associated with on-the-job driving, maintaining restrictions on

motor vehicle operation is essential to the protection of young workers. Despite the protections

afforded by HO 2, motor vehicle-related incidents are a leading cause of death among young

workers. Between 1990 and 1992, the National Traumatic Occupational Fatalities (NTOF)
Hazardous Orders in Non-Agricultural Occupations

24

surveillance system, based on death certificates from all states, identified 32 motor vehicle

deaths of workers ages 16 and 17, comprising 28.8% of work-related fatalities in this age group. 

The motor vehicle fatality rate of 1.01 per 100,000 full-time equivalent (FTE) workers was

higher than the rates for workers ages 18 through 44 [Castillo and Malit 1997]. On average,

death certificates in NTOF have been found to identify about 80% of occupational deaths [CDC

2001b]. NTOF differs from CFOI in that the minimum age covered is 16. Table 7 displays

occupational motor vehicle fatality rates and frequencies by age group. 

Table 7. Frequency and Rates (Deaths Per 100,000 FTE) of Occupational Motor Vehicle

Fatality by Age Group, United States, 1990-1992

Age Group (Years) Deaths Rate

16-17 32 1.01

18-19 71 0.85

20-24 309 0.86

25-34 870 0.86

35-44 789 0.82

45-54 710 1.16

55-64 470 1.50

65+ 234 3.33

Source: National Traumatic Occupational Fatality Surveillance System, National Institute for Occupational Safety

and Health [Castillo and Malit 1997]

Analysis of a special CFOI research file provided to NIOSH which includes detailed data such as

actual age, but does not include data from New York City, identified 18 highway fatalities

among workers age 16, and 29 fatalities among workers age 17 for the years 1992-1997 [NIOSH

2001d]. Ten of the 47 decedents (21.3%) were employed in the agricultural production industry,

and thus would not have been covered by HO 2. The occupation specified for 13 of the

decedents was “truck driver” or some other transportation occupation. Table 8 displays

additional characteristics of occupational highway fatalities among workers ages 16 and 17.
Hazardous Orders in Non-Agricultural Occupations

25

Table 8. Characteristics of Occupational Highway Fatalities Among 16- and 17-Year-Olds,

United States, 1992-1997

Age 16 Age 17

Primary Source of Injury

Truck

Car

All other

Total

5 (27.8%)

7 (38.9%)

6 (33.4%)

18 (100.0%)

12 (41.4%)

12 (41.4%)

5 (17.2%)

29 (100.0%)

Event Type

Highway collision

Highway noncollision

All other

Total

6 (33.3%)

7 (38.9%)

5 (27.8%)

18 (100.0%)

13 (44.8%)

9 (31.0%)

7 (24.1%)

29 (100.0%)

Position in Vehicle

Driver

Passenger

Total

13 (72.2%)

5 (27.8%)

18 (100.0%)

22 (75.9%)

7 (24.1%)

29 (100.0%)

Industry

Agriculture/forestry/fishing

Construction

Transportation, communications, public utilities

Wholesale/retail trade

Services

All other

Total

5 (27.8%)

—

—

—

—

7 (38.9%)

18 (100.0%)

6 (20.7%)

6 (20.7%)

—

10 (34.5%)

—

—

29 (100.0%)

Occupation

Transportation and material moving

Farming/forestry/fishing

Laborer

Service

All other

Total

—

5 (27.8%)

—

—

9 (50.0%)

18 (100.0%)

9 (31.0%)

7 (24.1%)

5 (17.2%)

—

—

29 (100.0%)

Time of Incident (Nearest Hour)

6 a.m. to 11 a.m.

12 noon to 5 p.m.

6 p.m. to 9 p.m.

10 p.m. to 5 a.m.

Total

7 (38.9%)

9 (50.0%)

—

—

18 (100.0%)

7 (24.1%)

13 (44.8%)

6 (20.7%)

—

29 (100.0%)

Source: Census of Fatal Occupational Injuries (CFOI), Bureau of Labor Statistics [NIOSH 2001d]. Dashes indicate

that BLS reporting requirements were not met.
Hazardous Orders in Non-Agricultural Occupations

26

Graduated Driver Licensure (GDL) Systems

In recent years, traffic safety researchers have advocated the adoption of GDL systems for youth

less than 18 years of age. The rationale for GDL is that while basic driving skills are quickly

acquired, young drivers’ abilities to make decisions in complex traffic situations develop only

through accumulation of real-world driving experience [McLaurin 1999]. The most

comprehensive GDL systems begin with a learner’s permit period which stipulates basic driver

training, adult driver supervision at all times, limited night driving, and restrictions on carrying

teen passengers. An intermediate period follows during which fewer driving restrictions are

imposed. Full licensure is typically achieved at age 18, provided the young driver remains free

of at-fault crashes, moving violations, and driving under the influence convictions [NHTSA

1998b]. Although not all GDL systems have been in place long enough for evaluations to be

completed, results thus far are encouraging (e.g., crash decreases of 34% and 31% in Kentucky

and Ontario, respectively) [Mayhew 2000; Foss and Evenson 1998]. 

HO 3: Coal Mine Occupations

Recommendation— Retain current HO.

Rationale— The coal mining industry is associated with high injury death rates and severe

nonfatal injuries. Further, work in coal mines is associated with serious lung diseases. Exposure

to respirable coal dust at a young age would mean a longer latency period in which to develop,

suffer, and die from lung diseases.

The Coal Mining is Associated With High Injury Death Rates and Severe Non-Fatal Injuries and

Illnesses

The coal mining industry had the 4th highest lifetime risk of fatal occupational injuries based on

NTOF data for the years 1990 and 1991, with 19 deaths per 1,000 fulltime workers– assuming a

45-year work life [Fosbroke et al. 1997]. Lifetime fatal injury risk is an average lifetime risk for

workers in a particular industry or occupation, assuming a 45 year working life. It was

calculated in a manner comparable to lifetime risk for fatal occupational illness [Fosbroke et al.

1997]. OSHA considers a lifetime risk of 1 death in 1,000 workers to be high enough to justify

the development of a standard for an industry [Stayner 1992; Adkins 1993]. There were 255

deaths in the coal mining industry between 1992 and 1997; the fatality rate was 41.9 per 100,000

workers [NIOSH 2001c, NIOSH 2001a]. In 1997, injuries and illnesses where coal was stated as

the source resulted in a median of 30 days away from work [BLS 1999b]. Injuries and illnesses

in the coal mining industry resulted in a median of 25 days away from work [BLS 1999b].

Work in Coal Mines Is Associated with Serious Lung Disease

Coal Workers’ Pneumoconiosis (CWP), more commonly known as “Black Lung Disease,” is a

chronic, irreversible illness arising from inhalation and deposition of coal dust in the lungs, and
Hazardous Orders in Non-Agricultural Occupations

27

lung tissue reaction to the dust. Clinical and radiographic signs of the disease usually appear

after at least ten years of respirable dust exposure. Workers exposed to coal mine dust more

commonly develop chronic bronchitis, emphysema, and airway obstruction (types of chronic

obstructive pulmonary disease [COPD]) than others with similar tobacco use [Wagner 1994]. A

prospective study of 8,878 working male coal miners, medically examined from 1969 to 1971,

and followed through 1979, demonstrated increased exposure-related mortality from

pneumoconiosis and from chronic bronchitis or emphysema, controlling for age and smoking

[Kuempel et al. 1995]. Analysis of death certificates for the years 1987 to 1996 demonstrated

that decedents whose typical employment was the coal mine industry died more frequently than

would have been expected from CWP (proportionate mortality ratio [PMR] = 111) and chronic

obstructive pulmonary disease (PMR = 2.4). PMRs greater than 1 indicate more deaths from a

specific cause of death than expected based on patterns in the general population [NIOSH

1999a]. Several epidemiologic studies have demonstrated an elevated risk of certain types of

cancer in coal miners [Swaen et al. 1985, 1995; Meijers et al. 1988, 1991; Golka et al. 1998],

however, the International Agency for Research on Cancer (IARC) concluded in a

comprehensive review [IARC 1997] that there was inadequate evidence in humans and in

experimental animals to classify coal dust as carcinogenic. Despite improvements in respiratory

protection for coal mine workers, exposures to respirable coal dust continue to occur, as well as

illness in workers exposed to less than the permissible level. For the period 1995-1996, 6% of

samples collected by the Mine Safety and Health Administration exceeded permissible levels

[NIOSH 1999a]. 

HO 4: Logging and Sawmilling Occupations

Recommendation— 1) Expand the HO to cover work in operation of timber tracts and tree farms

(SIC 081) and in forestry services (SIC 085). 2) Remove the current exemptions for

construction work for living or administrative quarters.

 

Rationale— 1) Fatality data show that work in logging and in sawmills and planing mills

continues to be associated with substantial numbers of fatalities and nonfatal injuries, and high

fatality rates. The logging industry has among the highest average annual fatality rates, and the

highest lifetime risk of fatal injury. The forestry industry also has a high fatality rate, and

workers face injury risks similar to those of logging workers. Forestry includes forest

firefighting, which poses substantial risk to workers of all ages. However, work in Forest

Nurseries and Gathering of Forest Products (SIC 083) is associated with very small numbers of

fatalities, and should not be prohibited for youth.

2) Construction work has high risks for fatal and nonfatal injuries, and should not be exempted

in the construction of living or administrative quarters at logging sites or mills (see

recommendation for construction HO on page 101). 

The Manufacture of Lumber and Wood Products Is Associated with High Numbers and Rates of

Fatal Injury
Hazardous Orders in Non-Agricultural Occupations

28

The logging industry (Bureau of Census Industry Code 230) had the highest lifetime risk of fatal

injury of any industry, at 47 deaths per 1,000 workers, based on an analysis of NTOF data for

1990 and 1991. Sawmills, planing mills, and millwork (Bureau of the Census Industry Code

231, which is equivalent to SIC codes 242 and 243) had the 14th highest lifetime risk of 5.8

deaths per 1,000 workers [Fosbroke et al. 1997].

CFOI data demonstrated that there were 1,218 fatalities between 1992-1997 in lumber and wood

products manufacturing industries (SIC 24, Table 9) [NIOSH 2001c]. These establishments

included logging companies (SIC 241); sawmills and planing mills (SIC 242); and companies

that manufacture millwork, veneer, plywood, and structural wood members (SIC 243); wood

containers (SIC 244); wood buildings and mobile homes (SIC 245); and miscellaneous wood

products (SIC 249). Ninety-three percent of the fatalities occurred in SICs 241, 242, and 243. 

The fatality rate for the 6-year period for all industries within SIC 24 was 27.7 deaths per

100,000 workers [NIOSH 2001c; NIOSH 2001a]. The fatality rate for the logging industry

alone was 103.6 deaths per 100,000 workers, more than 20 times the rate for workers in all

industries. It was not possible to calculate fatality rates separately for sawmills and planing mills

(SIC 242) and millwork, veneer, plywood, and structural members (SIC 243) because

employment data were not available for each of these industry sectors individually. The rate for

these two industry sectors combined was 11.5 deaths per 100,000 workers. 

Employment in logging was also associated with 3,883 nonfatal injuries and illnesses in 1997

requiring days away from work, with a median of 12 lost work days [BLS 1999b]. Large

numbers of injuries and illnesses were also seen in the other five SICs, but these required

considerably fewer median days away from work than did logging-related injuries.
Hazardous Orders in Non-Agricultural Occupations

29

Table 9. Deaths and Nonfatal Injuries and Illnesses Requiring Days Away from Work in

Lumber and Wood Products Manufacturing Industries, United States

Industry [SIC code] Deaths,

1992-1997

Deaths per

100,000

Workers,

1992-1997

Nonfatal

Injuries and

Illnesses,

1997

Median

Days Away

from Work,

1997

Logging [SIC 241] 874 103.6 3,883 12

Sawmills and planing mills

[SIC 242]

187 11.5* 8,482 5

Millwork, veneer, plywood,

and structural members [SIC

243]

69 11.5* 9,015 4

Wood containers [SIC 244] 19 7.0** 3,368 4

Wood buildings and mobile

homes [SIC 245]

21 4.8 4,013 4

Miscellaneous wood products

[SIC 249]

43 7.0** 2,293 4

Total [SIC 24] 1,218 27.7 31,054 ---

Source: Census of Fatal Occupational Injuries (Deaths) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Nonfatal injuries) [BLS 1999b], Bureau of Labor Statistics. Dashes indicate that data were not available.

*Rate for SICs 242 and 243 combined.

**Rate for SICs 244 and 249 combined.
Hazardous Orders in Non-Agricultural Occupations

30

In 2000, a 16-year-old male youth was

electrocuted while working at a sawmill. The

youth was employed to do odd jobs and

clean-up work. Working alone while other

workers were taking a break, the youth was

using a compressed air hose and nozzle to

blow sawdust off and away from a 440-volt

electric re-saw machine. The youth

apparently knelt down under the machine on

wet ground and contacted the machine’s

metal framework which was energized. The

re-saw machine had been powered down, but

not de-energized. The re-saw machine was

located outside and was not protected from

weather elements. Additionally, the machine

had exposed wiring and was not

appropriately grounded. [Missouri

Department of Health 2001].

NIOSH analysis of a special CFOI research

file for the years 1992 through 1997 (which

includes more detail than on the standard

research file, but excludes New York City)

identified 5 deaths of workers younger than

age 18 in SIC 24. All of the fatalities

occurred in logging (SIC 241) and in

sawmills and planing mills (SIC 242). The

fatality rate for all of SIC 24, taking into

account hours worked, was 17.6 deaths per

100,000 FTE workers ages 15-17, nearly twothirds the rate of 27.7 per 100,000 workers of

all ages [NIOSH 2001d]. Youth fatalities in

these settings involved being struck by falling

trees and vehicles [Windau et al. 1999].

The Forestry Industry Also Has a High

Fatality Rate

CFOI identified 82 fatalities of workers

employed in the forestry industry (SIC 08) between 1992 and 1997, with a fatality rate of 16.6

deaths per 100,000 workers (Table 10) [NIOSH 2001c]. Fatalities were largely confined to two

sectors within the forestry industry: Timber Tracts (SIC 081), which consists of establishments

that operate timber tracts or tree farms for the purpose of selling standing timber (35 deaths); and

Forestry Services (SIC 085), which contains establishments that perform services related to

timber production, wood technology, timber cruising and estimation, and forest firefighting and

fire prevention (39 deaths). Although government agencies engaged in forest firefighting and

fire prevention are placed by SIC rules in SIC 085, examination of CFOI data showed that 16

additional fatalities that were clearly attributable to forest firefighting were misclassified in the

public administration industry division. Therefore, the fatality rate of 16.6 for the forestry

industry underestimates the true risk to workers in the industry.

Transportation incidents were the most common fatal event among forestry workers, accounting

for 43 deaths (52.4%). However, forestry workers also experienced fatal injuries such as those

typically associated with the logging industry: in 26 of the 82 fatalities (31.7%), the worker was

struck by a falling object (a tree in all but one instance). 

 

The SOII identified 438 nonfatal injuries and illnesses to forestry workers in 1997 [BLS 1999b]. 

This small number may be attributed to the lack of coverage of government employees by the

SOII. High median days away from work, 25, were associated with nonfatal injuries and

illnesses to workers in Forestry Services.
Hazardous Orders in Non-Agricultural Occupations

31

Table 10. Deaths and Nonfatal Injuries and Illnesses Requiring Days Away from Work in

Forestry Industries, United States

Industry [SIC code] Deaths,

1992-1997

Deaths per

100,000

Workers,

1992-1997

Nonfatal

Injuries and

Illnesses,

1997

Median

Days Away

from Work,

1997

Timber tracts [SIC 081] 35 --- 148 5

Forestry services [SIC 085] 39 --- 246 25

Other forestry (includes

Forest Nurseries and

Gathering of Forest Products

[SIC 083] and Forestry,

unspecified [SIC 080])

8 --- --- ---

Total [SIC 08] 82 16.6* 438 7

Source: Census of Fatal Occupational Injuries (Deaths) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Nonfatal injuries) [BLS 1999b], Bureau of Labor Statistics. Dashes indicate that data were not available.

*Employment data for calculation of fatality rates below the 2-digit SIC were not available.

HO 5: Power-Driven Woodworking Machine Operations

Recommendation— 1) Expand the HO to include similar power-driven machines used to

operate on materials other than wood. Alternatively, NIOSH encourages DOL to consider

rewriting HOs 5, 8, and 12, which respectively address machines that work with wood, metal,

and paper, by merging into a single or multiple HOs which address the function of machines

rather than the material processed. 2) Retain the existing exemption for apprentices/student

learners.

Rationale— 1) Metal, woodworking, and special material machinery are associated with

substantial numbers of worker deaths and injuries. Although it is possible to identify some

deaths and injuries attributed to woodworking machines, and tools specifically, in other cases it

is not possible to identify if the machine was designed for or used on wood or some other

material. Furthermore, many of the hazards inherent in woodworking machines are found in

machines that process other materials. An advantage to rewriting the HOs to address function

rather than material processed would be the increased ability to monitor the incidence and

patterns of deaths and injuries associated with specific types of machinery using routinely

collected fatality and injury data. This would allow an assessment as to which machines

continue to be a safety concern for youth, and which machines are no longer a concern because

of advances in safety features or because of diminished use in workplaces. 
Hazardous Orders in Non-Agricultural Occupations

32

In April 1999, a 17-year-old youth severed

his right arm at the elbow while working on a

power-driven pallet-notching machine. 

[Associated Press 2000].

In 2000, a 14-year old male youth was pulled

into an operating wood chipper and fatally

injured. The youth, who had accompanied

his father to work, had been assigned the task

of dragging limbs and branches to the wood

chipper, and was specifically instructed not to

feed the chipper. He picked up a 4- to 5-inch

diameter limb and began feeding it into the

chipper when a branch struck him in the back

and pulled him into the rotating chipper

knives [NIOSH 2001e].

2) An apprentice/student learner exemption is appropriate since the hazards of specific

machinery are typically known, controllable, and limited to the machinery. 

Substantial Numbers of Deaths and Nonfatal Injuries and Illnesses Associated with PowerDriven Woodworking Machines and Similar Machinery

The ability to identify deaths and injuries

associated with equipment specifically

prohibited by HO 5 is hampered because of

an incompatibility with the classification

scheme used in occupational injury statistics,

the Occupational Injury and Illness

Classification Structures (OIICS) [National Safety Council 1995]. The OIICS classify machines

by function rather than the material processed by the machine. Although it is possible to identify

specific types of machines that principally work on wood, such as saws, in other instances, the

machines may work on wood as well as other materials, for example, boring, drilling, planing

and milling machinery. 

Table 10 provides data on fatal and nonfatal injuries associated with a variety of power-driven

machines that operate on wood, metal, and other materials. For the 6-year period 1992-97, there

were a total of 287 deaths among workers of all ages in which this type of machinery was found

to be a primary or secondary contributor to the death [NIOSH 2001c]. It is assumed that

stationary saws are primarily used on wood. Stationary sawing machinery contributed to 46

deaths. In 1997, there were 26,051 injuries and illnesses serious enough to require time away

from work associated with metal, woodworking and special material machinery [BLS 1999b]. 

Stationary saws accounted for 7,415 injuries and illnesses. The median days away from work

for injuries and illnesses associated with metal, woodworking and special material machinery

was slightly higher than the median for all injuries, 6 compared to 5. Injuries and illnesses

associated with stationary saws had a median

of 8 days away from work. 

Another type of machine that processes wood

and is not reflected in Table 10 because it is

classified under logging machinery, is a wood

chipper (OIICS code 3231). Wood chippers

typically consist of a feed mechanism, knives

mounted on a rotating chipper disc or drum,

and a power plant [NIOSH 1999b]. In order

to be able to feed large limbs into the

machine, there is minimal or no machine

guarding. A NIOSH analysis of CFOI data

for the period 1992 to 1997 identified 32

deaths among workers of all ages associated with this machinery [NIOSH 2001c]. Of these

deaths, 56% were in industries or occupations not currently covered by HOs, such as landscaping
Hazardous Orders in Non-Agricultural Occupations

33

services, tree removal, and electrical services. Deaths involved being caught by the feed

mechanism and being pulled through the chipper knives (41%), and being struck by parts that

separated from the machine (34%).

Table 10. Deaths and Nonfatal Injuries and Illnesses Requiring Days Away From Work

Associated with Metal, Woodworking, and Special Material Machinery, United States.

Type of Machinery [OIICS code] 1

N

 or 2N

Source of

Death, 

1992-97

Nonfatal

Injuries and

Illnesses

(1o source),

1997

Median Days

Away from

Work, 1997

Metal, woodworking, and special

material machinery, unspecified

[350]

12 1,565 8

Bending, rolling, shaping

machinery [351]

31 1,733 7

Boring, drilling, planing, milling

machinery [352]

23 2,340 5

Extruding, injecting, forming,

molding machinery [353]

77 2,172 6

Grinding, polishing machinery

[354]

12 2,322 4

Lathes [355] 25 1,109 6

Presses, except printing [356] 32 4,183 7

Sawing machinery, stationary [357] 46 7,415 8

Other metal, woodworking, and

special material machinery [359],

and threading and tapping

machines [358]

29 3,211 3 [OIICS 359]

7 [OIICS 358]

Total 287 26,051 6

Source: Census of Fatal Occupational Injuries (Deaths) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Nonfatal injuries), Bureau of Labor Statistics [BLS 1999b].

Table 11 provides data on fatal and nonfatal injuries associated with powered handtools. As

with the machinery identified above, it is difficult to identify in injury statistics powered tools

specific to woodworking. For the 6-year period, 1992-1997, there were 304 deaths associated
Hazardous Orders in Non-Agricultural Occupations

34

with powered tools, 136 of which were associated with cutting tools, such as chain saws [NIOSH

2001c]. In 1997 alone, there were 22,648 non-fatal injuries and illnesses associated with power

tools [BLS 1999b]. The median days away from work in 1997 was lower for powered tools than

for all injuries, 4 versus 5 days, respectively. It is important to note that there were 8 deaths

during the period 1992-97 and 5,812 injuries and illnesses in 1997 for which it was not

determined if the handtool was powered. These deaths and injuries are not included in Table 10,

but may have in fact involved powered handtools. 

Table 11. Deaths and Nonfatal Injuries and Illnesses Requiring Days Away from Work

Associated with Powered Handtools, United States

Type of Powered Handtool

[OIICS code]

1

N

 or 2N

Source of

Death,

1992-1997

Nonfatal

Injuries and

Illnesses, (1N

source) 1997

Median

Days Away

from Work,

1997

Unspecified [720] --- 353 7

Boring (incl. augers, drills) [721] 22 3,093 4

Cutting (incl. chainsaws) [722] 136 5,539 10

Striking and nailing (incl. 

riveters) [723]

9 2,739 5

Surfacing (incl. sanders) [724] 13 2,604 3

Turning (incl. screwdrivers) [725] 7 1,038 6

Welding and heating [726] 97 5,513 2

Other (incl. nail guns, stapling

tools) [729]

20 1,770 5

Total 304 22,648 4

Source: Census of Fatal Occupational Injuries (Deaths) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Nonfatal injuries), Bureau of Labor Statistics [BLS 1999b]. The dash indicates that BLS reporting

requirements were not met.

HO 6: Occupations Involving Exposure to Radioactive Substances and to Ionizing

Radiation

Recommendation— Revise HO to reflect current risks to youth for occupational radiation

exposures. The following wording is suggested: Working with any machine that generates

ionizing radiation, including assisting in diagnostic or therapeutic radiology procedures
Hazardous Orders in Non-Agricultural Occupations

35

involving ionizing radiation.

Rationale— Youth are increasingly working in settings such as medical or veterinary offices

where they may be exposed to ionizing radiation while assisting in diagnostic radiologic

procedures. Evidence for increased susceptibility of youth to ionizing radiation has prompted

OSHA and the U.S. Nuclear Regulatory Commission (NRC) to set the maximum permissible

exposure for youth at 10% of the permissible level for adults. The increased risk for youth and

research showing that radiographic equipment and procedures frequently do not meet national

standards make an apprentice/student learner exemption inappropriate.

Occupational Risk to Youth for Exposure to Radiation

According to the Current Population Survey, 46,159 youth under the age of 18 worked in

veterinary services, or offices and clinics of physicians, dentists, chiropractors, or other health

practitioners during 1999. This number has been increasing since 1988 when 18,068 youth

worked in these settings [NIOSH 2001a]. A 1987 survey of 29 randomly selected veterinary

practices with radiographic equipment in Ohio indicated that the majority did not meet standards

for x-ray equipment and procedures. Protective equipment such as lead shields and radiation

exposure monitors were used in fewer than half of the practices [Fritschi 2000].

Concerns about Youth Occupational Exposure to Radioactive Substances and Ionizing Radiation

Risks of occupational exposures to ionizing radiation in youth stem from concerns about

increased susceptibility for cell damage associated with adolescent growth and development, as

well as concern about increased likelihood for disease development with exposures at an earlier

age. There is some evidence of age-specific effects of ionizing radiation from studies of atomic

bomb survivors and Marshall Islanders exposed to fallout from nuclear weapons testing [Merke

and Miller 1992]. A number of entities have recommended or mandated no exposure or reduced

limits for youth occupational exposures to radiation [Emery and Cooper 1998]. The National

Council on Radiation Protection and Measurements recommended in 1964 and 1966 that youth

not be occupationally exposed to radiation, but that there be a provision for educational activities

with exposures not exceeding 0.1 rem (1 mSv) per year. The Nuclear Regulatory Commission

[10 CFR 20.1207] and OSHA [29 CFR 1910.2] both limit youth exposures to 10% of the

permissible exposure for adults, or 5 mSv (0.5 rem) per year and 3 mSv (0.3 rem) per quarter

year. It is noteworthy that this is the only OSHA standard that specifies a standard for youth

different than for adults. 

HO 7: Power-Driven Hoisting Apparatus Operations

Recommendation — 1) Expand the HO to cover repairing, servicing, disassembling, and

assisting in tasks being performed by the machine. This recommendation applies to all
Hazardous Orders in Non-Agricultural Occupations

36

machinery covered under this HO. 2) Expand the HO to prohibit youth from riding on any part

of a forklift as a passenger (including the forks), and from working from forks, platforms,

buckets, or cages attached to a moving or stationary forklift. 3) Expand the HO to prohibit work

from truck-mounted bucket or basket hoists commonly termed “bucket trucks” or “cherry

pickers.” 4) Expand the HO to cover commonly used manlifts that do not meet the current

definition, specifically aerial platforms. 5) Remove the exception that currently permits youth to

operate an electric or air-operated hoist of less than one ton capacity.

Rationale — 1) Substantial numbers of deaths and injuries are associated with operating and

assisting in tasks performed by power-driven hoisting apparatus, including deaths of youth.

Although HO 7 prohibits youth from assisting in operation of cranes and derricks, similar

prohibitions do not exist for other machines covered under this HO. Additionally, a considerable

number of deaths were associated with activities not directly related to operation of the hoisting

apparatus, notably servicing, repairing, and disassembling. 2) Substantial numbers of fatalities

occur among workers who are passengers on forklifts, riding on the forks, or working from

raised forklifts and attachments. None of these activities is currently prohibited for youth. 3)

Worker fatalities are associated with work from truck-mounted basket and bucket hoists. The

associated risk of falls and electrocution support expansion of HO 7 to prohibit work from truckmounted hoists. 4) The current definition of manlifts in HO 7 specifies that youth are prohibited

from riding on manlifts driven through pulleys, sheaves, and sprockets. Many other types of

manlifts now in use, particularly aerial platforms now excluded from HO 7, appear to pose more

significant injury risk. 5) Surveillance systems for fatal and nonfatal injuries do not provide

sufficient detail to justify the current exception that allows youth to operate hoists of less than

one ton capacity. A hoisted load weighing less than one ton has the potential to cause injury or

death as a result of falling, or being improperly rigged or handled. Hoist-related fatalities of

young workers have been reported, including a recent case in which a youth was killed while

operating a half-ton capacity hoist.

Power-Driven Hoisting Apparatus Are Associated with High Numbers of Deaths and Serious

Injuries and Illnesses Among Workers of All Ages, and Youth Specifically

Workers of all ages are killed and seriously injured in incidents associated with the machinery

covered by this HO: cranes, forklifts, hoists, manlifts and derricks. Table 12 includes data on

fatal and nonfatal injuries associated with selected types of hoisting machines that are clearly

identifiable from occupational injury statistics. With the exception of truck-mounted bucket and

basket hoists, all are at least partially addressed by HO 7. These selected types of machines

contributed to over 1,300 deaths of workers during the 6-year period, 1992-97 [NIOSH 2001c],

and over 22,000 serious injuries and illnesses in 1997 [BLS 1999b]. Injuries and illnesses

associated with this type of apparatus, with the exception of derricks, had more median days

away from work than injuries in general. 
Hazardous Orders in Non-Agricultural Occupations

37

Table 12. Deaths and Nonfatal Injuries and Illnesses Requiring Days Away from Work

Associated with Hoisting Apparatus, United States.

Type of Hoisting Apparatus

[OIICS Code]

1

N

 or 2N

Source of

Death,

1992-1997

Nonfatal

Injuries and

Illnesses

(1N Source),

1997

Median

Days Away

from Work,

1997

Cranes [343] 479 1,355 10

Overhead hoists [344] 64 961 7

Derricks [345] 31 140 2

Bucket or basket hoist – truck

mounted [3461]

99 189 5

Manlifts [3466] 69 1,227 10

Forklifts [851] 613 18,754 8

Total 1,355 22,437 ---

Source: Census of Fatal Occupational Injuries (Deaths) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Nonfatal injuries), Bureau of Labor Statistics [BLS 1999b]. The dashes indicate that BLS reporting

requirements were not met.

CFOI data for 1992-1997 showed that 290 of the 613 forklift-related fatalities (47.3%) were

associated with work activities other than operating the forklift. Many of the non-operator

fatalities were related to working around the machine: being run over, struck by, or pinned by a

forklift (97 fatalities); or being struck by a load that fell from a forklift (74 fatalities). In other

instances, workers died when they fell from a work surface elevated by a forklift (65 fatalities),

while repairing or servicing a forklift (26 fatalities), or while riding as a passenger on the forklift

or forks (21 fatalities) [NIOSH 2001c].

NIOSH analysis of CFOI data for 1992-1997 demonstrated that most crane-related fatalities

were among workers other than operators [NIOSH 2001c]. Only 99 of the 479 fatalities (21%)

were operating the crane. Thirty-six percent were engaged in construction, repair, and cleaning

work; 12% were operating other vehicles or equipment, and 13% were performing material

handling tasks. In 58 of the crane-related fatalities, the case narrative stated that the worker was

repairing or disassembling the crane.
Hazardous Orders in Non-Agricultural Occupations

38

In 2001, a 14-year-old youth working at a rental

equipment company was fatally injured by a

electric chain hoist. The youth was employed to

assist customers with loading and unloading rental

equipment from customer vehicles and preparing

the rental equipment for use by the next customer.

After using a half-ton electric hoist to remove a

vibratory plate tamper from a customer’s truck,

the youth attached himself to the hoist and was

seen raising and lowering himself using the hoist.

When he had not returned to the office several

minutes later, his coworkers found him suspended

by the chain around his neck [NIOSH 2001g].

In 1999, a 16-year-old youth and 2 adults fell

1200 feet to their death when the winch

operator lost control of the hoist line they

were “riding.” The three workers, who were

standing in loops tied into the hoist line, were

being hoisted up to paint a section of a 1500-

foot telecommunications tower. The hoist

mechanism consisted of a portable capstan

hoist at the base of the tower and a pulley at

the top. At about the 1200-foot level, the

hoist line began to slip off the capstan, and

the operator was unable to regain control

[NIOSH 2000b].

HO 7 now prohibits youth from

operating various types of hoists,

including overhead hoists, which

were associated with 64 deaths

between 1992 and 1997. Over this

6-year period, CFOI also identified

99 fatalities involving truckmounted bucket or basket hoists

commonly referred to as “cherry

pickers” or “bucket trucks,”

machinery not currently prohibited

for youth under HO 7 [NIOSH

2001c]. Deaths associated with

work from truck-mounted hoists

were due primarily to falls (49

fatalities) and electrocution (31

fatalities). 

HO 7's definition of “manlift,” limited to machines suspended by belts, cables, or chains and

driven through pulleys, sheaves, and sprockets, also does not reflect all types of these machines

currently in use. CFOI narratives indicate that the majority of the 69 manlift-related deaths

between 1992 and 1997 fell outside the definition of “manlift” provided in HO 7 in that the

machine was not used as a means of conveyance but as an aerial platform. Aerial platforms may

be described as manually-operated, powered, or boom-supported [Equipment Manufacturers

Institute 1995].

Analysis of a special CFOI research file that

includes detailed data such as age, but

excludes data from New York City,

identified 11 fatalities of youth less than 18

years of age associated with hoisting

equipment for the years 1992 to 1997. 

Forklifts accounted for 6 fatalities [NIOSH

2001d]. The forklift fatalities involved youth

operating the forklift, as well as working in

the vicinity of the forklift. Crane fatalities

all involved youth assisting in the operations

of the crane, such as adjusting outriggers, or

hooking or stabilizing a load.
Hazardous Orders in Non-Agricultural Occupations

39

HO 8: Power-Driven Metal Forming, Punching, and Shearing Machine Operations

Recommendation— Expand the HO to include several types of metalworking machinery

specifically excluded from this HO, including milling function machines, turning function

machines, grinding function machines, and boring function machines. Retain the

apprentice/student learner exemption. Please also note the recommendation under HO 5, for the

Department of Labor to consider rewriting HOs 5,8, and 12 into a single or multiple HOs that

address machine function rather than material operated on by a machine.

Rationale— Data on deaths and injuries associated with metalworking machines include tools

currently excluded under this HO. The hazards of these excluded tools are similar to the hazards

of woodworking tools which are prohibited by HO 5. There is some evidence to suggest that

youth may be at greater risk for amputations from presses than adult workers. Available data

suggests that training can be effective in reducing injuries and unsafe behaviors with power

presses and handtools, providing support for an apprentice/student learner exemption.

Metalworking Machines Associated with High Numbers of Deaths and Serious Injuries and

Illnesses

Please refer to HO 5 (page 31) for a discussion of issues related to the identification of deaths

and injuries associated with machines that operate on a specific type of material, such as metal;

and, Table 10 (page 33) for data on metal, woodworking and special material machinery. CFOI

data demonstrate that fatalities are associated with machines both prohibited and permitted by

HO 8 (assuming that some types of machines, such as bending, rolling, and shaping machines

work primarily on metal). While CFOI identified 31 fatalities between 1992 and 1997

associated with bending, rolling, or shaping machines, there were also 32 deaths involving

presses, 14 involving metalworking lathes, and 12 involving machinery used for grinding and

polishing [NIOSH 2001c].

As demonstrated in Table 10 (page 33), injuries requiring at least 1 day away from work have

also been associated with these types of machines: 1,733 injuries with 7 median days away from

work for bending, rolling, and shaping machines; 2,322 injuries with 4 median days away from

work for grinding and polishing machines; and 4,183 injuries with 7 median days away from

work for presses. One study suggested that workers less than 19 years of age were more likely

than older workers to sustain amputation injuries when operating presses [Jensen and Sinkule

1988]. 

Evidence for Value of Safety Training

Apprentice/student learner exemptions which are currently permitted under this HO are

supported by limited data demonstrating the effectiveness of training. Studies of college

students in simulated situations have found training to be effective in decreasing unsafe work

practices and injuries associated with operation of power presses and handtools [Rubinsky and

Smith 1971; Smith and Rubinsky 1972; Leslie Jr and Adams 1973; Cohen and Colligan 1998]. 
Hazardous Orders in Non-Agricultural Occupations

40

These studies emphasized the value of hands on experience and simulations.

HO 9: Occupations in Connection with Mining, Other Than Coal

Recommendation — 1) Expand to include all work performed in connection with petroleum and

natural gas extraction. 2) Remove the portion of exemption 3 now permitting repair and

maintenance of roads, and exemption 4 now permitting work on track crews. 

Rationale — 1) Workers throughout the mining industry continue to suffer high numbers and

rates of occupational fatalities and injuries, including the oil and gas extraction industry which is

currently excluded from HO 9. 2) Removal of these exemptions is consistent with

recommendations for new Hazardous Orders addressing construction work and railroad work

appearing later in this report (see pages 101 and 113). 

High Occupational Fatality Rates and Nonfatal Injuries and Illnesses Throughout the Mining

Industry, Including Oil and Gas Extraction

The metal mining (BOC code 040), oil and gas extraction (BOC code 042), and nonmetal

mines/quarries industries (BOC code 050) had the 7th, 8th, and 10th highest lifetime risk for

fatal injury, 11.2, 10.8, and 7.2 deaths per 1,000 full-time workers, respectively, based on 1990-

91 NTOF death certificate data. Coal mining ranked 4th with a lifetime fatal injury risk of 19.1

deaths per 1,000 full-time workers. Lifetime risk for fatal injury, as discussed previously for HO

3 (page 26), is an estimate of average lifetime risk of death for workers in a particular occupation

or industry, based on a 45-year working life [Fosbroke et al. 1997].

Workers throughout the mining industry continue to suffer high rates of occupational injury

death and large numbers of serious injuries, including in the oil and gas extraction industry

which is currently excluded from HO 9. The mining industry had the highest fatality rate of any

industry division in 1992-1997, 25.8 deaths per 100,000 workers [NIOSH 2001c; NIOSH

2001a]. The 1992-1997 fatality rate for oil and gas extraction, 25.8 per 100,000 workers, was

only slightly lower than the overall industry rate, and was nearly five times the fatality rate

among workers in all industries. Table 13 shows that the oil and gas extraction sector accounted

for more than half of all mining industry deaths between 1992 and 1997, although substantial

numbers of fatalities also occurred in the other three sectors [NIOSH 2001c]. Table 13 also

demonstrates the substantial number of injuries and associated disability in the various mining

sectors, with the median days away from work far in excess of the median 5 lost workdays

reported for all workers [BLS 1999b]. 

Table 13. Deaths and Nonfatal Injuries and Illnesses Requiring Days Away from Work by

Mining Industry Sector, United States.
Hazardous Orders in Non-Agricultural Occupations

41

Industry Sector Deaths,

1992-1997

Nonfatal

Injuries and

Illnesses,

1997

Median Days

Away from

Work, 1997

Metal mining 83 800 33

Coal mining 255 4,987 25

Oil and gas extraction 521 9,550 13

Nonmetallic minerals, except

fuels

143 2,732 13

Total 1,002 18,069 18

Source: Census of Fatal Occupational Injuries (Fatalities) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Injuries), Bureau of Labor Statistics [BLS 1999b]. 

Between 1980 and 1989, NTOF identified 10 fatalities of workers under age 18 in the oil and gas

extraction sector [NIOSH 1994a]; however, no additional fatalities of young workers have been

identified since 1989 by either NTOF or CFOI. These 10 fatalities involved injury scenarios

typical of those experienced by workers of all ages in this industry: electrocution, fall from an oil

rig or derrick, being struck by a falling machine part, and explosion of a storage tank. 

HO 10: Occupations in the Operation of Power-Driven Meat-Processing Machines and

Occupations Involving Slaughtering, Meat-Packing or Processing, or Rendering

Recommendation— 1) Expand to prohibit work in all meat products manufacturing industries

(SIC 201). Meat products industries include meat packing plants (SIC 2011), sausages and other

prepared meat products (SIC 2013), and poultry slaughtering and processing (SIC 2015). 2)

Consider a further revision to allow work involving the operation or feeding of meat and food

slicers in the retail, wholesale, and service industries. Operation of meat grinders; juice, oil, and

fat extractors; and other machines such as bone-cutting saws and meat patty-forming machines

should remain prohibited in retail, wholesale, and services industries. 3) Allow student

learner/apprenticeship exemptions for the use of meat grinders; juice, oil, and fat extractors; and

other machines listed under this HO in retail, wholesale, and service industries, but not for work

in meat products manufacturing industries. As defined in the current HO, the operation of these

machines would include setting up, adjusting, repairing, oiling, or cleaning [DOL 2001].

Although the suggested revisions would expand the HO to include additional industry sectors

which are not encompassed under the existing HO, such as poultry slaughtering and processing,

the suggested revisions would also result in some currently prohibited tasks being permitted for

youth. Specifically, the proposed revisions would allow youth to operate power-driven meat and

food slicers in wholesale, retail, and services industries. If such a revision were to be

implemented, it should be accompanied by a mandatory reporting period in which all serious
Hazardous Orders in Non-Agricultural Occupations

42

youth injuries and deaths resulting from previously prohibited activities are promptly reported

to the U.S. Department of Labor. This would allow an assessment as to whether the revision

should be rescinded or further refined to best protect working youth, while not unnecessarily

limiting job opportunities. 

Rationale— This is one of the more complex orders. It covers both meat products

manufacturing and the operation of meat processing machines in retail, wholesale, and service

industries. It applies to butcher shops, grocery stores, restaurants/fast-food establishments,

hotels, delicatessens, and meat-locker (freezer-locker) companies, and establishments where any

food product is prepared or processed for retail purchase. Sectors and recommendations are

described further below.

1) Although injury fatality rates in meat products manufacturing industries are relatively low,

rates of disorders due to repeated trauma are extremely high. This is true for poultry processing

which is not encompassed in existing HOs, as well as the manufacture of other meat products

which for the most part are covered. Repetitive motion disorders, which comprise a portion of

repeated trauma disorders, result in substantial days away from work across all industries. In

addition to the risk for repeated trauma disorders, there are a number of diverse and serious

health hazards associated with the slaughter and manufacture of meat products, including

exposure to infectious agents and respiratory hazards. Revising this HO to apply to specific

industries instead of occupations or tasks would greatly simplify compliance and enforcement of

the HO, and may be a more effective way of protecting youth. The current HO prohibits seven

specific types of work associated with meat slaughtering and processing, and may not be allinclusive of tasks and activities with serious injury and health risks in these industries. 

2) Although the title of HO 10 implies that it is limited to meat processing machines, this HO

actually includes all occupations involved in the operation, feeding, set-up, adjusting, repairing,

oiling, or cleaning of numerous power-driven food processing machines, regardless of the

product being processed (including, for example, the slicing in a retail delicatessen of meat,

poultry, seafood, bread, vegetables, or cheese). Machines covered include meat and bone cutting

saws, meat slicers, and grinders. Available data demonstrate that some types of food processing

machines, specifically grinders and juice, oil and fat extractors, are associated with serious

injuries, including amputations. Although data show high numbers of injuries associated with

power-driven slicers, the injuries appear to be relatively minor. This finding supports the

revision of the HO to allow operation of slicers in the retail, wholesale and services industries.

3) A student learner/apprenticeship exemption is not recommended for work in meat products

manufacturing industries because of the complexity of measures to prevent repeated trauma

disorders, and because these workplaces include diverse hazardous exposures frequently outside

the control of individual supervisors or workers. A student learner/apprenticeship exemption is

recommended for the use of meat processing machines in non-manufacturing settings. 

Compared with meat processing machines used in manufacturing, those used in settings such as

retail establishments are smaller, less complex machines. Hazards associated with these

machines are generally limited to the machines themselves, and may be reduced through worker
Hazardous Orders in Non-Agricultural Occupations

43

training and proper guarding and maintenance. Further, operation of meat processing machines

outside manufacturing settings is more likely to be an incidental work task; thus, exposure is

likely to be far lower than in a manufacturing facility, where machine operation may be the

primary work task.

Occupational Injury and Illness Statistics for the Meat Products Manufacturing Industries

Between 1992 and 1997, CFOI identified 129 occupational fatalities among workers of all ages

in the manufacture of meat products (which includes meat packing plants; sausages and other

prepared meats; and poultry slaughtering and processing); none of the fatalities were to youth

under the age of 18 [NIOSH 2001c]. The fatality rate was 4.8 deaths per 100,000 workers, about

the average for all industries [NIOSH 2001c; NIOSH 2001a]. Vehicles were the primary source

of fatality (38%), followed by other sources (which include fire, environmental extremes, and

bullets)(16%), machinery (13%), and parts and materials (12%).

In 1997, there were an estimated 13,646 occupational injuries and illnesses resulting in days

away from work among employees in the meat products manufacturing industry [BLS 1999b]. 

The greatest number of these injuries and illnesses occurred in meat packing plants (5,526),

followed by establishments that produce sausages and other prepared meats (4,147), and poultry

slaughtering and processing plants (3,973). For the entire meat products manufacturing industry,

the rate of injuries and illnesses resulting in days away from work was 2.8 per 100 FTE,

compared with 2.1 for all private industry workers. Within specific meat products

manufacturing sectors, workers in sausage and prepared meats plants had the highest rate per

100 FTE, 4.4, compared with 3.6 for meat packing plants and 1.6 for poultry processing plants. 

The median of 5 days away from work due to injuries or illnesses for all workers in meat

products manufacturing was identical to that for workers in all of private industry.

Work in Meat Products Manufacturing Industries is Associated with Significant Risk for

Disorders Associated with Repeated Trauma

Repeated trauma, as defined by BLS, includes disorders resulting from repetitive motion (e.g.,

carpal tunnel syndrome), exposure to noise, and rubbing and abrading as a result of friction or

pressure [BLS 1999b]. Workers in meat products manufacturing (SIC 201) have a very high

incidence rate of disorders associated with repeated trauma, with a rate of 686 cases per 10,000

full-time workers in 1997 [BLS 1999b]. The rate for meat packing plants specifically was 1,192,

while the rate for poultry slaughtering and processing (not currently covered by the HO) was

523. The rate for the manufacture of sausages and other prepared meats was 275, lower than the

other types of meat processing industries, but still relatively high. The incidence rates for meat

packing plants and poultry processing were well above the threshold of 320 used by NIOSH to

define industries where workers face high risk of workplace musculoskeletal disorders [NIOSH

1997b, pages 1-5]. 

In 1997, an estimated 1,869 workers in the meat products manufacturing industry suffered
Hazardous Orders in Non-Agricultural Occupations

44

repetitive motion disorders requiring days away from work. These disorders accounted for

13.7% of all days-away-from-work occupational injuries and illnesses in the industry, compared

with 4.1% in all industries [BLS 2000]. Across all industries, disorders associated with

repetitive motion were associated with a median 17 days away from work in 1997 [BLS 1999b]. 

Information on median days away from work due to repetitive motion disorders was not

available for the meat products manufacturing industry specifically. 

Although little is known about adverse effects of repeated trauma on adolescent workers

specifically, research addressing young athletes suggests that adolescents may be susceptible to

growth-related muscle, bone, or tendon injuries [Micheli and Fehlandt 1992]. Premature closure

of bone growth plates has been observed in young pianists and gymnasts [Attkiss and Buncke

1998; De Smet et al. 1993]. The relationship between child and adolescent occupational

exposure to biomechanical factors and the development of musculoskeletal disorders has been

identified in the National Occupational Research Agenda for Musculoskeletal Disorders as a

research priority [NIOSH 2001g].

Work in Meat Products Manufacturing Industries is Associated with Other Adverse Health

Effects

Work in the manufacture of meat products exposes workers to health hazards such as infectious

agents, airborne organic dust, bacterial endotoxins, and hazardous chemicals. Meat handlers,

more than most other occupational groups, are at risk for traumatic hand lesions and wound

infections [Finkel 1985]. This puts workers at risk for contracting zoonotic infections (infections

which occur in both animals and humans) as a result of handling infected animals or their

infected secretions or tissues [Cohen 1990; NIOSH 1993a]. Some of these infectious agents

such as bovine leukemia virus and bovine papilloma viruses, are carcinogenic in cows, and avian

leukosis sarcoma viruses, reticuloendotheliosis viruses, and Marek’s virus, are carcinogenic in

poultry. It is not known if exposure to these viruses is also associated with carcinogenesis in

humans, but increased rates of cancer have been described in meat processing/slaughtering

industries [Boffetta et al. 2000; Campbell 1999; Johnson and Griswold 1996; Johnson et al.

1995]. Bacterial endotoxins, which are found in organic dusts, are compounds present on the

cell wall of certain bacteria. Ongoing exposure to endotoxins is associated with respiratory

diseases and syndromes, including hypersensitivity pneumonitis, organic dust toxic syndrome,

chronic bronchitis, mucous membrane inflammation syndrome, and asthma-like syndrome

[Kirkhorn and Garry 2000; NIOSH 1992a]. Hazardous chemicals are also present in meat

processing settings [NIOSH 1994b]. Use of chlorine and sanitation chemicals in improperly

ventilated areas may cause irritation to mucous membranes of the eye, nose, and respiratory

tract. Chronic exposure to chlorine may cause chronic obstructive or restrictive lung disease and

anosmia (loss of the sense of smell) [Becker 1990].

Deaths and Injuries Associated with Meat Processing and Packing Machinery

It is difficult to identify the numbers of deaths and injuries specifically associated with meat

processing and packing machines because of the way occupational injury and illness data are
Hazardous Orders in Non-Agricultural Occupations

45

classified by the OIICS coding system. Machines and equipment used in the processing and

packaging of meat products are classified within the OIICS hierarchical coding scheme as

special process machinery (OIICS code 37). This category includes subgroups of food and

beverage processing machinery (OIICS code 371) and packaging, bottling, and wrapping

machinery (OIICS code 373) used for food as well as other products. Meat grinders are the only

machines specific to meat processing identified by a separate code (OIICS code 3713). Other

codes encompass machines or equipment such as food slicers that could process meat as well as

other foods, including fruits and vegetables. Coding guidelines on how bone-cutting saws

should be classified – within food and beverage processing machinery (OIICS code 371) or

within sawing machinery (OIICS code 357) – are not clear. 

Fatal Injuries Due to Food Processing Machinery and Packing Machinery

For the 6 year period 1992 through 1997, there were 46 deaths associated with food processing

machinery and packing machinery (OIICS codes 371 and 373), none involving youth less than

18 years of age (Table 14) [NIOSH 2001c; NIOSH 2001d]. Thirty-three of the 46 deaths (72%)

occurred within the manufacturing industry division. Of the 33 manufacturing deaths, eight

were classified in meat products manufacturing, and 19 in other types of food and beverage

manufacturing. Workers in the wholesale, retail, and services industries comprised the 13

remaining deaths, the majority of which did not appear to be associated with machinery used to

process or pack foods. 

The 46 worker deaths due to food processing machinery and packing machinery were associated

with a variety of machines. Workers being caught in meat grinders accounted for five deaths. 

Deaths associated with other specific types of food processing machinery and packing

machinery, including food slicers, were too small in number to meet BLS reporting

requirements. 

Nonfatal Injuries and Illnesses Due to Food Processing Machinery and Packing Machinery

Nonfatal injuries and illnesses associated with food slicers were frequent (7,280) [BLS 1999b]

although rates are not available given the lack of information on the numbers of food slicers in

use nationwide. Eighty-six percent of food slicer injuries occurred in retail trades [BLS 1999b]. 

Injuries from slicers appeared to be relatively minor based on a median of 4 days away from

work [BLS 1999b]. 

Injuries and illnesses associated with meat grinders were less common (315), but appeared to be

relatively severe based on days away from work. Median days away from work in 1997 were 18
Hazardous Orders in Non-Agricultural Occupations

46

In 2000, a 15-year-old youth employed by a

grocery store had the lower half of his arm

severed by a meat grinding machine. The

youth’s job was to clean up in the meat

department, including washing parts of the

meat grinder. The youth was instructed to

wash and reassemble the meat grinder. The

youth reached into the funnel with his right

hand to guide the auger screw, and

inadvertently activated the “on” switch with

another part of his body. The youth’s arm

was pulled into the grinder, and severed

several inches above the elbow. [NIOSH

2000d].

for meat grinders [BLS 1999b] (Table 14).

Sixty-seven percent of meat grinder

injuries occurred in retail trades, with 26%

occurring in manufacturing industries. 

The types of injuries and illnesses

associated with meat grinders were further

examined using multiple years of SOII

data available on CD-ROM [BLS 2000]. 

From 1994-1999, there were an estimated

1,956 nonfatal injuries requiring days

away from work involving meat grinders,

requiring an annual average of 11 median

days away from work. Amputations

accounted for 15% of these injuries (288)

[BLS 2000]. NIOSH is recommending

that the use of meat grinders continue to be

prohibited for youth in the retail, wholesale, and services industries based on the severity and

nature of injury, and evidence that these machines result in injury in industries other than

manufacturing. An apprentice/student learner exemption is recommended because supervision

and training by a qualified and experienced person could reasonably minimize the risks to youth,

while providing valuable job skills training. Apprentice/student learner exemptions have

stringent requirements for training and ongoing close supervision by a qualified and experienced

person.

Juice, oil, and fat extractors were also associated with severe injuries and illnesses, with a

median of 22 days away from work (Table 14) [BLS 1999b]. Forty-one percent of injuries from

juice, oil, and fat extractors occurred in services industries [BLS 1999b]. It is not possible to

separate the number of injuries associated with machines that extract fat from meats from those

associated with machines that extract juices or oils from fruits and vegetables. This is not

critical for justifying the recommendation to prohibit the use of oil, juice, and fat extractors by

youth: other portions of HO 10 prohibit the use of specific powered processing machines

regardless of the food being processed. 

Table 14. Fatal Injuries and Nonfatal Injuries and Illnesses Requiring Days Away from Work

Associated with Food Processing and Packing Machinery, United States
Hazardous Orders in Non-Agricultural Occupations

47

Machinery [OIICS code] 1

N

 or 2N

Source of

Death,

1992-1997

Nonfatal

Injuries and

Illnesses, 1N

Source,

1997

Median

Days Away

from

Work, 1997

Food and beverage processing machinery–

specialized, unspecified [3710]

5 308 5

Food slicers [3711] --- 7,280 4

Juice, oil, fat extractors [3712] --- 130 22

Meat grinders [3713] 5 315 18

Mixers, blenders, whippers– food and beverage

[3714]

8 712 11

Food and beverage processing machinery–

specialized and n.e.c. [3719]

9 771 6

Packaging, bottling, wrapping machinery,

unspecified [3730]

--- 292 5

Bottling, canning, filling machinery [3731] --- 199 5

Packaging, wrapping, bundling machinery

[3732]

10 728 5

Product labeling machinery [3733] --- 133 3

Sealing, stapling machinery [3734] --- 397 14

Packaging, bottling, wrapping machinery,

n.e.c. [3739]

5 472 3

Total 46 11,737 ---

Source: Census of Fatal Occupational Injuries (Fatalities) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Injuries), Bureau of Labor Statistics [BLS 1999b]. Dashes indicate that BLS reporting requirements were

not met. 

In summary, the recommendation to prohibit all work by youth in the meat products

manufacturing industry sector under HO 10 is strongly supported by the available information. 

Evaluation of the risks associated with specific machines covered by HO 10 is limited by a lack

of injury and fatality data on certain machines, including bone cutting saws and meat patty

forming machines. Evaluation of HO 10 is further limited by the inability to calculate injury and

fatality rates for any of the machines addressed by this HO.
Hazardous Orders in Non-Agricultural Occupations

48

The information available does indicate that grinders and extractors can cause severe injuries,

which supports the case for continued restrictions. The data for operation of meat and food

slicers do not indicate risks for fatalities or severe injuries, and thus a case can be made that

operation of these types of machines in retail, wholesale, and service industries could be

allowed. However, there are a number of reasons to be cautious in proposing this change: data

sources do not clearly identify specific food processing and packing machinery involved in

fatalities and injuries; injuries from slicers are common; and large numbers of youth are

employed in the sectors where these types of machines are used. NIOSH recommends that

further evaluation be directed to HO 10 to provide additional consideration of these issues. The

implementation of any revision should be accompanied by a mandatory reporting period in

which all serious youth injuries and deaths resulting from previously prohibited activities are

promptly reported to the U.S. Department of Labor. This would allow additional assessment as

to whether the prohibitions should be reinstated or further refined to best protect working youth,

while not unnecessarily limiting job opportunities.

HO 11: Power-Driven Bakery Machine Occupations

Recommendation – Consider revising to allow for the operation of “counter-top models” of

power-driven bakery machines, comparable to those intended for household use. If such a

revision were to be implemented, it should be followed by a mandatory reporting period in which

all serious youth injuries and deaths resulting from previously prohibited activities are promptly

reported to the U.S. Department of Labor. This would allow an assessment as to whether the

revision should be rescinded or further refined to best protect working youth, while not

unnecessarily limiting job opportunities.

Rationale– Available data suggest that fatal events involving power-driven machines are

infrequent, and nonfatal injuries requiring time away from work are of moderate severity. 

Fatality data identified a small number of fatalities among workers of all ages due to commercial

grade bakery machines. None involved counter top models such as those commonly used in the

home.

Occupational Injury and Illness Statistics for Food Processing and Packing Machinery

This HO prohibits use of several types of bakery machines, including: horizontal or vertical

dough mixers; batter mixers; bread dividing, rounding, and molding machines; dough brakes;

dough sheeters; combination bread slicing and wrapping machines; cake cutting band saws; and

cookie or cracker machines. There are a number of power-driven bakery machines which are

exempted from the HO, including machinery involved in ingredient preparation and mixing,

product forming and shaping, finishing and icing, slicing and wrapping, and pan washing. Most

of the machines discussed in HO 11, both permitted and prohibited, would be classified as food

processing and packing machinery in the OIICS coding system, source codes 371 (food and

beverage processing machinery) and 373 (packaging, bottling, and wrapping machinery),
Hazardous Orders in Non-Agricultural Occupations

49

In 2001, a 16-year-old worker died while

cleaning a dough mixer in a pizzeria. The

youth was cleaning the machine when he

became entangled in the beaters and was

pulled into the machine. The youth was

working alone at the time, and it is unclear

how he became entangled in the machine

[Associated Press 2001].

respectively. However, OIICS codes 371 and 373 also encompass many machines not addressed

by HO 11 (e.g., meat grinders).

A review of CFOI data for 1992 through

1997 provided information on 10 fatalities to

workers of all ages involving power-driven

bakery machines prohibited by HO 11. The

majority of the cases (80%) involved large

commercial mixers. No fatalities were

reported that involved counter top bakery

machines. Work with mixers, blenders, and

whippers (OIICS source code 3714) was

associated with 712 non-fatal injuries and

illnesses in 1997, with a median of 11 days away from work [BLS 1999b]. 

As with HO 10, it may be prudent to perform some additional evaluation given the lack of

specificity in the available data. Implementation of any revision should be accompanied by a

mandatory reporting period in which all serious youth injuries and deaths resulting from

operation of powered bakery machines are promptly reported to the U.S. Department of Labor. 

This would allow additional assessment as to whether the prohibitions should be reinstated or

further refined to best protect working youth.
Hazardous Orders in Non-Agricultural Occupations

50

In 2000, a 16-year-old worker in a produce

market died from crushing injuries when he

was caught in the vertical downstroke baler he

was operating. The youth, working alone in

the basement of the produce market, was using

the baler to crush cardboard boxes when he

was caught by the machine’s hydraulic ram. 

After the incident, it was determined that the

machine’s safety interlock had been bypassed,

allowing the machine to operate with the

loading door in the open position. The youth

may have reached into the baling chamber

while the machine was operating, and was

caught by the ram as it cycled [NIOSH 2001i].

HO 12: Power-Driven Paper-Products Machine Occupations

Recommendation — 1) Retain the current HO and incorporate the requirements of the

Compactor and Baler Act (Public Law 104-174, August 6, 1996). 2) Expand the HO to include

machines such as balers and compactors used to process other materials such as aluminum cans,

plastic, foam, and rubber. 3) Continue to emphasize enforcement of portions of the Compactor

and Baler Act requiring balers to conform to construction and operational standards that greatly

reduce exposure to hazardous energy. 4) Retain the apprenticeship/student learner exemption

currently allowed under this HO. These recommendations are consistent with the 1999 NPRM

published by DOL and with previous NIOSH comments in support of the proposed rule [64 Fed.

Reg. 67130 (1999); NIOSH 2000a].

Rationale — 1) Power-driven paper products machines are associated with a substantial number

of worker deaths and injuries. 2) Balers and compactors used to process other scrap materials

such as plastic and aluminum cans pose similar risk of injury from crushing or amputation, and

are identified in injury and fatality data. 3) Investigations of baler-related incidents show that

failure to maintain machinery in safe operating condition contributes to fatalities and serious

injuries, and that neither adult supervisors nor young workers may fully appreciate the risks

posed by uncontrolled hazardous energy. 4) An apprentice/student learner exemption is still

appropriate as long as training of young workers to recognize injury hazards is accompanied by

careful monitoring by adult supervisors and regular inspection and maintenance of balers. 

Substantial Numbers of Deaths and Injuries Are Associated with Paper Balers and Compactors

The OIICS system does not include a source code that can be used to identify deaths and injuries

associated with balers and compactors. Cases were identified in the CFOI system by searching

narrative fields for mention of balers and

compactors, then manually reviewing

identified cases. The number of cases

identified by CFOI using this method

should be considered a minimum number

of cases. Narrative fields in CFOI

frequently do not specify the kind of

machine involved. Thus, an unknown

number of fatalities associated with balers

and compactors are not identified. 

A review of cases from CFOI for 1992-

1997 provided information on 29 fatalities

involving balers or compactors [NIOSH

2001c]. The majority of the cases (59%)

involved crushing injuries. Nine deaths

(31%) were in the scrap and waste
Hazardous Orders in Non-Agricultural Occupations

51

materials industry (SIC 5093), which includes recycling facilities. Eight other fatalities (28%)

occurred in a wide range of manufacturing settings. Paper or cardboard balers were specified in

11 of the 29 cases (38%). Other fatalities involved machinery for baling or compacting scrap

metal, trash, cans, plastic wrap, and cotton.

In eight of the CFOI cases, the decedent was trying to clear a jam in the machine when the

fatality occurred [NIOSH 2001c]. Other fatalities occurred when a co-worker, not knowing

someone was in the machine, turned it on, or were due to the machine automatically activating

once the jam was cleared. Overall, in almost half of the cases (48%), the machine was either

already on, or a co-worker unknowingly activated the machine to cause the fatality. In 17% of

the cases the fatality occurred when the decedent fell into the machine. 

Substantial numbers of non-fatal baler-related injuries have also been reported. More than three

years (Oct. 1, 1996 - Dec. 31, 1999) of data from the National Electronic Injury Surveillance

System (NEISS), which provides surveillance of non-fatal occupational injuries presenting to

hospital emergency departments, were examined. Again, text searches of narrative fields were

used to identify cases. Thus, these estimates of emergency department treated injuries should be

considered a minimum number of cases. Paper balers and box compactors accounted for an

estimated 2,625 injury reports nationwide. Of these injuries 32% resulted in a crush/contusion,

29% lacerations, 25% sprain/strains, and 14% other injuries including fractures and dislocations. 

Almost half of the injuries occurred in either a retail or grocery store, with 24% occurring in

manufacturing [NIOSH 2001b].

Investigations of Baler-Related Fatalities Identify Injury Risk Factors

Between 1993 and 2000, NIOSH investigated 11 baler-related incidents that resulted in 10

fatalities and one case of a double amputation [California Department of Health Services 1995;

Colorado Department of Health 1994a; Massachusetts Department of Health 1996; New Jersey

Department of Health and Senior Services 1993, 1995, 1996; NIOSH 1996a; NIOSH 1997c;

NIOSH 1997d; Texas Workers’ Compensation Commission 1998]. The materials being

processed were paper, cardboard, newspaper, trash, and plastic milk jugs. These investigations

identified the presence of risk factors influencing the likelihood of injury for workers operating,

loading, servicing, and maintaining balers and compactors. In 10 of the cases, uncontrolled

hazardous energy and absence of an effective training program contributed to the risk of injury

or death. In five cases, machine safeguards were absent and in three cases, there was insufficient

supervision/observation of the employee. 

The investigations also found that the balers and compactors were routinely used to process

other scrap materials, such as plastic and aluminum cans. The machines involved in seven of the

cases were known to be prone to material jams. In five of the incidents, the victim was injured

after entering or falling into the operating machine during attempts to clear jammed material. 

Three of the incidents were unwitnessed, but evidence strongly suggests that a jam had occurred

prior to the victim entering the machine. The victim was located in an unsafe loading position in
Hazardous Orders in Non-Agricultural Occupations

52

In 1996, a 17-year-old youth employed at a recycling center

suffered amputation of both legs after he fell inside a

horizontal hydraulic baler. The victim and three co-workers

had been loading cardboard into the baler via an inclined

conveyor belt when the cardboard jammed in the baler’s feed

chute. The victim shut down the conveyor and climbed the

belt to the feed chute opening, clearing the jam by holding

onto the top cover of the baler feed chute and pushing with

his feet. When the jam cleared, he fell through the feed

chute into the baling chamber. Before he could climb out,

the ram automatically activated, cycled into the baling

chamber, and amputated his legs near the knees [NIOSH

1997c].

one of the incidents. In

another incident, the victim

was injured while

attempting to retrieve

material which had been

mistakenly loaded into the

compactor. Investigators

were unable to determine the

manner and reason for the

victim’s entry into the baler

during the remaining

incident.

Machines Used to Bale and

Compact Paper Products Are

Also Used to Compact Other

Materials

Fatality data from surveillance systems and from field investigations show that baler and

compactor-related deaths are not limited to those in which paper or cardboard is being processed. 

Many machines are adaptable for baling and compacting a wide variety of materials – paper,

aluminum cans, plastic milk jugs, and general household refuse. Others are intended specifically

for processing a single product, usually metals. These specialized metal balers and compactors,

which handle items such as cars, radiators, and siding, often feature shear blades that may not be

present on lighter-duty balers. While these and other large stationary balers are generally found

in facilities that specialize in processing scrap and waste materials, smaller general-purpose

portable machines are marketed for use in businesses such as grocery stores, hotels, restaurants,

and hospitals. Smaller balers found in these and other retail and services establishments operate

in essentially the same way as larger balers, and present similar risks of injury.

Other Power-Driven Paper Products Machines Are Also Linked to Deaths and Injuries 

Employees who work on or around paper production machinery risk being caught in running

machinery, being struck by falling paper rolls, falling from machinery, and being electrocuted.

Paper production machinery (OIICS code 374) was involved in 26 fatalities between 1992 and

1997 among workers of all ages [NIOSH 2001c], and 867 nonfatal injuries and illnesses in 1997

[BLS 1999b] (Table 15). OIICS code 374 includes subcategories for some of the machines

either explicitly included or excluded under HO 12 (calenders, coaters, dryers, formers, slitters,

winders, washers, bleachers, and refiners) but does not allow for identification of other machines

also specified in HO 12. Further, case narratives often do not specify machinery involved to the

same level of detail found on the lists of inclusions and exclusions under this Hazardous Order. 

However, there are several types that can be identified. Most prominent are paper winders and

rewinders, which are now specifically excluded from HO 12, with eight fatalities. The other

paper production machines associated with fatalities were coating machines (now excluded from
Hazardous Orders in Non-Agricultural Occupations

53

the HO); pulpers, repulpers, and paper dryers (neither included nor excluded); and corrugators

(included and therefore now prohibited for youth). 

Table 15. Deaths and Nonfatal Injuries and Illnesses Requiring Days Away from Work

Associated with Paper Production Machinery, United States

Machinery [OIICS

code]

1

N

 or 2N Source of

Death, 1992-1997

Nonfatal

Injuries and

Illnesses

(1o source),

1997

Median Days

Away from

Work, 1997

Paper production

machinery, unspecified

[3740]

8 229 5

Slitters, winders – paper

production [3745]

8 332 7

Paper production 

machinery, n.e.c. [3749]

— 257 6

Other specified paper

production machinery

[3741, 3742, 3743,

3744, 3746]

6 49 —

Total 26 867 6

Source: Census of Fatal Occupational Injuries (Deaths) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Nonfatal injuries), Bureau of Labor Statistics [BLS 1999b]. Dash indicates that no data were available.

Current Injury Data Preclude Assessment of Risk Associated with All Machines Covered Under

This HO

As discussed above, it is difficult to identify deaths and injuries associated with paper balers and

compactors as the OIICS provides no source code that allows identification of these machines. 

Balers and compactors are now subsumed under the “Other machinery” category which includes

all machines not covered by other OIICS codes, and can only be identified through text word

searches of case narratives, which frequently do not specify the kind of machine involved. 

NIOSH will recommend to the Bureau of Labor Statistics that separate codes that distinguish

between horizontal balers and vertical upstroke or downstroke balers be established. Horizontal

balers with conveyors are most often used in large recycling centers or manufacturing facilities,

while vertical balers are used in retail establishments at which youth are frequently employed. 

A similar problem exists for other types of machines covered under this HO. Although there is a
Hazardous Orders in Non-Agricultural Occupations

54

separate OIICS source code for paper production machinery, there is not sufficient detail in the

existing coding structure to determine if all current prohibitions under this HO are justified, or if

specific machines now excluded from the HO ought to be prohibited. Paper rewinders, excluded

from this HO but for which there is a separate OIICS code, were associated with nine fatalities

between 1992 and 1997 [NIOSH 2001c]. There is no mechanism for tracking fatalities due to

other machines now excluded from the HO, such as creping, parchmentizing, and bundling

machines. NIOSH will recommend to the Bureau of Labor Statistics that OIICS codes for paper

production machinery be modified to cover additional machines specified in HO 12. 

Additional Training is Needed for Effective Injury Prevention

The Compactor and Baler Act (PL 104-174; August 6, 1996) specifies conditions under which

youth can load certain types of balers. These conditions include compliance with the voluntary

American National Standards Institute (ANSI) standard for compactors and balers, which

includes training provisions [ANSI 1997a; ANSI 1997b]. While the ANSI standards stipulate

training requirements for workers assigned to operate, maintain, and service balers and

compactors, NIOSH investigations indicate that additional training is needed for effective injury

prevention. For those workers assigned to load only, but not operate, service, or maintain the

machines, the training should address safe loading procedures, the recognition of operational

hazards and the hazards associated with entering energized machines. NIOSH investigations

further indicate that the employer’s supervisory and lead personnel should be trained to

recognize the need for increased observation of youthful workers, and to understand the

prohibitions against minors operating and servicing balers and compactors.

HO 13: Occupations Involved in the Manufacture of Brick, Tile, and Kindred Products

Recommendation— Retain the current HO

Rationale— Work in occupations involved in the production of clay construction products,

including brick, tile, and other clay products, and silica brick or other silica refractories

continues to be hazardous to workers of all ages. Although injury fatality rates are

comparatively low, occupational exposure to respirable crystalline silica in this industry is

strongly associated with chronic, debilitating, and sometimes fatal lung disease. Further, inhaled

crystalline silica from occupational sources has been classified as carcinogenic to humans by the

International Agency for Research on Cancer [IARC 1997].

Fatal Injuries and Nonfatal Injuries and Illnesses Associated with the Manufacturing of Brick,

Tile, and Kindred Products

During the 6-year period 1992-1997, CFOI identified 15 deaths associated with the

manufacturing of structural clay products (SIC code 325), and a rate of 6.8 deaths per 100,000

workers [NIOSH 2001c; NIOSH 2001a]. During 1997, there were 1,340 injuries and illnesses

resulting in days away from work, with a median of 6 days away per injury [BLS 1999b]. 
Hazardous Orders in Non-Agricultural Occupations

55

In a cluster of 4 cases of acute silicosis in

sandblasters in a single tombstone factory, a

23-year-old black male smoker, with

exposure to crystalline silica for a period of

2.5 years, died with silicosis confirmed by

lung biopsy, and complications of

tuberculosis and renal failure [Suratt et al.

1977]. This case demonstrates that although

silicosis usually occurs in older workers after

many years of exposure, young workers are

also at risk after relatively brief periods of

exposure to respirable silica dust.

Workers May Be Exposed to Silica Dust which Is Associated with Decreased Lung Function and

Silicosis

Workers in the brick- and tile-manufacturing

industries are exposed to varying amounts of

free silica dust. Exposure to respirable

crystalline silica dust in these industries is

associated with the development of silicosis,

lung cancer, pulmonary tuberculosis, and 

airway diseases such as chronic obstructive

pulmonary disease and bronchitis [NIOSH

2001j; Zuskin et al. 1998; Liou et al. 1996;

Burge et al. 1995; Myers and Cornell 1989]. 

Silicosis is a irreversible, sometimes fatal

interstitial lung disease caused by the

pulmonary response to inhaled crystalline

silica [Wagner 1997]. Severity of disease is

related to exposure level, duration of

exposure, and cigarette smoking [Zuskin et

al. 1998; Liou et al. 1996; Myers 1989]. 

Acute silicosis occurs following exposure to very high concentrations of silica dust, within 2

weeks or up to 5 years. Accelerated silicosis occurs after 5 to 10 years of continued exposure,

and chronic silicosis, the most common form of the disease, occurs with insidious onset after at

least 10 years of overexposure. Chronic silicosis increases the risk of mycobacterial

(tuberculous or non-tuberculous) infections [Elmes 1994]. An analysis of national mortality data

from the U.S. National Center for Health Statistics [Althouse et al. 1995] demonstrated that

tuberculosis is about 20 times more likely to be listed as a cause of death in decedents with

silicosis compared to decedents without silicosis. Evidence has also associated exposure to high

levels of crystalline silica with increased rates of autoimmune diseases, including scleroderma,

rheumatoid arthritis, and systemic lupus erythematosus [Parks et al. 1999].

Inhaled Crystalline Silica Is Carcinogenic to Humans

In 1997, the International Agency for Research on Cancer concluded that there is a causal

relationship between exposure to crystalline silica and human cancer and classified crystalline

silica as a Class 1 carcinogen [IARC 1997]. The increased risk for lung cancer has been shown

primarily in workers who have developed silicosis [Finkelstein 1998; Hnizdo et al. 1997;

Amandus et al. 1995]. 
Hazardous Orders in Non-Agricultural Occupations

56

HO 14: Occupations in the Operation of Power-Driven Circular Saws, Band Saws, and

Guillotine Shears

Recommendation – 1) Revise definition of machinery covered by this HO to include other

machines, such as chainsaws, which perform cutting and sawing functions through direct contact

between the cutting surfaces and the material (the current definition is based on the presence of a

continuous series of notches or jagged teeth). Alternatively, NIOSH encourages DOL to

consider developing a new HO that combines the sawing machinery covered under this HO with

other specialized machinery that performs cutting and sawing functions through direct contact

of the cutting surface and the material. 2) Retain the exemption for apprentices/student learners,

except in the case of chainsaws and other hand-held power saws.

Rationale – 1) Stationary saws and hand-held power saws, including chainsaws, continue to be

the source of substantial numbers of fatalities as well as nonfatal injuries, which may be

unusually severe. The HO bases the definition of prohibited machines on the presence of a

continuous series of notches or jagged teeth. Not all machinery that perform cutting or trimming

functions have visible notches or teeth, e.g. chainsaws or abrasive cutting discs which perform

the same function. 2) For stationary saws and shearing machines, an apprentice/student learner

exemption is warranted given that means of controlling hazardous energy associated with these

machines are well-understood, and that the hazards are generally confined to the machine itself. 

In contrast, hand-held power saws, including chainsaws, are used in less controlled conditions,

often in construction and logging operations. Injury risk factors associated with hand-held

power saws are more diverse, and more difficult to recognize and eliminate.

Worker Deaths and Injuries Are Associated with Power-Driven Stationary and Hand-Held Saws,

and Shearing Machines

The Census of Fatal Occupational Injuries (CFOI) for 1992-1997 identified a total of 151 deaths

associated with stationary sawing machinery, chainsaws, powered hand-held saws other than

chainsaws, and shearing machines of all types (Table 16) [NIOSH 2001c]. For all these

machines combined, the highest numbers of fatalities occurred in the manufacturing industry

(which includes logging and sawmills) (84 deaths), followed by the construction industry (31

deaths). 

The primary hazards associated with the 46 fatalities related to stationary saws were being

caught in running machinery (17 deaths), and being struck by flying objects (12 deaths) [NIOSH

2001c]. In this group, there were also fatalities resulting from electrocution and other types of

contact with objects. The 29 fatalities related to use of hand-held power saws were associated

with a wide variety of hazards. The single most common event was being struck by a swinging

or slipping object (9 deaths), with many of the case reports consistent with kickback or loss of

control of the hand-held power saw. However, use of these saws was also associated with

electrocution, being struck by falling trees, explosions, and carbon monoxide poisoning. Among

the 70 chainsaw-related fatalities, the primary fatal events were being struck by a tree (38
Hazardous Orders in Non-Agricultural Occupations

57

In 1995, a 17-year-old youth in New Mexico

was killed when he lost control of the

chainsaw he was operating. It was his first

day on the job [NIOSH 1995a].

deaths) and being struck by a swinging or slipping object (16 deaths). The majority of the latter

events involved kickback of the chainsaw. There were seven fatalities associated with shearing

machines, six classified into OIICS code 3152 (shearing machines), and a seventh identified

through a keyword search of the CFOI injury narrative. In five of the seven fatalities associated

with shearing machines, the worker was caught in running machinery.

In 1997, machines covered under this HO were the source of 10,484 nonfatal injuries and

illnesses requiring days away from work. Chainsaws, not currently covered under this HO,

contributed to another 1,627 injuries. Injuries and illnesses associated with hand-held power

saws appear to be particularly severe, with a median 13 days away from work [BLS 1999b].

Table 16. Deaths and Nonfatal Injuries and Illnesses Requiring Days Away from Work

Associated with Stationary Sawing Machinery, Powered Saws, and Shearing Machines, United

States

Machinery [OIICS code] 1

N

 or 2N

Source of

Death, 1992-

1997

Nonfatal

Injuries and

Illnesses

(1o Source),

1997

Median Days

Away from

Work, 1997

Sawing machinery –

stationary [357]

46 7,415 8

Chainsaws – powered [7221] 70 1,627 10

Hand-held saws – powered,

except chainsaws [7224]

29 2,762 13

Shearing machines [3512] 6 307 3

Total 151 12,111 ---

Source: Census of Fatal Occupational Injuries (Deaths) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Nonfatal injuries), Bureau of Labor Statistics [BLS 1999b]. The dash indicates that no data were

available. 

HO 14 May Now Exclude Similar Machinery that Poses Significant Injury Risk

The current HO bases the definitions of

circular saws and band saws on the

presence of continuous series of notches or

jagged teeth. Not all machinery that

performs cutting or trimming functions has

visible notches or teeth, e.g., chainsaws or
Hazardous Orders in Non-Agricultural Occupations

58

In 1996, a 16-year-old laborer was electrocuted while

salvaging conductors and electrical equipment from an

inactive oil field. The youth, working as a summer hire for

an electrical contractor, was coiling de-energized power lines

that had been released by the 25-year-old crew leader. When

one of the lines was cut, tension on the pole caused the deenergized line that the victim was holding to contact a nearby

energized, 7,200-volt power line, energizing the salvage

power line [NIOSH 1996b]

In 1998, a 17-year-old male laborer, who was

working on the dismantling of a section of

railroad tracks, died when a bulldozer on

which he had been riding overturned and fell

on top of him. The bulldozer, also driven by a

17-year-old, was being driven across a trestle,

partially on a catwalk that was not designed to

carry such a load [Minnesota Department of

Health 1998].

abrasive cutting discs which perform the same functions. Available data demonstrate that

chainsaws specifically contributed to 70 worker deaths between 1992 and 1997, and over 1,600

lost workday injuries. It is the potential for contact with the moving disc or band, rather than

notches or teeth alone, that creates the greatest injury risk from this group of sawing and cutting

machines. CFOI data that show the predominance of caught-in-running-machinery incidents

support this argument. Thus, the definition of “saw” under this HO may exclude certain

machines similar to circular and band saws that present injury risks from unguarded cutting

surfaces, despite the absence of visible notches or teeth.

HO 15: Occupations Involved in Wrecking, Demolition, and Shipbreaking Operations

Recommendation— Retain the current HO.

Rationale— The wrecking, demolition, and shipbreaking industries are associated with large

numbers of fatal and severe nonfatal injuries. Wrecking, demolition, and shipbreaking also

expose workers to potentially lethal and carcinogenic substances, including asbestos, lead,

polychlorinated biphenyls (PCBs), as well as other toxic substances.

Wrecking, Demolition, and

Shipbreaking Operations

Are Associated with Fatal

and Nonfatal Injuries

During the 6-year period

1992-1997, 129 deaths

were identified by CFOI in

wrecking and demolition

industries. Of these, 109

were identified as

occurring in establishments coded as SIC 1795 (“Wrecking and Demolition Work”), and an

additional 20 were identified by a

keyword search (“wreck” or “demoli”) of

narrative information. Among the 109

fatalities to employees of demolition

contractors (SIC 1795 only), 56% were

employed as laborers. The primary work

tasks associated with these deaths were

construction, repair, or cleaning (58%). 

The predominant events leading to

fatalities were being struck by a falling

object (22%), being caught in or crushed

by a collapsing structure (20%), and

falling from a roof (11%) [NIOSH
Hazardous Orders in Non-Agricultural Occupations

59

In 1989, a 15-year-old laborer was working

alone in the basement of an abandoned 3-

story building and was trapped for 2 hours

when the structure collapsed. He had been

salvaging bricks from a column that was

supporting the building. He was rescued by

emergency personnel and suffered minor

injuries [NIOSH 1995b]. 

2001c]. Fatal injury rates could not be calculated because employment data were not available. 

Shipbreaking, meaning any kind of breaking down of a ship for the purpose of salvaging and

selling its scrap-metal and other components, is classified within SIC 4499, “Water

Transportation Services, Not Elsewhere Classified.” This group also includes industries such as

boat rental, boat chartering, and piloting. Narratives for all fatalities in this group were

examined, and no fatalities involving shipbreaking were identified. 

Englund and Cohn [1997], investigative reporters with the Baltimore Sun Newspaper,

documented fatal and severe non-fatal injuries in shipbreaking operations in the U.S., in a

Pulitzer Prize-winning series of articles about the industry. Extremely hazardous working

conditions were described in shipbreaking operations in Texas, Maryland, North Carolina,

California, and Rhode Island. Three workers died within 12 months of each other at two

shipbreaking operations, in Texas and North Carolina. A 43-year-old worker who was working

in total darkness without safety equipment, fell 30 feet into a tank and died 2 days later due to

his injuries. In the same yard, a 58-year-old

laborer was killed while walking across a

scrapyard when he was struck by a large

piece of bulkhead being cut by another

worker. An OSHA investigation in a North

Carolina scrapyard revealed that the death of

a worker, killed when he was struck by a

piece of metal thrown from a pipe-splitting

alligator shear, could have been prevented if

the alligator shear had the required safety

guards. The same North Carolina scrapyard

was cited by OSHA for safety violations after

a 28-year-old worker, who was cutting steel

pipes in the engine room of a destroyer, suffered severe burns, a fractured leg, and temporary

blindness in an explosion. A torch had ignited vapors which had accumulated in the room. 

Other instances of safety violations were also described.

Workers in These Industries May Be Exposed to Asbestos, Lead, Polychlorinated Biphenyls

(PCBs), and Other Toxic Substances which Cause Severe Illness and Cancer.

Many older structures and ships which are demolished contain asbestos in insulation, lead in

paint, and polychlorinated biphenyls, which were used extensively in the past for electrical

insulation, air system gaskets, and fluorescent light fixtures. Other toxic substances may also be

present [Klitzman et al. 1994; Balco and McKenna 1994; Jaques 1994; Pigg 1994; Oliver 1994;

IARC 1977, pp. 29-32]. Englund and Cohn [1997] described cases of improper handling of

toxic substances in ship-scrapping yards. They found OSHA records revealing that in a yard in

California, workers were told to lie to investigators about the mishandling of asbestos. A yard in

North Carolina was cited for not training workers to properly remove asbestos, not providing
Hazardous Orders in Non-Agricultural Occupations

60

protective suits, and not providing medical screening. In Rhode Island, a state agency

discovered unsafe practices in a scrapyard which had no fire watches, did not monitor for lead

and asbestos, and did not have an approved plan for PCB removal. A worker in Texas described

“burning cables,” the illegal practice of burning the PCB insulation off copper cables [Englund

and Cohn 1997].

Exposure to asbestos is associated with chronic, fibrotic, interstitial lung disease, as well as

malignant mesothelioma, lung cancer, and cancers of the larynx and gastrointestinal tract

[Wagner 1997; IARC 1987, p. 108]. The risk of lung cancer after exposure to asbestos rises

multiplicatively in the presence of smoking [IARC 1977, p. 69]. 

Lead poisoning in demolition workers can result from inhalation or ingestion of inorganic lead

during abrasive blasting, welding, cutting, and torch burning of surfaces coated with lead-based

paint, lead pipes and solder, and other lead building material. Acute, high-dose exposure may

cause anemia, abdominal colic, peripheral neuropathy, central neuropathy, nephropathy, and

sterility. Tremors, stupor, seizures, and coma may occur in severe poisoning in which blood

levels rapidly rise to over 100 mcg/dL. Lower-level, chronic, or recurrent exposure may lead to

non-specific symptoms and more subtle organ damage [Levin and Goldberg 2000]. 

PCBs were commonly used in a variety of industrial applications from the 1930's until the

1970's. Demolition workers and shipbreakers may be exposed to PCBs if they are working on

structures built during that time. PCBs were primarily used for their insulating, fire resistance,

and dielectric properties in electrical transformers and capacitors, but can also be found in

lubricants, sealants, paint, plastics, newspaper print, and dyes, many of which laborers may come

into contact with in demolition operations. The Environmental Protection Agency (EPA) banned

their production in 1978 when the adverse health effects of PCBs were recognized (Public Law

94-469). A review of mortality studies of exposed workers reported higher than expected rates

of several types of cancer, including melanoma, and cancers of the liver, rectum, gastrointestinal

tract, brain, and hematopoietic system [Kimbrough et al. 1999]. PCBs are considered potentially

carcinogenic to humans by NIOSH [NIOSH 1986a], the EPA [EPA 1980], and IARC [IARC

1987]. 

HO 16: Occupations in Roofing Operations

Recommendation — 1) Expand current HO to include all work performed on roofs. The HO

should not be limited solely to roofing operations that involve construction, maintenance, and

repair of roofs. 2) Remove the exemption for apprentices/student learners. These

recommendations are consistent with the 1999 NPRM published by DOL and with previous

NIOSH comments in support of the proposed rule [64 Fed. Reg. 67130 (1999); NIOSH 2000a].

Rationale — 1) All work on roofs, including work unrelated to the construction, maintenance,

and repair of roofs, is associated with high numbers of work-related injury deaths and serious

injuries among adults and youth. Work on roofs presents fall hazards and frequently places
Hazardous Orders in Non-Agricultural Occupations

61

In 2000, a 16-year-old male construction

framing crew-member died after a 27-foot

fall from the roof of a building under

construction. The youth had been moving a

roof truss into place for installation,

supporting himself on an 8-inch-wide

structural beam. The youth fell into the

interior of the building and was fatally struck

on the head by one of the trusses that also fell

[NIOSH 2000d]. 

workers in close proximity to overhead power lines. 2) The diverse hazards of working on roofs

make an exemption for apprentices or student learners inappropriate. Close supervision and

training will not sufficiently reduce the risk of fatal injury. The high risk of fatal injury in the

roofing occupation among all workers also supports the removal of an exemption.

Hazards of Working on Roofs

Work on roofs is associated with falls from

heights and contact with electrical energy. 

Workers are exposed to serious injury and

death from falls that arise from:

C stepping or falling into roof openings

created for skylights

C stepping, falling, or sliding off the roof

edges after tripping or losing balance

C stepping on unsupportive roofing

materials, such as insulation or rotten

roofing

C placing weight on poorly secured structural members (e.g., rafters), or nonstructural roof

attachments (e.g., gutters)

C being knocked off balance by loads on cranes and material hoists

C falling through a skylight

C being blown over when handling sheets of plywood

C falling when a ladder slips or collapses

C falling due to failure or collapse of scaffolding

C stepping onto or off of a roof from either a ladder or a scaffold

Workers may sustain serious burn injuries and electrocution from inadvertent contact with

electrical wiring or with electrical power transmission lines. Contact may either be direct, where

the employee actually touches an uninsulated power line, or indirect, where the employee is

holding a conductive object (e.g., an aluminum gutter, ladder, or antenna) and the object contacts

the power line. 

The Roofing Occupation Has One of the Highest Lifetime Risks of Work-Related Injury

The hazards associated with work on roofs is reflected in the risk of occupational fatal injury

among roofers. The roofer occupation is among the occupations at highest lifetime risk of fatal

work-related injury among workers of all ages [Fosbroke et al. 1997] and one of the riskiest

occupations in the construction industry [Chen and Fosbroke 1998]. Roofers had a lifetime risk

of 9.4 deaths per 1,000 working lifetimes in 1990 and 1991, ranking 16th among all occupations

[Fosbroke et al. 1997]. Fatality data from CFOI indicate that between 1992 and 1997, the annual

rate of work-related fatality was 28.8 deaths per 100,000 roofers [NIOSH 2001c; NIOSH 2001a]. 

Falls accounted for 71% (233) of the 326 fatalities identified during that period.
Hazardous Orders in Non-Agricultural Occupations

62

In 1998, a 15-year-old youth died while

working as a window washer’s helper. The

youth had been standing on the roof assisting

the window washer with the set up of the

rooftop carriage supporting the boatswain’s

chair. As the window washer bounced in his

chair to check the stability of the apparatus,

the carriage, which had not been tied back to

an anchor and had no counter weights

attached, slipped over the edge of the roof.

The two workers’ fall protection harnesses

were tied to the carriage, causing them both

to fall. The window washer was severely

injured and the youth was killed.

[Washington Department of Labor and

Industries 2001]. 

Work on Roofs is Associated with Fatal Falls

During the period 1992 to 1997, 803 workrelated fatal falls from roofs occurred

[NIOSH 2001c]. The majority of fatal falls

from roofs occurred in the construction

industry, followed by services,

manufacturing, agriculture, and wholesale or

retail trades (Table 17). From 1982 to 1997,

the NIOSH Fatality Assessment and Control

Evaluation Program investigated 26 fatalities

in which a worker fell from or through a roof

[NIOSH 2000e]. Investigators identified the

following factors associated with roof-related

falls: unguarded roof openings; unsecured or

unstable materials; and loss of balance. Four

of the fatalities were associated with falls

through skylights. Failure to provide

standard skylight covers or fixed standard

railings on all exposed sides as required by

OSHA General Industry Standards [29 CFR 1910.23(a)(4)] contributed to the skylight-related

fatalities. 

Table 17. Number and Percent of Fatal Falls from Roofs By Industry Division, United States

Industry Division Deaths,

1992-1997

Percent

Construction 651 81.1

Services 39 4.9

Manufacturing 30 3.7

Agriculture 25 3.1

Wholesale or retail trades 21 2.6

Other 37 4.6

Total 803 100

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]

Among young construction workers less than18 years of age during the period 1992 through

1997, 12 fatal falls occurred, three-fourths of which involved falls from or through roofs and
Hazardous Orders in Non-Agricultural Occupations

63

In 1986, a 17-year-old part-time laborer was

electrocuted and another 17-year-old severely

injured while cleaning soot from a smoke

stack on the flat roof of a two-story building. 

The victim and his coworker could not reach

the smoke stack with the metal scraper they

had been given. Without a supervisor

present, they decided to improvise an

extender with a 9-foot piece of metal pole. 

As the victim was carrying the pole, it

contacted a 7200 volt power line which was

13 feet, 3 inches above the surface of the roof

and electrocuted him. His co-worker was

severely injured when he attempted to help

[NIOSH 1986b].

skylights. In comparison, these types of falls accounted for only one third of fatal falls in

construction workers of all ages [Windau et al. 1999].

Non-Fatal Falls from Roofs Are Severe and Result in Many Days Away from Work

In 1997, falls from roofs accounted for 3,341 total non-fatal work-related injuries and illnesses. 

The median of 30 days away from work for these types of injuries indicates that they are

commonly severe. Approximately 45% of these injuries and illnesses resulted in 31 or more

days away from work. Less than 25% of the injuries and illnesses resulted in fewer than 6 days

away from work [BLS 1999b].

Work on Roofs Increases Proximity to Overhead Power Lines and Risk of Electrocution

From 1992 through 1997, there were a total

of 1924 deaths due to electrocution. This

includes injuries resulting from contact with

any energized source of power, including

lightning. Direct or indirect contact with

overhead power lines accounted for 778 of

these deaths. A keyword search

(keyword=roof) of the narrative descriptions

of these 1924 electrocution cases revealed

that the victim was working or preparing to

work on a roof in at least 66 cases. Based on

manual review of these 66 cases, 41 victims

were electrocuted when they or long metal

items they were holding came into contact

with a power line. Seventeen of the victims

came into direct contact with electrical

currents such as ungrounded wiring, air

conditioning or refrigeration units. Seven workers were struck by lightning while working on a

roof. Sixteen of the 66 were employed as roofers, 17 were construction laborers, and 11 were

carpenters. Other occupations included heating and air conditioning mechanic, electrician,

plumber or pipe fitter, stock handler, and structural metal worker [NIOSH 2001c].

HO 17: Occupations in Excavation Operations

Recommendation – 1) Retain the current HO. 2) Remove the exemption for apprentices/student

learners.

Rationale – 1) Excavation and trenching operations are associated with large numbers of worker

deaths, including deaths among young workers. 2) This work environment presents injury risks

due to collapsing earth, machinery, falling objects, fires, explosions, drowning, and
Hazardous Orders in Non-Agricultural Occupations

64

In 1997, a 17-year-old construction laborer

died of injuries sustained in a trench cave-in

at an oil tank removal site. The youth was in

a 12-foot-deep trench, using a gas-powered

saw to cut the rods which held the tank in the

ground. The trench was neither shored nor

sloped. The youth had finished cutting three

rods when the side wall of the trench

collapsed. He was pushed up against the tank

by the force of the soil, striking his head on

the tank. After being removed from the

trench by emergency personnel, the youth

was transported to a nearby hospital, where

he was pronounced dead on arrival

[Massachusetts Department of Public Health

1998b].

electrocution. Nearly three-fourths of the fatalities involved collapsing earth in trenches and

excavations. This hazard can be reduced or eliminated only by sloping, shoring, or installation

of trench shields: interventions which require action by a supervisor or other responsible party. 

Therefore, individual workers have little or no control over their exposure to this hazard, and

neither training in safe work practices nor use of personal protective equipment will reduce the

risk sufficiently. These factors, along with the diversity of injury hazards present in this work

environment, support removal of the exemption for apprentices/student learners. 

Substantial Numbers of Worker Deaths and Injuries Are Associated with Excavation Operations

Like HO 15, HO 17 addresses a range of work settings rather than work within a specific

industry or involving a specific machine. For this reason, identification of fatalities and injuries

associated with work in trenches, excavations, tunnels, and shafts is difficult, and involves a

degree of subjectivity. CFOI for 1992-1997 contained 355 cases whose case narrative was

consistent with this work setting, and which

met one or more of the following criteria:

“trench,”, “excav,” “shaft,” or “tunnel”

appeared in the narrative; the deceased was

employed in SIC 1794 (Excavation

Contractors); or the fatal event was coded as

an excavation or trenching cave-in (OIICS

event code 041) [NIOSH 2001c].

As Table 18 shows, the primary injury

hazard during excavation operations was

collapsing earth, in most instances due to

trench collapses. However, nearly onefourth of the fatalities were associated with

other types of hazards, notably machinery. 

In the majority of these events, a worker in a

trench or excavation was struck by a

machine part, usually a bucket. The 13% of

fatalities not associated directly with

collapsing earth or machinery were due to a

wide variety of events: electrocution, fires

and explosions, drowning, and being struck by falling objects. Workers employed in the

construction industry accounted for 80% of the fatalities, but deaths also occurred among

workers in a range of other industries [NIOSH 2001c].
Hazardous Orders in Non-Agricultural Occupations

65

Table 18. Characteristics of Deaths Associated with Work in Trenches, Excavation Operations,

Tunnels, and Shafts, United States

Deaths 1992-1997

Injury hazard n (%)

 Collapsing earth

 Machinery

 Other

 Total

265 (74.6%)

44 (12.4%)

46 (13.0%)

355 (100.0%)

Industry

 Construction

 Transportation, communications, public utilities

 Public administration

 Mining

 Services

 Agriculture, forestry, and fishing

 Other

 Total

284 (80.0%)

14 (3.9%)

13 (3.7%)

11 (3.1%)

11 (3.1%)

10 (2.8%)

12 (3.4%)

355 (100.0%)

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]

The number of nonfatal injuries and illnesses associated with excavation operations is also

difficult to ascertain, given that there is no single OIICS code to identify these events, and that

the hazards addressed by this HO are not limited to a single industry. Injury data specific to SIC

1794 are not reported. In SIC 179, the broad group of miscellaneous special trades construction

contractors which includes excavation contractors, there were 18,854 days-away-from-work

injuries and illnesses in 1997 requiring a median 8 days away from work [BLS 1999b]. For

OIICS event code 041 (excavation or trenching cave-in), there were 143 nonfatal injuries and

illnesses reported in 1997 resulting in a median 10 days away from work. Neither of these

measures is satisfactory for assessing the number of nonfatal injuries associated with excavation

operations: the industry grouping is too broad, and the event code is too narrow. 
Hazardous Orders in Non-Agricultural Occupations

66

In 1999, a 17-year-old laborer died and a co-worker was

injured when an unprotected wall of a trench they were

working in collapsed. The excavator operator responsible

for digging the trench and setting sewer system components

had removed the trench shield to aid in removal of broken

pipes, but did not replace the shield when work began the

following day. The youth and a co-worker entered the

unprotected trench to set pipe and check the grade of the

sewer line. A section of the trench wall 30 feet long and 11

feet high caved in, burying the youth up to his mid-chest

and his co-worker up to his knees. It took some time for

the two workers to be removed from the trench, as the

trench shield had to be re-installed to ensure rescue

workers’ safety. The youth was transported to a local

hospital, but died 5 hours after the incident following

emergency surgery. [NIOSH 2000f].

Deaths of Young Workers

Have Occurred During

Excavation Operations

Of the 355 excavation-related

fatalities identified by CFOI

between 1992-1997, five

involved the deaths of young

workers younger than age 18

[NIOSH 2001d]. All of these

involved trench collapses in

which the youth was struck or

buried by falling earth. All

five youth were employed in

the construction industry.
67

In 1995, a 12-year-old male working parttime for a farmer was killed when he lost

control and overturned a tractor in a 12-foot

deep roadside ditch. The youth, who was

driving a tractor equipped with a front end

loader and pulling an empty feed wagon,

was driving downhill on a slightly sloping

gravel road. As the youth came to the bottom

of the hill, the road had a culvert and deep

ditches dropping off sharply at the edge of

the road. The youth drove too close to the

edge, causing the tractor to roll completely,

crushing him under the left rear wheel and

fender of the tractor. The tractor had no

ROPS or seatbelt, and the seat was adjusted

in the back position, making the distance

from the seat to the brakes too long for this

driver. Additionally, the loader frame may

have obstructed the view of the front wheels

making it difficult to see the exact position of

the front wheel and the edge of the road.

[University of Iowa 1995a]

Agricultural Occupations

HO 1: Operating a Tractor Over 20 PTO Horsepower or Connecting or Disconnecting an

Implement or Any of Its Parts To or from Such a Tractor.

Recommendation — 1) Retain the HO with the removal of the 20 PTO (power take-off)

horsepower threshold. 2) Revise exemption for 14- and 15-year-olds with tractor certification to

require tractors to be equipped with a rollover protective structure (ROPS) and mandate the use

of seatbelts.

Rationale — 1) Tractor-related fatalities have been the leading source of work-related farming

deaths in the U.S. for many years. Available data sources frequently do not include enough

detail to determine the horsepower of tractors or PTOs involved in fatal and non-fatal injuries. 

Additionally, PTO horsepower differs from tractor engine horsepower and may be difficult to

identify by Wage and Hour inspectors, employers, supervisors and youth workers. Furthermore,

available data do not support the notion that a tractor’s horsepower (engine or PTO) is related to

risk of injury. Therefore, the current 20 horsepower PTO requirement should be eliminated. 2)

A ROPS, when used in conjunction with a seatbelt, is the most important safety feature on a

tractor in reducing the number of deaths from overturns. This engineering safety measure, in

addition to tractor safety training and mandated seatbelt use, should be an effective means of

preventing a substantial number of tractorrelated injuries and fatalities among young

workers.

Tractors Are a Leading Cause of Fatal and

Non-Fatal Injuries in Agriculture

Tractor-related incidents are the most

common type of agricultural fatality in the

U.S. [Myers et al. 1998a; Etherton et al.

1991; Purschwitz and Field 1990]. Tractor

overturns are the most common event among

tractor fatalities, followed by run-overs

[Myers et al. 1998a; Etherton et al. 1991]. 

CFOI for 1992-1997 identified 1845 tractor

(OIICS source codes 8530 and 3123)

fatalities in all industries; over 75% (1421)

occurred in agricultural production [NIOSH

2001c]. Of the agricultural fatalities,

approximately half (707) resulted from

tractor overturns [OIICS event codes 4233

and 4141], with 265 deaths resulting from

tractor run-overs [OIICS event codes 4232
Hazardous Orders in Agricultural Occupations

68

and 4330] (Table 19). The tractor-related fatality rate for agricultural production workers of all

ages was 11.1 deaths per 100,000 workers [NIOSH 2001c; NIOSH 2001a].

A review of agricultural fatality investigations in 10 states between 1990-1996 revealed that in

27 of the 31 fatalities attributed to tractor overturns, a ROPS was not in place. In two of the

remaining overturns, a ROPS was present, but the operator was not wearing a seatbelt [Pratt and

Hard 1998]. 

Table 19. Fatal Events for Tractor-Related Fatalities in the Agricultural Production Industry

[SIC 01,02] for All Ages, United States

Event [OIICS event code] 

Deaths

 1992-1997

Overturns [4233] 625

Fell from and struck by vehicle [4232] 188

Jack-knifed, overturned [4141] 82

Pedestrian struck by vehicle in non-roadway area [4330] 77

Struck by rolling, sliding objects on floor or ground level [0240] 68

Highway accident, moving in same direction [4112] 48

Caught in running equipment or machinery [0310] 38

Struck by falling object [0210] 33

Fall from moving vehicle [4231] 25

Noncollision accident, unspecified [4230] 24

Compressed or pinched by rolling, sliding, or shifting object [0320] 23

Vehicle struck stationary object [4220] 20

Caught in or compressed by equipment or objects, nec [0390] 16

Other 154

Total 1421

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]

A review of non-fatal farm injury data for all ages identified an estimated 5,745 tractor-related

lost-time work injuries on U.S. farms from 1993-1995 resulting in a median 5.5 days of

restricted activity for the injured person [NIOSH 2001k].

Fatal and Nonfatal Tractor-Related Injuries to Youth in Agriculture
Hazardous Orders in Agricultural Occupations

69

In 1994, a 10-year-old male suffered acute

lacerations of the brain and multiple skull

fractures when the tractor he had been

driving overturned. The youth was driving

the tractor on a public highway, pulling a hay

baler and a hayrack loaded with bales of hay. 

When the youth attempted to make a turn

onto a gravel road, the rear wheels of the

tractor began to slide and the momentum of

the baler, hayrack, and load of hay caused the

tractor to slide to the edge of the road and

overturn, pinning the youth beneath the

tractor. Although emergency personnel

arrived moments after the incident, the youth

was pronounced dead at the scene. The

tractor was not equipped with a ROPS 

[Minnesota Department of Health 1994].

Just as with adult farm workers, tractors are also the leading source of fatalities for young

agricultural workers, with overturns being the most frequent injury event [Hard et al. 1999;

Castillo et al. 1999b]. Tractors pose added risk to youth for many reasons. Youth may lack

work experience and the cognitive abilities to recognize and control potential hazards. 

Additionally, there may at times be a physical mismatch between the youth and the size of the

machinery [CDC 1999a]. As illustrated in the case in the text box on page 67, the youth was

operating a tractor in which the seat was set at the farthest distance from the brake pedals,

making it difficult for the youth to operate the brakes safely.

A review of CFOI data (1992-1997)

identified 27 tractor-related fatalities for

youth under the age of 16 [NIOSH 2001d]. 

Fourteen of the fatalities occurred while the

youth were operating the tractor. Nineteen of

the deaths resulted from the tractor

overturning. Other circumstances included

run overs, PTO entanglements, and fatalities

while disconnecting implements from the

tractor. Table 20 shows the age distribution

for youth fatalities and the associated injury

event. 

A review of non-fatal farm injury data

identified an estimated 3069 injuries from

tractors for 1998 for youth under the age of

16 [NIOSH 2001l]. These data were from the

Childhood Agricultural Injury Survey

(CAIS). CAIS was a nationwide telephone

survey of farm operators which collected youth injury information for the calendar year of 1998. 

CAIS was conducted for NIOSH by the U.S. Department of Agriculture. Of these injuries, 2185

youth were operating the tractor at the time of the injury. Sixty-three percent of the tractors were

equipped with ROPS and 56% of the tractors had seatbelts. Of those tractors with seatbelts, 82%

of the operators reported to be wearing them at the time of the injury. Injury severity was

measured on a 5-point scale (1=minor 5=life threatening). Injuries that occurred on a tractor

equipped with a ROPS had a mean severity of 1.4. Injuries on tractors not equipped with a

ROPS had a mean severity of 3.0. In 44% of the injuries, the youth was using the tractor for

tilling purposes at the time of the injury.
Hazardous Orders in Agricultural Occupations

70

Table 20. Agricultural Tractor-Related Deaths to Youth by Age Group and Injury Event, United

States

Age Group

Deaths 

1992-1997 Events [OIICS event code]

Less than 12 9 (34%) Caught in running equipment or machinery [0310], Compressed

or pinched by rolling, sliding, or shifting objects [0329], jackknifed/overturned no collision [4141], overturn [4233],

pedestrian struck by vehicle [4330]

12-13 9 (33%) Jack-knifed/overturned no collision [4141], fell from and struck

by vehicle [4232], overturn [4233], pedestrian struck by vehicle

[4330]

14-15 9 (33%) Jack-knifed/overturned no collision [4141], overturn [4233],

collision between railway vehicle and other vehicle [4420]

Source: Census of Fatal Occupational Injuries [NIOSH 2001d]

Data Are Deficient in PTO Horsepower Information

Agricultural HO 1 deals specifically with youth under the age of 16 operating a tractor over 20

PTO horsepower. There are two compelling reasons for removing the horsepower requirement

from HO 1. First, although tractors used for farming tasks generally exceed the 20 PTO

horsepower requirement, the available data sources do not specify horsepower when providing

details on tractor-related incidents. Additionally, since PTO horsepower differs from tractor

engine horsepower (PTO horsepower being slightly less than engine horsepower),Wage and

Hour inspectors, employers, supervisors and youth workers may not be able to determine PTO

horsepower without contacting the manufacturer or consulting an operator’s manual. The

difficulties in determining a tractor’s PTO horsepower, both in research and enforcement, make

compliance with the HO difficult. Therefore, the PTO horsepower requirement should be

eliminated.

Training As a Means of Instilling Safe Tractor Operating Practices

Youth ages 14 and 15 who have completed approved tractor or machinery certification programs

are exempt from requirements of the agricultural hazardous orders covering these work activities

[DOL 1990]. The effectiveness of these tractor safety training programs has not been adequately

evaluated nationwide. However, two studies have attempted to evaluate these tractor

certification programs in two states, Indiana and Wisconsin [Carrabba et al. 2000; Wilkinson et

al. 1993]. Carrabba et al. [2000] recently conducted a study in Indiana to determine the impact

of 4-H tractor safety programs on the behavior and attitudes of youth tractor operators [Carrabba

et al. 2000]. The results of this study indicate that participants in tractor safety programs

demonstrate a greater level of confidence in operating tractors, and that the programs appear to

have a positive influence on the safe operating procedures of participants in the training. A

study by Wilkinson et al. [1993], which evaluated the training certification programs in
Hazardous Orders in Agricultural Occupations

71

Wisconsin, found that youth who had completed a training program reported an increase in

usage of tractors equipped with ROPS and were less likely to ride on a tractor as a passenger.

Effectiveness of Rollover Protective Structures for the Prevention of Tractor-Related Injuries

ROPS are structural components attached to vehicles and are designed to protect the operator if

the vehicle overturns during operation; they can either be enclosed in a tractor cab or

unenclosed. A ROPS limits the degree to which the tractor rolls and the seatbelt keeps the

operator within the protective space of the ROPS. A seat belt should always be used in

conjunction with ROPS.

Rollover protective structures have been identified as the best means of preventing deaths from

overturns. However, only 35% of all farm tractors in the U.S. were equipped with ROPS in

1993 [Myers et al. 1998a]. A study of tractor rollover incidents in Nebraska found that of

approximately 250 persons involved in unprotected tractor rollover incidents, 40% died. Only

one person operating a ROPS-equipped tractor that rolled over was fatally injured, and this

person was not using a safety belt at the time of the incident and was ejected from the ROPS

protective zone [CDC 1993a]. Additional studies of ROPS effectiveness in the U.S. have shown

that for tractors equipped with ROPS, fatalities occurred only when farmers did not use a

seatbelt to prevent ejection from the protective environment of the ROPS during a rollover

[Reynolds and Groves 2000]. A study in Sweden, which has implemented regulations requiring

ROPS on all tractors, has shown a 92% reduction in tractor rollover fatalities following the

intervention [Springfeldt et al. 1998]. The United States has a tractor rollover lost-life rate 24

times higher than Sweden [Thelin 1998] 

Other studies provide further evidence of a reduction in agricultural tractor fatalities associated

with increased use of ROPS [Cameron et al. 1992; Cotten 1997]. Additionally NIOSH has

estimated that a 71% reduction from the current number of rollover fatalities would be expected

by increasing the use of ROPS to cover all tractors that do not currently have any form of ROPS. 

NIOSH further estimated that the efficacy of ROPS would approach 100% if accompanied by

universal use of safety belts on all unenclosed ROPS equipped tractors [CDC 1993a]. Cotten

[1997] reported that ROPS have proven to be effective, and that the powerful impact of this

engineering design is illustrated by the fact that tractors equipped with ROPS constitute less than

1% of fatalities when used in conjunction with safety belts.
Hazardous Orders in Agricultural Occupations

72

HO 2: Operating or assisting to operate (including starting, stopping, adjusting, feeding or

any other activity involving physical contact associated with the operation) any of the

following machines:

i) Corn picker, cotton picker, grain combine, hay mower, forage harvester, hay

baler, potato digger, or mobile pea viner;

ii) Feed grinder, crop dryer, forage blower, auger conveyor, or the unloading

mechanism of a nongravity-type self-unloading wagon or trailer, or 

iii) Power post-hole digger, power post driver, or nonwalking-type rotary tiller.

HO 3: Operating or assisting to operate (including starting, stopping, adjusting, feeding, or

any other activity involving physical contact associated with the operation) any of the

following machines:

i) Trencher or earthmoving equipment;

ii) Fork lift;

iii) Potato combine; or

iv) Power-driven circular, band, or chain saw.

Recommendation – Combine HO 2 and HO 3, and expand prohibition from lists of specific

machines to machines that perform general functions (e.g. harvesting and threshing machinery;

mowing machinery; plowing, planting and fertilizing machinery; other agricultural and garden

machinery; excavating machinery; loaders; wood processing machinery, such as wood chippers

and debarkers; sawing machinery, including chain saws; powered conveyors; and, mobile

equipment, including forklifts) following the terminology used in current coding systems.

Rationale – Work with machinery in agriculture is associated with high numbers of work-related

deaths among adults and youth. Work with machinery exposes workers to many hazards such as

entanglements, run-overs, roll-overs, being struck by materials and objects, and falls. The

current HOs list specific types of machinery which are prohibited; this is problematic due to the

continuing introduction of new types of machinery in agricultural production. Combining the

two HOs into one inclusive machinery HO based on the function performed by the machine

would allow more effective tracking of injuries and comprehensive coverage of new types of

machinery that may come onto the market.

It is recognized that HO2 and HO3 were originally separated based on opportunities for

machinery certification. Although the issue of machinery certification is beyond the scope of

this report, DOL should consider evaluating which machines may be safely operated by 14- and

15-year-old youth with appropriate safety training. It is important to note that those machines

which 14- and 15-year-olds may be certified to operate under the current HO 2 result in more

deaths annually than those listed in HO 3 for which certification is unavailable. Machinery

certificates should make it clear which machinery are permitted, so that employers and

compliance personnel can easily determine if a youth has received the required training. 

Changing administrative procedures to clarify which machines a youth may operate would

eliminate the need to separate HO 2 and HO 3.
Hazardous Orders in Agricultural Occupations

73

Farm Machinery is Associated with Substantial Numbers of Deaths and Injuries among Workers

During the 1980's, machinery-related incidents were the second leading cause of occupational

fatalities in the United States. Thirty percent of these were in the agriculture/forestry/fishing

industries [Pratt et al. 1996]. A 1991 study found that agricultural machines were involved in an

annual average of 369 deaths per year [Etherton et al. 1991]. Other studies have shown that farm

machinery is a leading source of traumatic injuries on U.S. farms [CDC 1995; Etherton et al.

1991].

During the period 1992-1997, 472 farm machine-related deaths were identified by CFOI in

agricultural production (OIICS source codes: 3100-3190, 3240, 3427, 4830) [NIOSH 2001c]. 

Harvesting machinery, including balers, were the most common source of machinery-related

fatalities (Table 21). Plowing and cultivating machinery, and spreaders, are examples of

machines that contributed to a substantial number of deaths yet do not appear to be encompassed

under the existing agricultural HOs. Because of the lack of detail in the OIICS coding structure

and information in narrative fields of the CFOI system, it was not possible to identify whether

the fatalities identified in categories such as balers (OIICS source 3111) and combines (OIICS

source 3112) were covered by the existing agricultural HOs. For example, grain combines are

prohibited by HO2 and potato combines are prohibited for youth by HO3. It is not possible to

determine if other types of combines are reflected in the fatality statistics.

Almost a quarter of the farm machine-related fatalities resulted from being caught in running

equipment or machinery (Table 21) [NIOSH 2001c]. Other common fatality events were falling

from and being struck by machinery (16%), overturns (14%), and being struck by falling objects

(9%). 

Other Types of Machinery Are Associated with Substantial Numbers of Deaths and Injuries

among Agricultural Workers

An additional 125 fatalities were identified which resulted from nonagricultural equipment (i.e.,

earthmoving equipment, loaders and forklifts) (Table 22) [NIOSH 2001c]. Front-end loaders,

not covered by agricultural HO2 or HO3, were associated with the highest number of deaths

(36), followed by forklifts (24), and bulldozers (18). Similar to the farm machinery fatalities,

many of these fatalities resulted from overturns (18%), being stuck by a falling object (15%),

and pedestrians being struck (11%). Most of the fatalities from falling objects resulted from

being struck by falling buckets. When examining the data for fatalities related to power-driven

saws, there were no fatalities associated with band or circular saws in agricultural production and

less than 5 fatalities attributable to chain saws. 
Hazardous Orders in Agricultural Occupations

74

Table 21. Fatal Injuries to Agricultural Production Workers Associated with Agricultural and

Garden Machinery, United States

Machinery [OIICS source code]

1° or 2° 

Source of Death, 

1992-1997

Agricultural/garden machinery [310] 30

Harvesting, threshing machinery [311] 165

 Harvesting and threshing machinery, unspecified [3110] –

 Balers [3111] 60

 Combines [3112] 47

 Harvesters, reapers [3113] 17

 Threshers [3114] –

 Harvesting, threshing machinery, n.e.c. [3119] 34

Mowing Machinery [312] 145

 Mowing machinery, unspecified [3120] 12

 Lawn mowers – riding [3122] 8

 Mowers – tractor [3123] 115

 Mowing machinery, n.e.c. [3129] 10

Plowing, planting, and fertilizing machinery [313] 73

 Plowing, planting, and fertilizing machinery, unspecified [3130] 8

 Plowing and cultivating machinery [3131] 22

 Seed planting machinery [3132] 7

 Spreading machinery – agricultural [3133] 22

 Plowing, planting, and fertilizing machinery, n.e.c. [3139] 14

Other agricultural/garden machinery [319] 10

Conveyors – screw, auger [3427] 27

Trailers [4830] 22

Total 472

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]. Dashes indicate that BLS reporting requirements

were not met.
Hazardous Orders in Agricultural Occupations

75

In 1997, a 13-year-old male died of injuries

sustained when he was run over by a grass

seeder. As an adult coworker drove a tractor

pulling the seeder, the youth rode in an area

between the seeder and the tractor on the

hitch of the seeder. The youth was using his

hand to reach into the open seed

compartments and keep the seed evenly

distributed inside the compartments. While

he was doing this, he apparently lost his

balance and fell from the frame of the seeder

and was run over by it [Minnesota

Department of Health 1997].

Table 22. Fatal Injuries to Agricultural Production Workers Associated with Nonagricultural

Machinery, United States

Machinery [OIICS source code]

1° or 2° 

Source of Death, 

1992-1997

Excavating machinery [321] 32

Loaders [322] 69

Forklifts [851] 24

Total 125

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]. 

Fatal and Non-Fatal Machine-Related Injuries to Youth Working in Agricultural Production and

Services Sectors

A review of fatal work-related injuries to youth in the agricultural production and service sectors

has shown that machinery is the second leading source of fatal injuries to youth in the United

States. The machinery-related fatalities in this study were associated with several different types

of machinery including: plowing, planting and fertilizing machinery; harvesting and threshing

machinery; and loaders [Castillo et al. 1999b]. 

CFOI data (1992-1997) identified 23 farm

machinery-related fatalities to youth less than

16 employed in agricultural production. The

machinery most commonly associated with

youth fatalities were spreading machinery,

not currently prohibited by HO2 or 3, and

augers. Ten of these fatalities resulted from

the youth being caught in running equipment

or machinery, and 5 deaths resulted from

youth riding on and falling from the

machinery. An additional 6 cases were

identified which involved machinery

currently prohibited in HO3. Two-thirds of

these injuries resulted from work with

loaders, which is not explicitly covered by

either HO 2 or HO 3. There were no identifiable youth fatalities associated with power-driven

circular, band, or chain saws [NIOSH 2001d]. 

An examination of CAIS data identified an estimated 3035 machinery-related injuries in 1998. 
Hazardous Orders in Agricultural Occupations

76

Tilling and planting machinery (47%) and harvesting machinery (9%) were the most common

types of machinery involved in the injuries. Approximately half of the machinery was reported

to have protective equipment in place at the time of the injury. Additionally, 51% of the injured

youth were wearing some type of protective clothing. Safety goggles (88%) were the most

common type of protective clothing being used, followed by gloves (11%). An estimated 166

injuries occurred to youth operating chain saws. [NIOSH 2001l].

HO 4: Working on a Farm in a Yard, Pen, or Stall Occupied By a:

(i) Bull, boar, or stud horse maintained for breeding purposes; or

(ii) Sow with suckling pigs, or cow with newborn calf (with umbilical cord present).

Recommendations – Retain current HO.

Rationale – Agricultural injury statistics clearly show that animal-related farm injuries remain

problematic for all workers, regardless of age. Farm animals may be dangerous to humans in

many different situations, such as: territorial protection, maternal instincts, social relationships,

or simply an interruption of their normal habits. Youth exposed to these hazardous situations

often lack the experience and the knowledge to detect the subtle signs an animal often exhibits in

these situations before attacking. Further, the difference in body weight between a child and the

average farm animal makes injuries more common and severe [NIOSH 2000a; 64 Fed. Reg.

67130 (1999)]. 

Work with Farm Animals Accounts for a High Proportion of Fatal and Nonfatal Injuries in

Agriculture

Animal-related injuries are an important occupational hazard associated with farming [Boyle et

al. 1997; Layde et al. 1996; Cogbill et al. 1985]. A study of injuries in five states has shown that

animals are the primary source of injuries to both males (25%) and females (49%) in the farm

household [Boyle et al. 1997]. Additionally, in a study of occupational farm injuries in central

Wisconsin, cattle were responsible for the majority (87%) of animal-related injuries [Layde et al.

1996].

A review of data for both fatal and non-fatal animal-related injuries was conducted. HO 4 deals

specifically with youth under the age of 16 working on a farm in a yard, pen, or stall occupied by

a: 1)bull, boar, or stud horse maintained for breeding purposes; or 2) sow with suckling pigs, or

cow with newborn calf (with umbilical cord present). However in the majority of instances

existing data are not specific enough to provide this level of detail. Additionally, because the

farm often serves as both the home and work place for many youth, it is often difficult to

distinguish between work and non-work injuries.

The Census of Fatal Occupational Injuries (CFOI) for 1992-1997 identified 167 fatalities

involving animals on farms, 133 of which were identified as occurring in a farm yard, pen, or

stall as specified by HO 4. Almost half (49%) of the fatalities were due to interactions with a
Hazardous Orders in Agricultural Occupations

77

bull. In 29% of the bull-related fatalities, the incident occurred while the bull was being moved

or loaded in or out of the farm yard/pen/stall. Five fatalities were identified which involved a

cow with a newborn calf [NIOSH 2001c]. 

Data from the Traumatic Injury Surveillance of Farmers (TISF), a nationwide mail survey of

farm operators which collected injury information from farm operators in agricultural production

for the years 1993-1995, suggested that in 1994 an estimated 121,937 lost-time work injuries

occurred on U.S. farms [Myers 1998]. Twenty percent of these injuries were attributable to

livestock, which was the leading cause of injury. Several studies also have indicated that

animal-related injuries account for between 12 and 33% of all farm injuries [Brison and Pickett

1992; Pratt et al. 1992; Nordstrom et al. 1995; Lewis et al. 1998].

Youth Suffer Fatal and Nonfatal Injuries Due to Animal-Related Work in Agriculture

Several studies have shown that animals are one of the most common sources of injury to

children on farms [Layde et al. 1996; Cogbill et al. 1985; Hoskin and Miller 1979]. Cogbill et

al. [1985] reported that animal-related injuries account for 43% of injuries to children on farms. 

Additionally, in a survey of farm injuries in 21 states, Hoskin and Miller (1979) found a

significant number of injuries occurring as a result of a cow protecting her calf. 

A review of CFOI cases for 1992-1997 found that 6% (n=8) of animal-related fatalities clearly

identified as occurring in a farm yard, pen, or stall, occurred to youth under the age of 16. As

previously stated, the data were not specific enough in some instances to report at the level of

detail indicated in the HO [NIOSH 2001d].

An examination of non-fatal farm injury data for youth collected by NIOSH for the calendar year

of 1998 estimated that 20% (6438) of all injuries to youth under the age of 20 occurring on farms

were animal-related (injury rate: 3.2/1000 youth). In over 70% of the cases the injured youth

was under the age of 16. Additionally, 69% of these animal-related injures were determined to

have occurred while the youth was completing work/chores on the farm. The animals most

commonly involved in the injuries were horses (37%) and cattle (31%) [NIOSH 2001l].

HO 5: Felling, Bucking, Skidding, Loading or Unloading Timber with Butt Diameter of

More than 6 Inches.

Recommendation – Retain HO, but remove the 6 inch diameter threshold.

Rationale – Work on farms associated with timbering exposes workers to many of the same risks

as in logging occupations (see nonagricultural HO 4, page 27). Tractors can overturn while

attempting to remove stumps or while dragging logs that get caught on stumps or trees. Trees

can fall on people and chain saws can buck causing severe lacerations and amputations. This

type of work continues to be extremely hazardous for all workers, and includes tasks which are

prohibited for minors less than 18 under nonagricultural HO 4. Available data sources often do
Hazardous Orders in Agricultural Occupations

78

not report sufficient detail to determine the butt diameter of trees. Further, there is no evidence

that working with timber with a butt diameter of 6 inches or less is any safer than work with

larger timber. Therefore, the 6 inch diameter threshold should be removed. It is evident from

the data that these types of activities present considerable risk to workers of all ages and should

remain prohibited for agricultural workers less than 16.

Hazards of Logging Are Present in Agricultural Settings

Logging is one of the most hazardous industries in the United States [Braddee and Myers 1997;

Myers and Fosbroke 1994]. Although there is little data on logging-type fatalities in agricultural

production, many of the same hazards exist for farmers as for loggers (see nonagricultural HO 4,

page 27). According to NTOF data for the years 1980-1992, logging-type practices resulted in

173 work-related “struck by falling object” deaths to farmers, which represented 46% of all

deaths in the agricultural production industry [Braddee and Myers 1997]. A study of 16 rear

rollovers due to improper hitching to farm tractors in New York found that 63% of overturns

occurred when operators were pulling logs or removing stumps [CDC 1996a]. 

Fatalities Associated with Logging-Type Activities in Agricultural Production

From 1992-1997, CFOI identified 97 fatalities associated with felling, bucking, skidding,

loading or unloading timber among workers in agricultural production in the U.S. [NIOSH

2001c]. Over half of these deaths resulted from being struck by an object, most commonly a

felled tree or limb. Almost one-third of these deaths occurred while a worker was using a tractor

to push or pull trees or stumps causing the tractor to overturn. Other common factors were being

struck by a tree while pushing/pulling with tractor or other machinery, and falls from heights

(Table 23). Of those fatalities due to being struck by an object, the majority of the cases (12%)

involved being struck by a tree.

Table 23. Fatality Events Associated with Logging-Type Activities in Agricultural Production,

United States.

Event [OIICS Event Code]

 Deaths

1992-1997

Struck by Object [02] 51

Fall to lower level [11] 8

Nonhighway, noncollision accident [423] 34

Other 4

Total 97

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]
Hazardous Orders in Agricultural Occupations

79

In 1994, a 13-year-old male sustained fatal

massive head trauma when the tractor he was

using overturned to the rear while pulling a

felled 18-inch diameter tree that was still

partially attached at the stump. The tow

chain had been hooked directly around the

rear axle. The tractor was not equipped with

a ROPS [CDC 1996a].

Youth Injuries Associated with Logging-Type Activities in Agricultural Production

Data from the CAIS identified 219 injuries in

1998 requiring at least 4-hours of restricted

activity or professional medical attention to

youth less than 16 who were injured while

using chain saws to cut wood on the farm

[NIOSH 2001l]. 

HO 6: Working from a Ladder or Scaffold (Painting, Repairing, or Building Structures,

Pruning Trees, Picking Fruit, etc.) at a Height of Over 20 Feet.

Recommendation – 1) Expand the HO to cover work on: roofs; farm structures including silos,

grain bins, windmills, and towers; and vehicles, machines, and implements (while retaining

prohibitions against work from ladders and scaffolds). 2) Reduce the maximum height at which

youth under 16 may work in these settings from 20 feet to 6 feet. 

Rationale – 1) Fatality and injury data for the agricultural production industry show that large

numbers of worker fatalities and injuries result from falls from elevation. Fall hazards in

agriculture are much broader than those identified in HO 6. Expansion of the HO to cover work

on roofs, on farm structures, and on vehicles, machines, and implements would cover more of

the work situations in which fatal falls have been found to occur. 2) Available fatality data for

workers of all ages suggest that permitting youth to work at heights of up to 20 feet is not

sufficiently protective: the majority of fatal falls among agricultural production workers for

which the height of the fall was known occurred from a height of 20 feet or less. Lowering the

height threshold for youth in agriculture would make HO 6 more consistent with occupational

safety standards for the construction industry that require fall protection at 6 feet.

Fatal Falls Among Agricultural Production Workers Continue

CFOI identified 166 fatal falls among agricultural production workers between 1992-1997, the

majority of which were falls from elevation [NIOSH 2001c, Table 24]. Most prominent among

fatal falls in agricultural production were falls from vehicles, machinery, or implements, and

falls from roofs and farm structures. Work from ladders and scaffolds, the only work situations

now restricted for youth by agricultural HO 6, were not associated with large numbers of fatal

falls. There were 17 falls from ladders, comprising 10.2% of the total. Data on falls from

scaffolds did not meet minimum BLS reporting requirements. 
Hazardous Orders in Agricultural Occupations

80

Table 24. Fatal Falls Among Agricultural Production Workers, United States

Event* Deaths, 1992-

1997

Fall from vehicle, machine, or implement 33

Fall from farm structure (e.g., silo, grain bin,

windmill)

19

Fall from roof 18

Fall from ladder 17

Fall from floor, dock, or ground level 16

Fall from horse 13

Fall from haystack or hay bales 11

Fall from tree 7

Fall or jump to lower level, other and

unspecified 

12

Fall on same level 14

Fall, unspecified 6

Total 166

Source: Census of Fatal Occupational Injuries, [NIOSH 2001c]. 

*Event categories in this table do not correspond directly to OIICS categories. Cases were re-grouped to provide

more specific information about circumstances of fatal falls in agricultural production.

Clearly, fall hazards in the agricultural production industry are not limited to ladders and

scaffolds, which are the only hazards now addressed in HO 6. Work on roofs and work at

heights on farm structures could be defined clearly, but other hazards such as working at heights

on stationary vehicles and work in trees and on haystacks may be more difficult to address.

Data on the Height of Fatal Falls in Agriculture Are Limited

Of the 152 fatal falls from elevation in the agricultural production industry identified by CFOI,

only 38 case narratives (25%) indicated the number of feet fallen by the fatally injured worker. 

However, it is noteworthy that in 22 of the 38 incidents, the worker fell from 20 feet or less. 

These data suggest that permitting work at a height of up to 20 feet does not provide adequate

protection for agricultural workers of all ages, and is therefore not adequate to protect youth.

Substantial Numbers of Nonfatal Falls Occur Among Agricultural Production Workers
Hazardous Orders in Agricultural Occupations

81

In 1997, a 12-year-old boy died

after falling off a hay wagon on

which he was riding. The wagon

was being pulled by a tractor

driven by the boy’s uncle. The

boy apparently slipped and fell off

the wagon, and was then run over

by the wagon’s wheels.

[Associated Press 1997;

Evansville Courier 1997].

In 1994, there were an estimated 19,008 nonfatal falls from elevation resulting in 1⁄2 day or more

restricted activity among U.S. farm workers. Falls on the same level resulted in an estimated

12,153 injuries resulting in restricted activity [Myers 1998].

Fall-Related Fatalities and Injuries Among Youth Working in Agricultural Production Have

Been Reported

CFOI identified fall-related fatalities among agricultural workers younger than age 16, none of

which involved a fall from elevation. In 1998, youth under age 16 on U.S. farms incurred an

estimated 11,334 injuries resulting in restricted activity due to falls from elevation [NIOSH

2001l]. Notable among these were falls from equipment or vehicles, many of which were allterrain vehicles (ATVs) (1,346 injuries); falls from horses (1,198 injuries); falls associated with

climbing steps or ladders (659 injuries); and falls associated with climbing other structures, often

trees or hay bales (603 injuries).

Other Federal Occupational Health and Safety Standards Do Not Address Falls in Agriculture

Federal occupational safety and health standards

applicable to workers of all ages require use of fall

protection for construction industry employees who

work 6 feet or more above a lower level. 29 CFR 1926,

Subpart M, stipulates that these employees must be

protected from falling through the use of guardrail

systems, safety net systems, or personal fall arrest

systems [29 CFR 1926.501]. These standards apply to

work situations such as unprotected sides and edges,

work on roofs, work at the edge of excavations, and

work above dangerous equipment. Construction

workers on scaffolds who are working more than 10 feet

above a lower level must be protected from falling to

that level; 29 CFR 1926.451 (g) specifies types of fall

protection to be used for the various types of scaffolds. Standards for general industry found in

29 CFR 1910, Subpart D, address fall hazards by requiring guarding of wall and floor openings,

and by defining specifications for ladder and scaffold construction. Additionally, standards for

some types of scaffolds require the use of guardrails at work levels of 10 feet or higher [29 CFR

1910.29]. None of the above standards for construction or general industry extend to workers in

agricultural production, nor do agricultural health and safety standards contain fall protection

provisions of any kind.

HO 7: Driving a Bus, Truck, or Automobile When Transporting Passengers, or Riding on a

Tractor as a Passenger or Helper.

Recommendation – 1) Expand to prohibit driving of all motor vehicles and off-road vehicles
Hazardous Orders in Agricultural Occupations

82

(including all-terrain vehicles), with or without passengers, on and off the highway. 2) Expand

to prohibit work as an outside helper on a motor vehicle. 3) Retain the provision prohibiting

riding on a tractor as a passenger or helper, but move it under agricultural HO 1. 

Rationale – 1) There are a number of strong arguments for this revision. Limiting this HO to

buses, trucks, and automobiles does not reflect the breadth of vehicles now in use in agricultural

production. Fatality and injury data support prohibition of driving of all types of motorized

vehicles, including all terrain vehicles (ATVs). Most states do not allow youth under age 16 to

exercise full driving privileges; in a few states the minimum age to obtain a learner’s permit is

16. Yet, HO 7 does not explicitly prohibit driving by agricultural workers under age 16. In

contrast, nonagricultural HO 2 places substantial restrictions on motor vehicle operation by 16-

and 17-year-olds in other industries. Finally, operating a motor vehicle without passengers,

currently allowed under HO 7, does not reduce crash risk among young drivers to acceptable

levels.

2) Available data indicate that there are fatalities and injuries among agricultural workers,

including youth under 16, associated with working as an outside helper on a vehicle. Revising

HO 7 to include prohibition of this activity would offer increased protection to young

agricultural workers, and would make this HO consistent with nonagricultural HO 2. 

3) Fatalities and injuries associated with riding on a tractor as a passenger have been reported

among agricultural workers, including youth under 16. Retention of this provision is warranted,

but it should be removed from HO 7 and placed under HO 1 so that all tractor-related hazards are

addressed in a single HO.

Agricultural Worker Fatalities and Injuries Are Associated with Driving Motor Vehicles, and

with Being an Outside Helper on a Vehicle

During 1992-1997, CFOI identified 1,541 fatalities of agricultural production workers due to

collisions and single-vehicle incidents on or off the highway (OIICS event codes 41 and 42). 

These comprised 45.6% of all occupational fatalities in the agricultural production industry. 

However, because of overlap with other agricultural HO’s, three groups were excluded from the

following discussion of HO 7: 1,008 tractor-related incidents classified by the OIICS system as

vehicle-related (already covered under Agricultural HO 1); 207 incidents involving mobile

machinery, including forklifts (already discussed under Agricultural HO’s 2 and 3); and 12

fatalities involving animal-drawn vehicles. The remaining 314 cases were collisions or singlevehicle incidents occurring on or off the highway, in which an agricultural production worker

died [NIOSH 2001c].

The majority (74.5%) of these 314 vehicle-related incidents occurred on the highway. Highway

incidents were dominated by truck-related incidents, with off-highway incidents most often

associated with trucks and ATVs (Table 25). Automobile-related incidents occurred primarily

on the highway, while those involving ATVs were more common off the highway. 

CFOI data show that the decedent was operating the vehicle in 83.8% of on-highway incidents,
Hazardous Orders in Agricultural Occupations

83

compared with 71.3% of off-highway incidents. CFOI does not record coded information as to

whether passengers were being transported, although in some instances the case narrative

provides some insight. Notable among the truck-related fatalities were 22 in which the decedent

was riding on the vehicle as an outside helper, generally in the truck bed. Fifteen of these

occurred off the highway, comprising 40.5% of the off-highway truck fatalities. 

Table 25. Fatalities Associated with Highway and Nonhighway Accidents Involving Motor

Vehicles (Excluding Tractors, Mobile Machinery, and Animal-Drawn Vehicles), by Primary

Source of Injury – Agricultural Production Workers, United States

Primary Source of Injury*

[OIICS Source Code]

Highway Accident

[OIICS Event 41],

1992-1997

Nonhighway

Accident [OIICS

Event 42], 1992-

1997

Automobile [821] 33 ---

Truck [825] 178 37

All-terrain vehicle [841] 6 30

Other vehicle [800-899, except

821, 825, 841, 851]

17 12

Total 234 80

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]. Dashes indicate that BLS reporting requirements

were not met.

* The primary source of injury identifies the object that directly produced or inflicted the fatal injury. For incidents

involving vehicles, the vehicle occupied by the decedent is the primary source of injury, while the striking vehicle, if

any, is the secondary source.

Fatalities and Injuries of Agricultural Workers Younger Than Age 16 Associated with Driving

Motor Vehicles, and with Being an Outside Helper on a Vehicle

CFOI identified a total of ten vehicle-related fatalities of agricultural workers under age 16

between 1992 and 1997, excluding events involving tractors, mobile machinery, and animaldrawn vehicles. Six occurred on the highway, and four off the highway [NIOSH 2001d].

The primary sources of injury most commonly cited was a truck (6 deaths). Youth fatalities

involving automobiles and ATVs were also reported, but the frequencies were too small to meet
Hazardous Orders in Agricultural Occupations

84

In 1998, a 9-year-old boy died when he was

run over by a cargo truck driven by his father,

a contracted seasonal farm laborer. The boy

had been picking blueberries with his father

and an 11-year-old boy. At the time of the

incident, the two boys were assigned to pick

up containers filled with blueberries from the

side of the field road, and load them into the

back of the cargo truck. The boys were

riding in the back of the cargo truck with the

door open as the father drove the truck in

reverse. The 9-year-old either jumped or fell

off the rear of the truck, and was run over by

the reversing truck [NIOSH 1998]. 

BLS reporting thresholds for CFOI data. The fatally injured youth was driving the vehicle in the

majority of the fatalities, but there were

incidents in which the youth was riding on

the vehicle as an outside helper.

In 1998, there were an estimated 5,444

vehicle-related injuries to youth under age

16 on U.S. farms, based on data from the

CAIS, a nationwide telephone survey of

U.S. farm operators conducted for NIOSH

by the U.S. Department of Agriculture. 

Nearly half (47.4%) of the vehicle-related

injuries involved ATVs. Other prominent

sources of injury were automobiles

(27.2%) and trucks (6.3%). The majority

of injured youth (73.9%) were operating

the vehicle, 8.7% were riding in a

passenger seat, and 6.1% were riding

elsewhere in or on the vehicle [NIOSH

2001l].

Hazards of Youth Operating Motor Vehicles Are Not Limited to Transporting Passengers

HO 7 currently prohibits driving by young agricultural workers only while transporting

passengers. Studies of highway crash risk in the general population show that transporting

teenage passengers increased risk of fatal crash for teenage drivers, although the presence of

passengers age 30 or older presented essentially the same level of risk as driving alone [Chen et

al. 2000; Preusser et al. 1998]. Although it is clear from CFOI case narratives that riding on the

outside of a truck is associated with fatalities among agricultural workers of all ages, available

data do not provide enough information to ascertain the overall involvement of passengers,

teenage or adult, in fatalities of young agricultural workers. Transporting teen passengers may

introduce additional risk for young drivers in the general population, but it is by no means the

only issue to be considered. 

Fatality and Injury Risk to Youth Operators of ATVs

Another vehicle-related risk not currently addressed under HO 7 is the operation of ATVs by

youth. Consumer product safety data show that persons under age 16 were the victims in 35% of

all reported ATV-related deaths in the general population between 1985 and 1998 [Consumer

Product Safety Commission 2000]. Data on ATV-related deaths and injuries are available from

the Consumer Product Safety Commission. These data include injuries associated with work as

well as recreational use. ATV use was associated with an estimated 28,700 injuries of youth

under 16 treated in hospital emergency departments in 1999 [Consumer Product Safety

Commission 2000]. Risk of ATV-related injury for youth under 16 was 2.5 times that for

operators aged 16 to 34 years, and 4.5 times that for operators aged 35 to 54 years [Consumer
Hazardous Orders in Agricultural Occupations

85

A 10-year-old boy working with his father to

load bales of hay onto a wagon was severely

injured when the tractor on which he was a

passenger overturned. The boy’s father, who

was driving the tractor, attempted to stop a

runaway hay wagon by positioning the

tractor’s loader bucket in the path of the

wagon. As the wagon struck the loader

bucket, the tractor overturned, severely

crushing the boy’s arm under the tractor seat,

and fatally injuring his father [University of

Iowa 1995b].

Product Safety Commission 1998]. A 1997 survey found that use of ATVs for nonrecreational

activities such as farming or ranching has increased in recent years, and that 95.9% of ATV

operators under the age of 16 were driving ATVs with engines greater than 90 cc. These ATVs

are intended for use by adults, and are manufactured with labels warning against their use by

children [Consumer Product Safety Commission 1998]. The American Academy of Pediatrics

has recommended that states prohibit all use of ATVs by persons less than 16 years of age,

noting that the immature judgment and motor skills that hamper the ability of youth under age 16

to safely operate other motor vehicles are also relevant to ATV operation by youth [American

Academy of Pediatrics 2000].

HO 7 Is Inconsistent with Many State Motor Vehicle Licensing Laws

HO 7 is inconsistent with many state licensing laws in that it prohibits driving when transporting

passengers, but does not otherwise prohibit driving. In 43 states, it is possible to obtain a

learner’s permit before age 16; however, a driver’s license (with and without intermediate

restrictions) can be obtained in only five of these states before age 16 [Insurance Institute for

Highway Safety 2001]. HO 7 does not explicitly prohibit motor vehicle operation by youth who

in many states are not old enough to obtain full driving privileges under their state licensing

laws. To be consistent with minimum requirements of state licensing laws, HO 7 should be

revised to prohibit agricultural workers under age 16 from operating a motor vehicle on the

highway. 

Substantial numbers of fatalities were also identified as occurring off the highway among

agricultural workers of all ages. While there would be some overlap between HO 7 and state

licensing laws if HO 7 were expanded to prohibit all highway driving for agricultural workers

under age 16, child labor laws provide the only means of addressing hazards associated with

driving and other vehicle-related tasks off the highway. There is no evidence to suggest that offhighway driving or work as an outside helper should be permitted for youth; there were 80 such

fatalities among workers of all ages over a 6-year period, four of which were among youth

younger than 16. Work as an outside helper on a motor vehicle is of particular concern. This is

now prohibited for youth under 18 under

nonagricultural HO 2, but no similar

protections for youth under 16 exist in

agricultural HO 7. 

Fatalities and Injuries of Agricultural

Workers Who Were Tractor Passengers

Have Also Been Reported

Of the 1,421 tractor-related fatalities to

agricultural production workers identified

by CFOI for 1992-1997, 12 of the

victims were clearly riding on a tractor as

a passenger [NIOSH 2001c]. There are a

number of other cases in which injury
Hazardous Orders in Agricultural Occupations

86

circumstances suggest the worker may have been a passenger on the tractor, but the CFOI

narrative does not specifically mention it. CFOI identified a total of 27 tractor-related fatalities

of agricultural workers younger than age 16 during 1992-1997 (see discussion under agricultural

HO 1, page 51), but did not identify enough cases involving tractor passengers under age 16 to

meet BLS reporting thresholds [NIOSH 2001d]. Nonfatal injuries to youth associated with this

situation have been reported: in 1998, an estimated 417 injuries were incurred by youth under

age 16 while riding as a passenger on a farm tractor [NIOSH 2001l].

Inclusion of Work on Tractors Under Agricultural HO 7

Other agricultural work involving operating tractors and connecting or disconnecting

implements is covered under agricultural HO 1. Prohibitions against riding on a tractor as a

passenger or outside helper should also be addressed under HO 1. There are three distinct

advantages to this change: (1) all work activities associated with tractor operation would be

addressed under a single HO; (2) HO 7 would be more clearly focused on hazards of motor

vehicle operation, and could more easily be modified to align with nonagricultural HO 2; and (3)

Wage and Hour inspectors would find it easier to enforce both agricultural HO 1 and HO 7.

HO 8: Working Inside:

i) A fruit, forage, or grain storage designed to retain an oxygen deficient or toxic

atmosphere;

ii) An upright silo within 2 weeks after silage has been added or when a top

unloading device is in operating position;

iii) A manure pit; or

iv) A horizontal silo while operating a tractor for packing purposes

Recommendation – Expand the HO to prohibit all work inside (i) a fruit, forage, or grain storage,

such as a silo or bin; (ii) a manure pit.

Rationale – Work in silos, bins and manure pits presents hazards in many forms: grain

engulfment; exposure to silo gas; and oxygen deficiency. The current HO is not comprehensive

enough in addressing these hazards. Work in silos and grain bins poses substantial risk of

engulfment. Given this hazard, it is recommended that the HO be expanded to prohibit work

inside all types of fruit, forage, or grain storage facilities, not just those designed to retain toxic

or oxygen-deficient atmospheres. Further, although the HO provides for a 2-week waiting

period to protect youth from entering a storage facility soon after new silage has been added,

toxic gases may be present at any time in these locations. Therefore, the removal of the 2-week

waiting period is also recommended. Manure pits also produce toxic atmospheres which can

overcome a worker in a very short period of time, and often result in multiple fatalities. The

hazards presented by manure pits justify their being retained in the HO. 

Grain Engulfment Associated with High Numbers of Deaths 
Hazardous Orders in Agricultural Occupations

87

In 1995, a 13-year-old male died of injuries

sustained after he was engulfed in corn inside

a steel grain bin. The youth had been seated

on the roof ladder of the bin observing corn

being removed from the bin through an

opened roof cover. The youth fell into the

bin unnoticed. It was not known that he was

in the bin until a tennis shoe came out of the

discharge opening. Emergency personnel

arrived on the scene and used power saws to

cut several holes into the bin. The youth was

removed and transported to the hospital

where he died two days later [Minnesota

Department of Health 1995].

Suffocation in flowing grain is the most

common cause of death associated with grain

storage structures in the U.S. [CDC 1996b]. 

Hazards exist either when the grain is being

unloaded or loaded, or when workers fall into

an air pocket under a crust of grain. Grain

that flows during loading and unloading has

characteristics of quicksand and can rapidly

induce immersion [CDC 1996b]. A worker

can be completely submerged in flowing

grain in less than 8 seconds [CDC 1996b;

Shutske 1999]. Suffocation can also occur if

a worker enters a grain bin containing caked,

frozen, or spoiled grain. When such grain is

unloaded from below, an overlying crust

forms which can collapse under the weight of

a person standing or walking on the crust [CDC 1996b].

Silo Gas Another Hazard Associated with Silos and Grain Bins: Silo Filler’s Disease 

After a silo is filled with chopped silage, a natural fermentation process takes place which

produces several harmful gases. The predominant gases formed are carbon dioxide (CO2) and 

oxides of nitrogen, which are heavy gases that will displace oxygen in a closed silo. This, in

addition to oxygen depletion by microbial activity in silage, can cause the oxygen concentration

in a silo to become low enough to cause suffocation and death [Pavelchak et al. 1999; NIOSH 

1994b]. 

The nitrogen oxides formed include: nitrogen dioxide (NO2), the most lethal; nitrous oxide (N2O)

which is easily oxidized to NO2; and nitrogen peroxide (N2O4), which has similar toxic effects as

NO2, but is colorless and odorless. Nitrogen dioxide is directly toxic to the lungs by forming

nitrous and nitric acids and causing burns to the small airways and alveoli. This causes a

syndrome known as “Silo Filler’s Disease” which may lead to Adult Respiratory Distress

Syndrome (ARDS) and death. The amount of acid formed and the severity of lung injury are

directly related to the concentration of NO2 [Wright 1989; CDC 1982]. Nitrogen dioxide levels

begin to increase within four hours after filling. Although nitrogen dioxide levels are generally

within a safe range after two weeks, dangerous amounts may remain for months if the silo has

not been opened [CDC 1982]. 

Manure Pits Present High Risk

Manure pits are fermentation tanks in which raw animal waste undergoes anaerobic bacterial

decay [CDC 1989]. Manure pits allow for easy cleaning of animal confinement buildings and

the efficient underground storage of large amounts of raw manure [NIOSH 1990a]. Four main
Hazardous Orders in Agricultural Occupations

88

gases are produced in manure pits: hydrogen sulfide, methane, ammonia, and carbon dioxide. 

Hydrogen sulfide is considered the most dangerous because it is highly toxic and is rapidly

released during agitation and pumping. Methane is continuously produced and released into the

air at a steady rate. Methane gas displaces oxygen in the closed environment of a manure pit

creating an oxygen-deficient, flammable, and explosive atmosphere [Doss et al. 1993]. Deaths

in manure pits can result either from oxygen deficiency or from the direct toxic effects of these

four gases [CDC 1993b]. The warmer, more humid weather that occurs during the summer

months accelerates the production and accumulation of hazardous gases [NIOSH 1993b; CDC

1993b]. Farm workers should be particularly aware of the hazards of entering pits during the

summer when conditions are optimal for increased gas generation [CDC 1993b]. The increased

risk during the summer months is particularly troublesome given the fact that most youth are

employed as farm workers during that time.

Multiple Fatalities are Common in Silos, Bins, and Manure Pits

Incidents in silos, bins or manure pits often result in multiple fatalities when co-workers or

others die during attempts to rescue initial victims [CDC 1993b; NIOSH 1993b; NIOSH 1990b]. 

Often after a worker enters an oxygen-deficient or toxic atmosphere and collapses, co-workers

notice the collapsed worker and enter the same atmosphere to attempt rescue; if they do not use

proper precautions they also collapse. From 1982-1992, NIOSH FACE investigated 68 confined

space incidents of all types resulting in 104 fatalities; 38% of the fatalities occurred during a

rescue attempt [CDC 1993b].

Many Hazards Exist in Silos, Bins, and Manure Pits

A review of CFOI, 1992-1997, identified 91 fatalities in agricultural production associated with

entering a silo, grain bin, or manure pit (Table 26) [NIOSH 2001c]. One hundred and eight

cases were identified by OIICS event codes for caught in or crushed in collapsed materials

(0400, 0490), other cave-ins (0420), inhalation in enclosed, restricted or confined space (3411),

depletion of oxygen from cave-in or collapsed materials (3830), depletion of oxygen in other

enclosed, restricted, or confined space (3840), and other oxygen deficiency (3890). A review of

the narratives for these cases identified the 91 cases which were associated with entering a silo,

grain bin, or manure pit. Over 60% of the fatalities occurred in grain bins, 25% in silos, and

13% in manure pits. Sixty-five percent of the deaths were due to grain engulfment, with the

remainder attributable to asphyxiation either due to oxygen deficiency or a toxic atmosphere. 

Four of the fatal incidents resulted in multiple deaths when a co-worker attempted rescue.
Hazardous Orders in Agricultural Occupations

89

Table 26. Deaths Associated with Work in Silos, Grain Bins, and Manure Pits, United States

Event [OIICS Event Code] Deaths,

1992-1997

Caught in or crushed in collapsing materials,

n.e.c. [0490]

59

Inhalation in enclosed, restricted, or confined

space [3411]

24

Depletion of oxygen in other enclosed, restricted,

or confined space [3840]

6

Other 2

Total 91

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]

Youth Agricultural Workers Also at Risk

CFOI (1992-1997) identified 8 fatalities in agricultural production to youth less than 16

occurring in either a silo, bin, or manure pit [NIOSH 2001d], the majority of these were from

grain engulfments. CAIS data for 1998 estimated 1470 non-fatal injuries to youth less than 16

from silos or grain bins [NIOSH 2001l]. An estimated 1250 of the injuries required admission to

a hospital, with an average hospital stay of 6 days.
Hazardous Orders in Agricultural Occupations

90

HO 9: Handling or Applying (including Cleaning or Decontaminating Equipment, Disposal

or Return of Empty Containers, or Serving as a Flagman for Aircraft Applying)

Agricultural Chemicals Classified Under the Federal Insecticide, Fungicide, and

Rodenticide Act (as Amended by Federal Environmental Pesticide Control Act of 1972, 7

U.S.C. 136 et seq.) as Toxicity Category I, Identified by the Word “Danger” and/or

“Poison” with Skull and Crossbones; or Toxicity Category II, Identified by the Word

“Warning” on the Label

Recommendation—Revise the HO to be consistent with EPA Worker Protection Standard for

pesticides. Any future changes to the EPA standards which either enhance protections for all

workers or add an additional margin of safety for children should also be reflected in the HO.

The following wording is suggested: Performing any tasks that would fall under the EPA

definition of "pesticide handler,” in 40 CFR Part 170 - The Worker Protection Standard. The

definition of “pesticide handler” as written in the Worker Protection Standard can be found on

page 91 of this report.

Rationale—The current HO only addresses exposures of farm workers under age 16 to Toxicity

Category I and II pesticides, which are of concern because of their acute toxicity. There is no

protection against other chronic hazards of pesticides, such as their potential neurotoxicity,

reproductive toxicity, endocrine disruption, and carcinogenic effects. The EPA’s Worker

Protection Standard was designed to protect workers from acute and chronic exposures to

pesticides. The HO to protect young agricultural workers from the hazardous effects of pesticide

exposure should, at a minimum, be consistent with the EPA standard. 
Hazardous Orders in Agricultural Occupations

91

40 CFR Part 170 - The Worker Protection Standard

This part of the Code of Federal Regulations (CFR) addresses workers’ and pesticide

handlers’ occupational exposures to pesticides used in the production of agricultural plants

on farms or in nurseries, greenhouses, and forests. Workplace practices required by the

Standard are designed to reduce the risks of pesticide-related illness or injury by reducing or

eliminating exposure to pesticides.

According to this regulation, a “pesticide handler” is defined as any person, including a

self-employed person: 

(1)Who is: 

(i) Mixing, loading, transferring, or applying pesticides. 

(ii) Disposing of pesticides or pesticide containers. 

(iii) Handling opened containers of pesticides. 

(iv) Acting as a flagger. 

(v) Cleaning, adjusting, handling, or repairing the parts of mixing, loading, or

application equipment that may contain pesticide residues. 

(vi) Assisting with the application of pesticides. 

(vii) Entering a greenhouse or other enclosed area after the application and before

the inhalation exposure level listed in the labeling has been reached or one of the

ventilation criteria established by this part ( § 170.110(c)(3)) or in the labeling has

been met: 

(A) To operate ventilation equipment. 

(B) To adjust or remove coverings used in fumigation. 

(C) To monitor air levels. 

(viii) Entering a treated area outdoors after application of any soil fumigant to

adjust or remove soil coverings such as tarpaulins. 

(ix) Performing tasks as a crop advisor: 

(A) During any pesticide application. 

(B) Before the inhalation exposure level listed in the labeling has been

reached or one of the ventilation criteria established by this part (§

170.110(c)(3)) or in the labeling has been met. 

(C) During any restricted-entry interval. 

(2) The term does not include any person who is only handling pesticide containers that have

been emptied or cleaned according to pesticide product labeling instructions or, in the

absence of such instructions, have been subjected to triple-rinsing or its equivalent. 
Hazardous Orders in Agricultural Occupations

92

Pesticide Use in Agriculture

Pesticides are defined by the Federal Insecticide, Fungicide, and Rodenticide Act (7 USC 136) as

“any substance or mixture of substances intended for preventing, destroying, repelling, or

mitigating any insects, rodents, nematodes, fungi, or weeds or any other forms of life declared to

be pests; any substance or mixture of substances intended for use as a plant regulator, defoliant

or desiccant.” Pesticides are extensively used in U.S. agricultural production, amounting to

about 4.5% of total farm production costs. In 1997, over 1.2 billion pounds of active ingredient

were used and included over 20,700 products and more than 890 active ingredients [Aspelin and

Grube 1999].

Tasks Involving Risk of Exposure to Pesticides

The following tasks involving handling or applying pesticides put workers at risk for hazardous

exposure: 

• Mixing, loading, transferring, or applying pesticides

• Disposing of pesticides or pesticide containers

• Handling opened containers of pesticides

• Acting as a flagger for aerial applications

• Cleaning, adjusting, handling, or repairing the parts of mixing, loading, or application

equipment that may contain pesticide residues 

• Assisting with the application of pesticides

• Entering a greenhouse or other enclosed area after the application

• Entering a treated area outdoors before expiration of the restricted-entry interval

 [40 CFR 170 - The Worker Protection Standard; Wilk 1993]

National Estimates of Pesticide-Related Fatalities

The most recent national estimates of unintentional deaths due to pesticides, where data were

extracted from death certificates and validated by physicians or coroners, were in the 1970's. Of

the 113 unintentional pesticide-related deaths in the two-year period 1973-1974, 11% of the

deaths were classified as occupationally related and 27% of the deaths occurred to children

under 5 years of age [Blondell 1997]. Poison Control Center data from 1985 through 1992

revealed 40 deaths (3 occupational) due to pesticide exposure [Blondell 1997]. CFOI data from

the period 1992-1997 identified 9 pesticide-related deaths, which included intentional and

unintentional inhalation and ingestion of pesticides [NIOSH 2001c].

National Estimates of Pesticide-Related Illnesses

Estimates of the occurrence of pesticide-related illness in the U.S. have been made using a

variety of data sources. The U.S. EPA has extrapolated statistics from the state of California to

estimate physician-diagnosed pesticide illnesses and injuries among agricultural workers in the
Hazardous Orders in Agricultural Occupations

93

U.S. at 10,000-20,000 annually [Blondell 1997]. California maintains the most reliable reporting

system for occupationally related pesticide poisonings [GAO 1995]. Potential occupational

cases of pesticide poisoning are investigated by the local county agricultural commissioner and

reported to the state [Edmiston and Maddy 1987]. 

Based on NEISS data from 1990-1992, there were an estimated 20,000 (95% CI, 15,000-25,000)

annual emergency department visits resulting from pesticide exposure [Blondell 1997]. 

Emergency department data will only capture injuries severe enough in the mind of the injured

person to require emergency department treatment. It has been estimated that only about 34% of

injuries and illnesses occurring in the workplace are initially treated in an emergency department

[CDC 2001a]. 

The American Association of Poison Control Centers Toxic Exposure Surveillance System

which collects data from 65 participating poison control centers, representing an estimated

95.3% of human poison exposures in the U.S. in 1998, revealed 86,289 human poison exposure

cases due to insecticides, pesticides, or rodenticides during 1998. Of these reported cases,

46,447 were children under 6 years of age and 14,436 were between 6 and 19 years of age

[Litovitz et al. 1999]. 

A recent study examined pesticide poisoning among working children using data from statebased surveillance systems (data were available from 1988-1999) and Poison Control Center

data from the Toxic Exposure Surveillance System (data were available from 1993-1998)

[Calvert 2001]. A total of 531 children under age 18 years were identified to have acute

occupational pesticide-related illness. Between 1993 and 1998, the overall incidence rate was

found to be 1.71 times that observed in working adults aged 25-44 years (95%CI=1.53, 1.91). It

was estimated that 62% of the cases were children employed in agriculture production and

services (BOC codes 010 [agricultural production, crops], 011 [agricultural production,

livestock], 012 [veterinary services], 020 [landscape and horticultural services], and 030

[agricultural services, n.e.c.]) and 32% were employed in other industries. Of the 81% of cases

where the EPA acute toxicity category was available, 67% of the illnesses were associated with

toxicity category III pesticides, which are not covered under the HO as currently written.

The above numbers may greatly underestimate the true incidence of pesticide-related illness. 

Based on two household surveys conducted in California in 1969 and in 1973, Kahn estimated

that the number of officially reported cases of pesticide-related illness is only about 1-2% of the

true number [Kahn 1976]. Applying this estimate nationally, Coye [1985] estimated that the

“true” prevalence of pesticide-related illness cases was about 313,300 (1% of an estimated 4

million farm workers) during 1982. 

Acute Health Effects of Pesticide Exposure
Hazardous Orders in Agricultural Occupations

94

Pesticide poisoning incidents have been

documented among California farm workers

aged 9-19, and often have required medical

treatment and lost work time. One incident

involved 23 farm workers, including 2 young

farm workers aged 9 and 11, who were

exposed to two Toxicity I pesticides

mevinphos (Phosdrin) and phosphamidon

(Dimecron). Workers experienced severe

symptoms of poisoning, and some were

hospitalized for observation and treatment. 

Cholinergic symptoms abated within four

weeks, while headaches, weakness, blurred

vision, and anorexia were more persistent

throughout the 18 weeks workers were

studied. The two young workers experienced

adverse effects such as nervousness and sleep

disorders for considerably longer periods

after exposure to these neurotoxic pesticides

[Midtling et al. 1985; Coye et al. 1987]. 

Acute effects of pesticide exposure vary by type of pesticide. The majority of pesticide

poisonings are caused by organophosphates. This type of pesticide works in both pests and

humans by inhibiting the enzyme acetylcholinesterase, which normally breaks down the

neurotransmitter acetylcholine (ACH). ACH is a neurotransmitter present in many organ

systems of the body and is required to

transmit impulses between nerve cells and to

provide vital communication between

systems. When acetylcholine is not broken

down concentrations increase in the

intercellular spaces, leading to symptoms of

nervous system hyperactivity, neuromuscular

paralysis, and central nervous system

dysfunction (cholinergic effects). Examples

of these symptoms include: 

• blurred vision caused by eye muscle

contraction; 

• tearing, salivation, nausea, vomiting,

pulmonary edema, urination, and

perspiration caused by stimulation of

secretory endocrine glands; 

• cardiac arrhythmias caused by impaired

impulse conduction to the heart; 

• constriction of the bronchial airways

caused by smooth muscle contraction; 

• cramps, weakness, and paralysis caused by

skeletal muscle contraction; 

• headache, dizziness, malaise,

hallucinations, convulsion, depression and

loss of consciousness, and respiratory drive depression caused by central nervous system

excitation followed by depression. 

Symptoms of acute exposure to other types of pesticides vary depending on the type of pesticide. 

Carbamates have similar anticholinergic effects as organophosphates. Acute exposure to

organochlorine insecticides causes symptoms of central nervous system excitation, including

excitability, dizziness, disorientation, paresthesias, tremors, and convulsions. Fumigants and

nematocides cause symptoms of respiratory irritation and central nervous system depression.

Substituted phenols interfere with a fundamental cellular energy production process (oxidative

phosphorylation) which causes systemic effects such as fever, increased heart and respiratory

rate, high blood pressure, anxiety, and seizures. Acute exposure to other types of pesticides

cause effects of varying severity [Rosenberg 1990].

Chronic Health Effects of Pesticide Exposure

Evidence suggests that the majority of pesticide-related illnesses are chronic rather than acute

[Coye 1985], but little is known about the extent and magnitude of chronic health problems
Hazardous Orders in Agricultural Occupations

95

related to occupational exposures to pesticides [NRC/IOM 1998; NRC 1993]. Serious chronic

and delayed effects include chronic dermatitis, sterility, adverse reproductive outcomes, blood

disorders, abnormalities in liver and kidney function, and chronic neurotoxicity [Rosenberg

1990]. Low-level exposure to pesticides may produce nonspecific central nervous system

symptoms such as headache, fatigue, drowsiness, insomnia, and sleep disturbances, mental

confusion, disturbances of concentration and memory, anxiety, and emotional lability. There is

also evidence in adults that acute pesticide poisoning leads to chronic effects on neurologic

function [Steenland et al. 1994; Rosenstock et al. 1990; Savage et al. 1988]. Carcinogenicity of

pesticides to humans has not been proven conclusively. However, experimental studies have

shown that some pesticides can cause cancer in animals, and epidemiologic research has shown

associations with cancer in humans [Blair 1996]. The International Agency for Research on

Cancer [IARC 1987] considers some pesticides to be probable human carcinogens.

Special Risks to Young Workers

Health effects of pesticides have been largely unstudied with respect to young workers

[NRC/IOM 1998]. However, based on an extensive review of the literature and studies on

immature animals, the National Research Council [1993] concluded that the toxicity of

pesticides can potentially be influenced by the immaturity of biochemical and physiological

functions and body composition of developing children and adolescents. There is age-related

variation in susceptibility to pesticides, based on different metabolic rates and ability to activate,

detoxify and excrete xenobiotic compounds, and both qualitative and quantitative differences in

toxicity of pesticides between children and adults. 

Guillette et al. [1998] studied two groups of 4- to 5-year-old children residing in northwestern

Mexico, who had similar genetic backgrounds, diets, water mineral contents, cultural patterns,

and social behaviors. One group lived in an agrarian environment (n=33) where pesticides had

been used since the 1950's. The other group (n=17), lived in the foothills where traditional

methods for controlling pests did not include pesticides. The children exposed to pesticides had

significantly less stamina, gross and fine eye-hand coordination, and cognitive ability, as

measured by the ability to draw a person. Some studies suggest chronic effects of pesticide

exposure in children, including attention deficit disorders, decrease in stamina, gross and fine

eye-hand coordination [Weiss 1997; Harmon et al. 1975]. 

The US EPA recently cancelled many uses of three highly toxic pesticides, methyl parathion,

chlorpyrifos, and azinphos methyl because they posed unreasonable risk to children

(neurorotoxic and neurodevelopmental). This determination is required under the Food Quality

Protection Act of 1998, but has been done for only a few pesticides to which children and

adolescents are exposed and never to determine unreasonable risks to farm workers under age

18. The EPA is completing a hazard assessment of all organophosphates to determine the

developmental and reproductive toxicity of these pesticides for enhanced susceptibility of infants

and children [EPA 1998a]. Many pesticides in current and past use have not been tested for all

endpoints of concern, and pesticide studies conducted to date are designed primarily to assess

pesticide toxicity in sexually mature animals, not developing children and adolescents

[NRC/IOM 1998, NRC 1993].
Hazardous Orders in Agricultural Occupations

96

HO 10: Handling or Using a Blasting Agent, Including but Not Limited to, Dynamite,

Black Powder, Sensitized Ammonium Nitrate, Blasting Caps, and Primer Cord

Recommendation – Retain the HO.

Rationale – Explosives are used in agriculture for a variety of purposes, such as stump or rock

removal, to facilitate the building of a farm pond, or demolition of a farm structure. The use of

explosives opens up the potential for catastrophic events, such as fires and explosions, and has

the potential for multiple-victim incidents. Although available data do not identify explosiverelated fatal and nonfatal injuries in agricultural production associated with the items listed in

HO 10, clearly this type of activity presents a substantial hazard to workers exposed to the use of

blasting agents. Retaining this HO would be consistent with the nonagricultural HO prohibiting

work in the manufacture and storage of explosives (HO 1, page 21). Therefore, it is

recommended that HO 10 remain in place.

Scarcity of Data on Blasting Agent Use in Agricultural Production

A review of CFOI data for the years 1992-1997 identified 63 deaths in agricultural production

associated with fires and explosions. However, there were no deaths in agricultural production

associated with the use of blasting agents as listed in HO 10. The most common source of

explosion resulted from workers welding on tanks or equipment (22%) followed by

propane/gasoline explosions (16%), and explosions related to overfilling tires or tanks with air

(13%) [NIOSH 2001c].

Hazards Associated with Use of Blasting Agents

The lack of fatal and non-fatal injury data does not imply that the use of such blasting agents

should be permitted for youth under the age of 16. The inherent danger associated with the use

of explosives, coupled with the potential for catastrophic results when explosives are used

improperly, warrant enough concern to retain the current HO. Such hazards are described in the

discussion of nonagricultural HO 1 (see page 21). 
Hazardous Orders in Agricultural Occupations

97

HO 11: Transporting, Transferring, or Applying Anhydrous Ammonia

Recommendation—Retain the HO.

Rationale—Anhydrous ammonia is a toxic, corrosive chemical [EPA 1998b] which requires

strict handling, operating, and maintenance procedures to prevent hazardous exposure [ANSI

1999]. Any exposure to the chemical may cause severe injury or death. No data exist to support

any changes to the HO.

Anhydrous Ammonia is a Commonly Used Fertilizer

Anhydrous ammonia (ammonia without water) is an inexpensive chemical used commonly in

agriculture as a fertilizer [Helmers et al. 1971]. Above its boiling point of minus 28 degrees

Fahrenheit, it is artificially kept in a compressed liquid state at high pressure for ease of

transport, storage, and application [Johnson 1975]. Tanks are pulled by tractors and ammonia is

sprayed directly onto fields. Exposures can occur during spraying or during connection and

disconnection of spraying equipment [Shaver and Tong 1991]. 

Exposure to Anhydrous Ammonia May Cause Severe Burns and Death Due to Suffocation

Anhydrous ammonia can cause severe burns and death due to its powerful corrosive action on

tissue. Inhalation of high concentrations causes death due to bronchoconstriction, edema, and

inflammation of the airway walls [EPA 2000; Leduc et al. 1992; Sharp 1965]. Exposure to

lower concentrations for longer periods can also be fatal as the gas reaches deeper parts of the

lung. Chronic fibrosis of the lung may occur if the victim survives the initial insult. Direct

contact with the ammonia in liquid form causes severe burns to skin and mucous membranes. 

Due to its high water solubility and alkalinity, it causes necrosis of the tissue and can penetrate

deeply. Severe corneal burns may result from contact with the eyes. If contact occurs as

anhydrous ammonia liquid escapes from a container, vaporization can cause freezing burns of

the skin and eyes due to rapid heat loss [Shaver and Tong 1991].

National and State Data on Injuries, Illnesses, and Deaths Due to Anhydrous Ammonia

Eight fatalities were identified in CFOI during the six-year period 1992-1997 related to work

with anhydrous ammonia [NIOSH 2001c]. The majority of the cases were due to exposure to

anhydrous ammonia gas. Explosions involving anhydrous ammonia were also identified. 

During 1997, injuries and illnesses where the source was identified as anhydrous ammonia

resulted in a median of 20 days away from work; 66% of the 88 cases resulted in more than 10

days away from work [BLS 1999b]. The Iowa State University Extension reported that between

1990 and 1992, 55 Iowans were injured in incidents involving anhydrous ammonia, 19 of which

required hospitalization for burns, loss of eyesight, and respiratory problems [Schwab et al.

1993]. During 1985, one-third of all emergency department visits due to agricultural chemicals

in a 21-county area in Nebraska were caused by anhydrous ammonia fertilizer [Rettig et al

1987]. Other deaths and severe injuries caused by exposure to anhydrous ammonia have been

reported in the literature [EPA 2000; Leduc et al. 1992; Sobonya 1977; Johnson 1975; Kass et al.
Hazardous Orders in Agricultural Occupations

98

1972; Helmers et al. 1971].

Requirements for the Safe Storage and Handling of Anhydrous Ammonia

Because of the dangerous properties of anhydrous ammonia, a national standard exists for safe

storage, transportation, and handling of the chemical [ANSI 1999]. According to the standard,

only properly trained personnel who are familiar with its physical properties should handle

anhydrous ammonia. Because it must be stored at high pressure, any leak will cause the

ammonia to spray and quickly vaporize. Anhydrous ammonia quickly reacts with any moisture,

including moisture in skin and mucous membranes, causing severe dehydration, cell destruction,

and chemical burns. Handlers of anhydrous ammonia must wear appropriate personal protective

equipment, including eye protection such as tight-fitting, chemical-proof goggles or an approved

full-face respirator. Proper use of specially approved equipment must be followed [ANSI 1999;

Shutske 1994]. In the event of an emergency, handlers should be able to act by shutting off the

flow of gas and coordinating evacuation. Youth should not be given the heavy responsibility of

following these complex procedures which, if not followed, could be fatal or severely

debilitating to themselves and any others nearby. 
99

V. RECOMMENDATIONS FOR NEW HAZARDOUS ORDERS

The following recommendations address serious occupational health and safety hazards for

young workers under age 18 that are not covered by the current Hazardous Orders. DOL should

be able to implement these proposals though the administrative rule-making process without any

new statutory authority.

Non-Agricultural Occupations

Commercial Fishing Occupations

Recommendation – Establish a new HO for work in commercial fishing occupations. An

apprentice/student learner exemption is not recommended.

Rationale – Workers in commercial fishing occupations have extremely high rates of

occupational fatality, with similarly high fatality rates among fishers younger than age 18. 

Fishers work in a highly unpredictable environment and face numerous risks for fatality or

serious injury. Many of the injury risks, particularly those related to weather, are not

substantially reduced or eliminated through training or experience, therefore an

apprentice/student learner exemption is not justified.

Commercial Fishers Have Extremely High Fatality Rates

The substantial risk of fatality associated with work in commercial fishing occupations

worldwide has been reported in the scientific literature for decades [Bell et al. 1990; CDC

1993c; CDC 1994; Driscoll et al. 1994; Lincoln 2000; NIOSH 1997e; NIOSH 1994c; National

Transportation Safety Board 1987; Reilly 1985; Schilling 1971]. During 1992-1997, CFOI

identified 440 fatalities of U.S. workers in fishing occupations, which include fishers (BOC

occupation code 497) and captains and other officers on fishing vessels (BOC occupation code

498) [NIOSH 2001c]. The 6-year fatality rate of 161.1 per 100,000 workers was the highest

among all occupations, exceeding the rate of 148.2 among logging occupations (BOC occupation

code 496) for the same period. Fishing, hunting, and trapping occupations had the second

highest lifetime risk of occupational fatality for 1990-1991, with 47.2 deaths per 1,000 45-year

working lifetimes [Fosbroke et al. 1997]. Other research found that male captains of vessels and

fishers were at substantial lifetime risk for fatality associated with a vessel sinking (38.2 and

24.3 deaths per 1,000 working lifetimes, respectively) [Myers et al. 1998b].

Of the 440 fatalities of fishers and other fishing vessel crew identified by CFOI between 1992-

1997, the predominant fatal events were water vehicle accidents (312 deaths, 70.9%) and

drownings (68 deaths, 15.5%) [NIOSH 2001c]. The remainder involved events such as contact

with electric current, being caught in running machinery, being struck by objects, and assaults. 

Fatalities have also occurred during harvesting of sea urchins and sea cucumbers, which is

usually done by hand by divers using scuba equipment [CDC 1994; Lincoln 2000].

Work in Commercial Fishing Occupations Occurs in a Complex, Unpredictable Environment

Work in commercial fishing poses substantial risk of fatality from a variety of sources. Fishers
Recommendations for New Hazardous Orders

100

In 1993, a 16-year-old commercial fisherman

became trapped and drowned after the fishing

vessel he was on capsized while under tow. 

The vessel was disabled and at anchor, with

only the skipper and the youth on board. 

After 11 hours, another vessel arrived and

began to tow the fishing vessel back to port. 

Within 2 minutes after towing began, the

vessel capsized, trapping the 20-year-old

skipper and the youth inside the pilot house. 

The skipper escaped and swam to safety, but

efforts to rescue the youth were unsuccessful

[NIOSH 1993c].

are exposed to hazards of drowning, falling overboard, vessel losses due to capsizing or

foundering, vessel collisions, fires and explosions, machinery-related incidents, and hypothermia

[Driscoll et al. 1994; NIOSH 1997e; Reilly 1985]. Among the numerous factors that have been

linked to fatalities among fishers and other crew are: economic pressures from brief fishing

seasons; fatigue; delays in rescue efforts due to the isolated locations of some fishing grounds;

lack of safety training requirements for commercial fishers; unpredictable and severe weather

conditions; nonuse of personal flotation devices; crew inexperience; lack of seaworthiness of

vessels; and slippery and unstable work surfaces [Driscoll et al. 1994; NIOSH 1997e; NIOSH

1994c; National Transportation Safety Board 1987; Reilly 1985; Schilling 1971]. 

Nonfatal Injuries and Illnesses Among Fishers Have Also Been Reported

There were an estimated 343 nonfatal injuries and illnesses requiring days away from work

among fishers in the U.S. in 1997. Although the number was small compared with other

occupations, these appear to have been of high severity. The median days away from work was

30, with 93.9% resulting in 21 or more days away from work [BLS 1999b]. Between 1991 and

1995, the Alaska Trauma Registry, which collects data on injuries requiring hospital admission

in Alaska, recorded 392 nonfatal injuries in the commercial fishing industry [Husberg 2000]. 

Fatalities and Nonfatal Injuries of Young Workers in Fishing Occupations

CFOI identified five fatalities of fishers

younger than age 18 between 1992 and

1997. The 6-year fatality rate per 100,000

FTE workers for ages 15-17 was 137.0. 

All five youth drowned when their fishing

vessel capsized, or when they fell from the

vessel [NIOSH 2001d; NIOSH 2001a]. 
Recommendations for New Hazardous Orders

101

Alaska Trauma Registry data for 1991-1998 included the following injuries to

fishers ranging in age from 11 to 17 years:

• Leg caught in seining line/ring on a purse-seiner, pinning fisher

against side of boat 

• Fisherman’s finger caught between a boat and a skiff.

• Arm caught in winch of fishing boat

• Multiple abdominal stab wounds during fight with another fisherman

• Foot caught in coil rope attached to seiner, dragging fisher against

skiff

• Tip of middle finger pulled off when gloved hand caught in coiled

rope, and rope was moved out 

The Alaska Trauma Registry identified a total of eight nonfatal injuries among fishers younger

than age 18 during 1991-1998 [Alaska Trauma Registry 2001]. 

Construction Occupations

Recommendation – Establish a new HO prohibiting all work in construction occupations as

defined by Bureau of the Census occupation codes 553-599, 866, and 869. An

apprentice/student learner exemption is not recommended.

Rationale – Workers in many of the construction trades have extremely high rates of

occupational injury fatalities, and sustain large numbers of nonfatal injuries, many of a severe

nature. Prohibiting work by youth in construction occupations, rather than in the entire

construction industry, has the advantage of protecting youth who may be asked to perform

construction tasks for non-construction employers. It also ensures continued opportunity for

youth to perform low-risk jobs such as clerical work in the construction industry. Despite a

number of existing HOs that address specific types of hazardous construction work (such as

roofing and trenching), construction work accounts for a substantial number of young worker

deaths. The number of deaths of young workers in construction is exceeded only by the number

of deaths in agriculture, forestry, and fishing, and retail trades. Additionally, available data

suggest that youth working in the construction industry and occupations have elevated fatality

rates, and that rates for youth are more than twice those of young and middle-aged adults.

Several factors support the establishment of a construction-wide HO instead of an approach

focusing on individual trades and occupations within construction. Most of the occupations do

have elevated fatality rates. Construction work is also associated with adverse health effects

from exposure to hazardous substances and from musculoskeletal disorders. Some construction

occupations that have relatively low fatal injury rates are associated with exposure to other

agents which may have long-term health effects, and thus merit inclusion. Youth employed in
Recommendations for New Hazardous Orders

102

construction are more commonly employed as laborers and helpers and are not likely to have the

skills to be technically considered a member of any specific construction trade. In addition, jobs

with small construction firms or in residential construction are likely to cut across a multitude of

tasks and construction occupations. In summary, NIOSH suggests that any HO cover the entire

construction sector. 

Because construction sites frequently include hazards outside the control of individual workers

or contractors, an apprentice/student learner exemption is not recommended. 

Injuries and Fatalities Among Workers in the Construction Trades

Between 1992 and 1997, 5,298 workers in the specialized construction trades and in construction

laborer occupations died as a result of work-related injuries. Occupation-specific fatality rates

ranged from 1.9 per 100,000 workers for carpet installers to 85.9 for structural metal workers. 

In 10 of the 32 construction occupations, fatality rates were greater than 20 per 100,000 workers,

or more than 4 times the rate among all workers in all occupations [NIOSH 2001c; NIOSH

2001a, Table 27].

Additionally, a number of the occupations listed in Table 27 were among the 50 occupations

with the highest lifetime risks of fatal occupational injury in 1990-1991: structural metal workers

(4th); electrical power installers and repairers (8th); construction laborers (10th); roofers (16th);

construction supervisors, n.e.c. (20th); construction trades, n.e.c. (23rd); electricians (27th);

brickmasons and stonemasons (33rd); concrete and terrazzo finishers (34th); and plumbers,

pipefitters, and steamfitters (48th) [Fosbroke et al. 1997].

In 1997, workers in construction trades occupations experienced an estimated 179,035 nonfatal

injuries and illnesses requiring days away from work, nearly 10% of days-away-from-work

injuries in the U.S. that year. Excluding construction laborer occupations, the median days away

from work for all lost-time injuries and illnesses of construction trades workers was 8 [BLS

1999b].

Table 27. Fatal Injuries and Nonfatal Injuries and Illnesses to Workers in the Construction

Trades, United States

Occupation [BOC Code] Deaths,

1992-

1997

Deaths/100,000

Workers,

1992-1997

Nonfatal

Injuries and

Illnesses,

1997

Median

Days Away

from

Work, 1997

Supervisors, Construction

Occupations

Supervisors; brickmasons,

stonemasons, and tile setters

[553]

15 37.4 212 15
Recommendations for New Hazardous Orders

Occupation [BOC Code] Deaths,

1992-

1997

Deaths/100,000

Workers,

1992-1997

Nonfatal

Injuries and

Illnesses,

1997

Median

Days Away

from

Work, 1997

103

Supervisors, carpenters and

related workers [554] 

33 26.8 781 13

Supervisors, electricians and

power transmission installers

[555]

34 14.8 547 6

Supervisors; painters,

paperhangers, and plasterers

[556]

22 34.5 139 66

Supervisors; plumbers,

pipefitters, and steamfitters

[557]

20 21.6 366 11

Supervisors, n.e.c. [558] 420 12.2 5,905 7

Construction Trades, Except

Supervisors

Brickmasons and stonemasons

[563]

88 8.7 3,237 8

Brickmason and stonemason

apprentices [564]

--- --- 139 10

Tile setters, hard and soft[565] 7 2.1 544 16

Carpet installers [566] 12 1.9 1,353 8

Carpenters [567] 548 7.6 37,091 8

Carpenter apprentices [569] 5 10.6 770 5

Drywall installers [573] 43 5.1 5,219 15

Electricians [575] 541 13.7 17,748 7

Electrician apprentices [576] 30 17.8 2,423 6

Electrical power installers and

repairers [577]

237 35.8 2,799 9

Painters, construction and

maintenance [579]

264 8.7 6,665 10

Paperhangers [583] --- 2.3 780 11
Recommendations for New Hazardous Orders

Occupation [BOC Code] Deaths,

1992-

1997

Deaths/100,000

Workers,

1992-1997

Nonfatal

Injuries and

Illnesses,

1997

Median

Days Away

from

Work, 1997

104

Plasterers [584] 22 10.0 862 6

Plumbers, pipefitters, and

steamfitters [585]

205 7.3 12,967 8

Plumber, pipefitter, and

steamfitter apprentices [587]

12 15.3 1,913 3

Concrete and terrazzo finishers

[588]

52 12.1 1,842 8

Glaziers [589] 14 6.4 1,784 5

Insulation workers [593] 25 7.2 2,276 7

Paving, surfacing, and tamping

equipment operators [594]

23 43.3 236 12

Roofers [595] 326 28.9 6,100 9

Sheetmetal duct installers [596] 21 10.6 3,181 5

Structural metal workers [597] 264 85.9 4,214 13

Drillers, earth [598] 35 35.8 972 9

Construction trades, n.e.c.

[599]

251 21.7 4,039 10

Construction laborer

occupations

Helpers, construction trades

[866]

68 10.8 6,169 5

Construction laborers [869] 1,649 38.1 45,761 7

Total 5,293 --- 179,035 ---

Source: Census of Fatal Occupational Injuries (Deaths) and Survey of Occupational Injuries and Illnesses (Nonfatal

injuries) [NIOSH 2001c], Bureau of Labor Statistics [BLS 1999b]. Employment data used in the calculation of

fatality rates were obtained from the Current Population Survey [NIOSH 2001a]. Dashes indicate that no data were

available.

Fatalities of Young Workers Employed in the Construction Trades
Recommendations for New Hazardous Orders

105

In 1998, a 15-year-old roofer helper died after

falling 16 1⁄2 feet from a roof to a concrete

basement way. At the time of the incident, the

youth and a 16-year-old co-worker had been

removing shingles from the roof of a house. While

working to remove old shingles, the youth either

struck a bundle of new shingles with his body or

with the handle of a shovel. The bundle began to

slide toward the back edge of the roof. In

attempting to retrieve the bundle, the youth lost his

balance and fell off the back edge of the roof,

landing on his back and striking his head on the

concrete basement way. The 15-year-old youth

died the following day of a closed head injury

[NIOSH 1999c].

Between 1992-1997, CFOI identified

55 fatalities of workers under 18

employed in the specialized

construction trades or as construction

laborers. Thirty-five of the 55

(63.6%) were working as

construction laborers. Among all

youth ages 15-17 employed in the

construction trades and laborer

occupations, there were 24.6 deaths

per 100,000 FTE employees during

1992-1997. Among youth employed

as construction laborers, the fatality

rate was 42.3 [NIOSH 2001d; NIOSH

2001a]. A previous analysis of CFOI

data suggested that youth 15-17 years

of age working in construction had

greater than 7 times the risk for fatal

injury as youth in other industries, and greater than twice the risk of workers 25-44 years of age

working in construction [Barkume et al. 2000].

All but eight of the 55 fatally injured youth less than 18 years of age who died between 1992 and

1997 while working in construction occupations were employed in the construction industry:

seven (12.7%) in residential construction, eight (14.5%) in heavy construction, and 32 (58.2%)

by special trades contractors. Specific industries with the highest number of young worker

fatalities were roofing, siding, and sheet metal work (7); electrical work; and concrete work. 

The predominant fatal events were: falls (14, 25.5%); contact with electric current (14, 25.5%);

transportation incidents (11, 20.0%); and being struck by objects (9, 16.4%). 

Health Hazards in Construction

Work in construction may involve exposure to numerous substances with many possible adverse

health effects. Workers on construction sites, even those who do not work directly with

hazardous substances, may still be exposed as bystanders [Ringen et al. 1995]. Among the

substances that have been linked to occupational illness among construction workers are dusts

such as asbestos, cement, synthetic vitreous fibers, silica, and wood dust; dusts and fumes from

sources such as cadmium, lead, copper, zinc, and asphalt; and solvents and other chemicals such

as toluene, polyurethanes, epoxy resins, and methylene chloride. Among the conditions and

adverse effects that result from exposure to these substances (and have been linked to work in

construction) are: lead poisoning, asbestosis and other lung disorders related to exposure to

fibers, cancers, inhalation injury, asthma, chronic obstructive pulmonary disease, bronchitis,

contact dermatitis, silicosis, teratogenic effects, neurotoxic effects, and other chronic toxic

effects [Osorio and Melius 1995; NIOSH 1991a; NIOSH 1992b; NIOSH 2001m; Ringen et

al.1995; Ruhl and Kluger 1995; Sullivan et al. 1995]. Inhaled fibers are more dangerous than

other particles because they become trapped and are not cleared by the lungs. If they remain in
Recommendations for New Hazardous Orders

106

the tissue long enough, chronic irritation and inflammation can cause cells to mutate and become

cancerous [Elmes 1994]. 

Population studies have shown that work in construction occupations has been associated with

increased mortality due to chronic diseases and cancer. Based on death certificate data from the

National Occupational Mortality Surveillance System (1979-1990), significantly elevated

proportionate mortality ratios (PMRs) for cancer, mental disorders, pneumoconioses, asbestosis,

silicosis, chronic liver disease, and systemic sclerosis have been observed among men usually

employed in construction [Robinson et al. 1995]. Twenty of 64 preventable sentinel

occupational health conditions resulting from workplace exposures have been linked with

employment in a construction trade [Robinson et al. 1995; Mullan and Murthy 1991].

Construction workers are rarely based at the same work site for extended periods, thus the nature

and levels of their exposure to hazardous substances and environments may vary over time. 

Measuring exposure to harmful agents on construction sites is complicated by the mobility of

workers on individual construction sites, frequent changes in work sites and employers, logistics,

and limitations in measurement technology [Ringen et al. 1995]. Diagnosis of work-related

illnesses is complicated by long latency periods [Ringen et al. 1995; Sullivan et al. 1995]. It has

been suggested that the extensive movement of construction workers on the job site requires

workers to be more responsible for their own protection than in other work settings [Ringen et al.

1995]. If the construction work environment presents these challenges to workers of all ages, it

may pose greater dangers for young workers, who are likely to have less of the experience and

knowledge needed to recognize and respond to the variety of health and safety hazards present. 

Work in the construction trades has also been associated with morbidity and disability due to

musculoskeletal disorders. Construction work may involve manual handling of heavy materials,

static muscle contractions, exposure to vibration, repetitive motions, and awkward or strenuous

work postures or movements [Holmstrom et al. 1995; Ringen et al. 1995]. In 1997, construction

industry workers in the U.S. sustained an estimated 44,317 nonfatal injuries and illnesses

attributed to overexertion, 25,500 of which involved lifting, and an additional 2,806 injuries and

illnesses related to repetitive motion [BLS 1999b]. 

Work in certain construction trades may be associated with relatively low risk of fatal injury, yet

may present risk of adverse health effects or musculoskeletal disorders that is unacceptable for

workers under 18. Examples include low back pain and knee disorders among carpet and tile

layers [Engholm and Englund, cited in Holmstrom et al. 1995; NIOSH 1990c], asbestosis among

insulation workers [Sullivan et al. 1995]; exposure to lead and solvents among painters [Osorio

and Melius 1995; Ringen et al. 1995]; and exposure to silica among plasterers, drywall installers,

and other occupations [Lofgren 1993]. 

Work in Refuse Occupations

Recommendation – Establish a new HO prohibiting work in refuse collection. An

apprentice/student learner exemption is not recommended.
Recommendations for New Hazardous Orders

107

Rationale – Refuse collection workers have high rates of work-related fatalities, which are due

primarily to hazards related to traffic vehicles and refuse collection vehicles. Hazards of vehicle

operation and work as an outside helper are addressed by HO 2. However, youth employed as

refuse collection workers also risk injury as vehicle passengers, as pedestrians who move among

traffic vehicles while retrieving refuse, and from vehicle-mounted compacting equipment.

Workers in this occupation may also be exposed to toxic chemical and biological agents through

routine handling of waste materials, the hazards of which may not be readily apparent. No

apprentice/student learner exemption is recommended because of the high fatality rates and work

in environments frequently outside of the control of individual workers or supervisors. 

Fatal Injuries Among Refuse Collectors

CFOI identified 132 fatalities of refuse collectors between 1992-1997 [NIOSH 2001c]. The 6-

year fatality rate per 100,000 workers in this occupation was 47.3 [NIOSH 2001c; NIOSH

2001a]. The majority of fatally injured refuse collectors were employed in two transportation

industry sectors: refuse systems (SIC 4953, 69 deaths), and local trucking without storage (SIC

4212, 39 deaths). The remaining 22 deaths occurred among employees in public administration. 

The primary source of fatal injury for refuse collectors was most commonly a truck (97 deaths,

73.5%) or an automobile (10 deaths, 7.6%). Transportation-related events accounted for 105

(79.5%) of the deaths, and were predominantly related to: a vehicle striking a pedestrian on the

roadway or roadside [OIICS event codes 431 and 432] (43 deaths, 32.6%); a noncollision event

on the highway [OIICS event code 414] (25 deaths, 18.9%); other transportation events on the

highway [OIICS event codes 410-413 and 419] (13 deaths, 9.8%); and a vehicle striking a

pedestrian off the roadway [OIICS event code 433] (12 deaths, 9.1%). An additional eight

deaths involved workers becoming caught in or compressed by equipment or objects [OIICS

event code 03]; five of these resulted from the worker becoming caught in the compactor unit of

a refuse collection truck.

Nonfatal Injuries and Illnesses to Refuse Collectors

In 1997, refuse collection workers sustained an estimated 3,811 work-related injuries and

illnesses resulting in days away from work. The median days away from work was 10, with

18.5% of the injuries requiring 31 or more days away from work [BLS 1999b]. Overexertion,

particularly due to lifting, was reported to be the leading cause of nonfatal injuries to refuse

collectors between 1992 and 1997, accounting for nearly one-third of all cases [Drudi 1999]. A

study of municipal solid waste workers in Florida estimated that 57 of 100 workers incurred a

work-related musculoskeletal or dermal injury annually [Englehardt et al. 2000]. High numbers

of lacerations, contusions, fractures, vehicular injuries, and back injuries associated with lifting

were found in this worker population.

Refuse Collectors Face Multiple Vehicle-Related Injury Risks

Workers who collect and haul refuse are exposed to risk of injury from vehicle traffic while on

daily pickup routes. Refuse collection workers may ride on the outside of the vehicle to allow

them to more quickly retrieve refuse at stops along the route. Workers riding on the outside of
Recommendations for New Hazardous Orders

108

refuse collection vehicles are at risk of falling off the truck and being run over by the truck or

another vehicle. While retrieving refuse, they may also be backed over by the refuse collection

vehicle, or struck by a motorist [NIOSH 1997f; NIOSH 1982; Drudi 1999; Englehardt et al.

2000]. Refuse collection vehicles are also equipped with compactors which are similar in

function and operation to stationary compactors and balers already prohibited under HO 12, and

which pose similar risks for inadvertent activation, leading to crush and amputation injuries 

Refuse Collection Also Poses Health Hazards to Workers

Refuse collectors routinely handle materials of unknown origin which may contain hazardous

substances. These materials may be neither properly labeled nor acceptable for disposal through

conventional means, and the hazards they present may not be readily apparent to workers

[NIOSH 1982]. Workers in refuse collection, including those employed at landfills and transfer

stations, are exposed to toxic biological or chemical agents through direct contact (e.g., skin

contact, puncture or laceration of the skin, or ingestion) or through aerosol transmission. High

concentrations of airborne bacteria, dust, and fungal spores have been reported at landfills and

transfer stations [Poulsen et al. 1995]. These exposures have been linked with symptoms such as

pulmonary and gastrointestinal disorders, eye inflammation, irritation of the skin and mucous

membranes, and organic dust toxic syndrome among refuse collectors [Poulsen et al. 1995;

Englehardt et al. 2000]. 

Water Transportation Industries

Recommendation – Establish a new HO prohibiting work in water transportation industries. No

apprentice/student learner exemption is recommended.

Rationale – Fatality data show that work on or around shipping vessels and docks is associated

with large numbers of fatalities, high fatality rates, and nonfatal injuries resulting in substantial

lost work days. The water transportation industry ranks fifth in lifetime risk of fatal injury. Not

only are there obvious hazards such as drowning and ships capsizing and/or sinking associated

with work in this industry, but also less obvious hazards such as falls, and being struck by

shifting cargo or machinery. Work in water transport industries often occurs at sites outside the

control of individual workers or employers (for example multiple contractors and ships at ports),

and many of the injury risks are not likely to be substantially reduced or eliminated through

training and supervision, particularly those related to fatalities associated with ship worthiness

and the environment. For these reasons, no student/learner exemption is recommended for this

industry.

High Numbers and Rates of Fatal Injury Associated with Work in Water Transportation 

Merchant seamen are exposed to numerous hazards, including water, extremes of weather,

mechanical equipment, and toxic cargoes [Hansen 1996]. Studies in Sweden, Denmark, and

Iceland have shown an increased risk of injuries involving water transport and a high risk for

violent deaths, including suicide and homicide. Alcohol use was a contributing factor in many

of the fatalities [Hansen 1996; Rafnsson and Gunnarsdóttir, 1993, Larsson and Lindquist, 1992]. 
Recommendations for New Hazardous Orders

109

The lack of access to medical assistance in a timely manner is also a contributing factor to the

morbidity and mortality resulting from at-sea incidents [Hansen 1996].

The water transportation industry (SIC Code 44) ranked fifth in lifetime risk of fatal injury, with

16 deaths per 1,000 working lifetimes in 1990-1991. Further, water transport occupations (BOC

codes 828, 829, 833, and 834) ranked third in lifetime risk for fatal injury with 40 deaths per

1,000 working lifetimes in 1990-1991 [Fosbroke et al. 1997]. 

CFOI, 1992-1997, identified 377 fatalities in water transportation industries. Fifty-seven percent

of these occurred to workers in water transport occupations, such as ship captains, mates, sailors, 

deckhands, and marine engineers. An additional 10% of fatalities occurred to stevedores who

load and unload shipping vessels. Water vehicles, including barges, ships, and tugboats, were

the primary or secondary source of death in 45% of the cases. The most common fatality event

was water vehicle accidents (171) followed by oxygen deficiency (38), which was primarily

associated with drowning (Table 28). The fatality rate for workers in the water transportation

industry was 37.5 per 100,000 workers [NIOSH 2001c; NIOSH 2001a].

In 1997, workers in the water transportation industry sustained an estimated 7,107 nonfatal

injuries and illnesses requiring days away from work. These injuries and illnesses required a

median of 17 days away from work [BLS 1999b]. 
Recommendations for New Hazardous Orders

110

Table 28. Fatality Events Associated with Deaths in the Water Transportation Industry, United

States

Event [OIICS Event Code]

Deaths,

1992-1997

Water Vehicle Accident [45] 171

Oxygen deficiency [38] 38

Struck by [02] 38

Fall to lower level [11] 19

Pedestrian, nonpassenger struck by vehicle, mobile equipment [43] 18

Assaults [61] 12

Highway accident [41] 12

Contact with electric current [31] 11

Caught in or compressed by equipment or objects [03] 11

Exposure to caustic, noxious or allergenic substances [34] 10

Other 37

Total 377

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]

Work in Scrap and Waste Materials Industry

Recommendation – Establish a new HO prohibiting work in the scrap and waste materials

industry. An apprentice/student learner exemption is not recommended.

Rationale – The scrap and waste materials industry exposes workers to both injury and health

hazards. Workers in the scrap and waste materials industry have extremely high rates of

occupational injury deaths. Machinery and industrial vehicles were responsible for over half of

the deaths in this industry between 1992 and 1997. Although HO 2 addresses a portion of

vehicle-related injury risks for workers in this industry by prohibiting operation of motor

vehicles by youth under 17 years of age, vehicle-related injury risks in this industry extend to

pedestrian workers. The processing of scrap and waste materials also exposes workers to

dangerous levels of lead and polychlorinated biphenyls (PCBs). No student learner/apprentice

exemption is recommended due to the high lifetime risk of fatal injury and poor control of

hazardous exposures.

Fatalities Associated with Work in the Scrap and Waste Materials Industry 
Recommendations for New Hazardous Orders

111

The scrap and waste materials industry (SIC Code 5093) ranked 11th in lifetime risk of fatal

injury, with 7 deaths per 1,000 working lifetimes [Fosbroke et al. 1997]. CFOI, 1992-1997,

identified 187 fatalities in the scrap and waste materials industry (SIC 5093). Establishments

included in this industry are primarily engaged in assembling, breaking up, sorting, and

wholesale distribution of scrap and waste materials, including auto wreckers engaged in

dismantling automobiles for scrap. Almost half (44%) of the deaths were caused by contact

with objects and equipment, which included being struck by an object (42), and being caught in

or compressed by equipment or objects (36). Transportation accidents (40), fires and explosions

(24), and assaults and violent acts (21) were also associated with deaths in this industry (Table

29). In 22 of the 40 transportation accidents (55%), the fatally injured worker was struck by a

highway or railway vehicle. Vehicles (54) and machinery (44) were the most frequent primary

source of death. The fatality rate for workers in the scrap and waste materials industry was 15

per 100,000 workers [NIOSH 2001c; NIOSH 2001a].

Table 29. Fatal Events for Deaths in the Scrap and Waste Materials Industry (SIC 5093), United

States.

Event [OIICS event code]

Deaths,

1992-1997

Contact with objects and equipment [0] 83

Falls [1] 6

Exposure to harmful substances or environments [3] 13

Transportation accidents [4] 40

Fires and explosions [5] 24

Assaults and violent acts [6] 21

Total 187

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]

Health Hazards in Scrap and Waste Materials Industry

A study examining lead exposure in Washington State found scrap metal handling to be one of

the most commonly reported lead-exposed activities. Further, scrap metal dealers and recyclers

demonstrated the lowest use of industrial hygiene controls (4.7%) among lead-using employers

in the study [Nelson and Kaufman 1998]. Health Hazard Evaluations conducted by NIOSH have

discovered high lead and PCB exposures present in the scrap and waste materials industry

[NIOSH 1993d; NIOSH 1983; NIOSH 1991b] . Workers can be exposed not only from

contaminated soil, but also from dust within work areas and offices [NIOSH 1988a; NIOSH

1983]. The health effects of lead and PCBs are discussed on pages 59 and 133.
Recommendations for New Hazardous Orders

112

In 1988, a 17-year-old employee was

unloading a rail car filled with corn at a

commercial grain facility. He was found

about an hour later buried under the grain

with his legs sticking out from the bottom of

the car. The victim apparently climbed or

fell into the car [Freeman et al. 1998]

In 1988, a 17-year-old employee of a

commercial grain elevator was buried and

suffocated in milo inside a grain storage tank. 

The victim was standing near the draw-off

while two other employees brushed spoiled

grain from the sides of the tank. When a

fourth employee located outside of the tank

started the unloading equipment, the resulting

grain slide buried the victim near the drawoff [Freeman et al. 1998].

Farm Product Raw Materials Wholesale Trade Industry

Recommendation – Establish a new HO prohibiting work in the farm-product raw materials

wholesale trade industry (SIC 515). No apprentice/student learner exemption is recommended. 

Rationale – Workers in the farm-product raw materials industry have high rates of work-related

fatalities. Work in this industry presents a wide range of hazards, including grain entrapments,

rail and vehicle accidents, and contact with large animals. Many of the hazardous activities in

this industry are equivalent to tasks currently prohibited for youth working in other industry

sectors such as agricultural production. No apprentice/student learner exemption is

recommended due to the diversity of hazards in this industry.

Fatal and Nonfatal Injuries Associated with Work in the Farm-Product Raw Materials Industry

The farm-products raw materials industry

(SIC 515) had a lifetime risk of fatal

occupational injuries of 5.7 per 1,000

fulltime workers for the years 1990-1991

[Fosbroke et al. 1997]. CFOI, 1992-1997,

identified 86 fatalities among workers of all

ages in the farm-products raw materials

industry (SIC=515)[NIOSH 2001c]. This

industry had a fatality rate of 17.5 per

100,000 workers [NIOSH 2001c; NIOSH

2001a]. The farm-products raw materials industry includes grain elevators, grain and beans

wholesale markets, livestock auctions and wholesale markets, and other farm product wholesale

markets. The most common fatality events were being caught in or crushed in collapsing

materials (20%) most often grain or beans, followed closely by highway accidents (19%) which

usually involved tractor trailers. The most common primary source of deaths were trucks (23%),

grains (15%) and animals (9%). In 1997, an estimated 2,320 nonfatal injuries and illnesses

requiring days away from work were associated with work in the farm-product raw materials

industry. These injuries and illnesses required a median of 3 days away from work [BLS

1999b]. 

Health Hazards Associated with Work in

Wholesale Trade in Farm Product Raw

Materials

Similar to farmers and farm workers, workers

in the wholesale trade of farm product raw

materials, such as grains and livestock, are

exposed to a variety of organic and inorganic

dusts and substances associated with adverse 

health effects. Grain dust may contain many
Recommendations for New Hazardous Orders

113

substances, including vegetable products, insect fragments, animal dander, bird and rodent feces,

pesticides, microorganisms, endotoxins, and pollens. The most serious respiratory effects

associated with grain handling include farmer’s hypersensitivity pneumonitis (farmer’s lung),

silo filler’s disease (discussed on page 87), organic dust toxic syndrome, and other inflammatory

and asthma-like respiratory disorders. Farmer’s hypersensitivity pneumonitis, associated with

allergic sensitization to moldy grains or other dusts, may result in progressive, irreversible lung

disease [Kirkhorn and Garry 2000]. Organic dust toxic syndrome, sometimes called silo

unloaders disease and grain fever, is less well understood [Blanc 1999], but very common [Von

Essen et al. 1999]. It is an acute febrile illness, not associated with allergic sensitization or

progressive disease, which occurs soon after exposure to high amounts of endotoxin-containing

organic dust [Von Essen et al. 1999; Kirkhorn and Garry 2000]. 

A review of 5-years of workers’ compensation data in Washington State found wholesale trade

in farm product raw materials to have one of the ten highest incidence rates of occupational skin

disorders [Kaufman et al. 1998]. Other hazards to workers in this industry include exposure to

pesticides. Pesticides, in addition to being used on grain in the field, are also applied to

harvested grain during storage and transport. Dust generated by abradement from grain handling

operations is composed primarily of the outer layer of the grain kernels, where pesticides have

been applied. Grain dust has been shown to have a higher concentration of pesticide residue

than is found in bulk grain [Palmgren and Lee 1984]. Pesticide exposure is associated with acute

and long-term health risks, and developing adolescents may have increased risk of adverse

health outcomes (see pages 90 and 132).

Railroad Industry

Recommendation – Establish a new HO prohibiting young workers from working in the railroad

industry. An apprentice/student learner exemption is not recommended.

Rationale – Large numbers of fatal and nonfatal injuries have been identified among workers in

the railroad industry. Railroad workers are among occupations with the highest lifetime risk of

fatal injury. Fatalities in the railroad industry are caused by sources such as being struck by

trains, falls, being struck by shifting cargo, and railway accidents. Railroad work is also

associated with adverse health effects, including hearing loss and silicosis. Work in the railroad

industry is characterized by work environments with multiple hazards that are frequently outside

the control of individual supervisors or workers. For these reasons, an apprentice/student learner

exemption is not recommended.

Fatal Injuries and Nonfatal Injuries and Illnesses in the Railroad Industry

The railroad industry (SIC code 40) ranked 14th in lifetime risk of fatal injury with 5.7 deaths per

1,000 working lifetimes in 1990-1991. Further, rail transport occupations (BOC codes 823, 824,

825, and 826) ranked 16th in lifetime risk for fatal injury with 8.4 deaths per 1,000 working

lifetimes in 1990-1991 [Fosbroke et al. 1997]. 

CFOI, 1992-1997, identified 208 fatalities in the railroad industry. Sixty-four percent of these
Recommendations for New Hazardous Orders

114

occurred to workers in rail transport occupations, such as conductors and yardmasters (52),

locomotive operators (33), brake, signal, and switch operators (41), and other rail vehicle

operators (7). Rail vehicles were the primary source of death in 69% of the cases. The most

common fatality event was railway accidents (102) which included train derailments and train

collisions with other trains or non-rail vehicles, followed by pedestrians being struck by a

vehicle (54). The fatality rate for workers in the railroad industry was 12.9 per 100,000 workers

[NIOSH 2001c; NIOSH 2001a].

In 1997, workers in the railroad transportation industry sustained an estimated 5,448 nonfatal

injuries and illnesses requiring days away from work. These injuries and illnesses required a

median of 17 days away from work [BLS 1999b].

Long-Term Health Effects of Railroad Work

In addition to traumatic injuries which occur in the railroad industry, there is also the potential

for adverse health effects which may develop over a period of years. Hearing loss is a common

problem associated with railroad workers. Noise levels from typical railroad yard activities such

as car coupling, air brake application, engine noise, and locomotive horns range from 90 to 120

decibels [Urman 1978]. Railroad workers are also exposed to high levels of silica dust [Bureau

of National Affairs 1993]. In workplace evaluations, NIOSH has found high exposures to silica

dust among railroad track maintenance workers [NIOSH 1993e, NIOSH 2001n]. Exposure to

silica dust is associated with chronic lung disease and cancer, as previously discussed on page 54

and below on page 135.

Work at Heights

Recommendation – Establish a new HO for nonagricultural occupations prohibiting work at a

height of 6 feet or more from ladders; scaffolds; trees; and structures including towers, silos,

poles, oil rigs, bridges, and antennas; and machinery. An apprentice/student learner exemption

is not recommended.

Rationale – Falls to a lower level result in significant numbers of workplace fatalities and

injuries among workers of all ages, including fatalities of workers under age 18. Although HO

16 prohibits work in roofing occupations, youth in the workplace face numerous other fall

hazards that are not addressed by existing HOs. The above recommendation is consistent with

OSHA regulations that use 6 feet as the threshold for the provision of fall protection in many

work situations. Because safe work at heights requires use of personal protective equipment and

strict adherence to safe work practices, existing OSHA regulations are not sufficient to protect

youth. Further, these OSHA regulations are applicable only to certain industries, occupations,

and work tasks, and in some instances afford lower levels of protection than the changes

proposed here. Additionally, the fit and effectiveness of personal fall arrest systems have not

been specifically evaluated for youth workers. An apprentice/student learner exemption is not

recommended.

Falls to a Lower Level Among Leading Causes of Occupational Fatalities
Recommendations for New Hazardous Orders

115

Since CFOI was implemented nationwide in 1992, falls have consistently ranked among the

leading causes of workplace fatality [BLS 1999a]. Falls to a lower level accounted for a total of

3,448 worker deaths between 1992 and 1997. The annual number of fatal falls to a lower level

increased steadily from 503 in 1992 to 651 in 1997. 

Falls from roofs, from ladders, and from scaffolds or staging were the most common types of

fatal falls to a lower level [Table 30]. A large number were classified as a “fall to a lower level,

n.e.c.” Most common among this group of 675 fatalities were falls from structures and surfaces

such as towers, poles, and bridges (187); falls from machinery (154); and falls from trees (117)

[NIOSH 2001c]. In addition to fatal falls, work in trees is associated with risk of electrocution. 

One source reported that these two events together accounted for 68% of all occupational

fatalities among tree trimmers between 1980 and 1989 [NIOSH 1992c]. 

Fall fatalities occurred among workers in all industry and occupation groups, but incidence was

particularly high in those employed in the construction industry (1,877 deaths, 54.4% of the

total) and in precision production, craft and repair occupations (1,598 deaths, 46.3% of the total)

[NIOSH 2001c, Table 31]. 

Table 30. Fatal Falls and Nonfatal Falls to a Lower Level Resulting in Days Away from Work,

by Event Type, United States

Event [OIICS event code] Deaths, 1992-

1997

Nonfatal

Injuries and

Illnesses, 1997

Median days

away from

work, 1997

Fall to lower level,

unspecified [110]

133 2,670 15

Fall down stairs or steps

[111] 

90 24,482 8

Fall from floor, dock, or

ground level [112]

201 6,325 15

Fall from ladder [113] 550 24,859 11

Fall from piled or stacked

material [114]

26 1,126 11

Fall from roof [115] 803 3,341 30

Fall from scaffold, staging

[116]

481 4,466 22

Fall from building girders or

other structural steel [117]

230 649 42
Recommendations for New Hazardous Orders

Event [OIICS event code] Deaths, 1992-

1997

Nonfatal

Injuries and

Illnesses, 1997

Median days

away from

work, 1997

116

Fall from nonmoving vehicle

[118]

259 18,377 14

Fall to lower level, n.e.c.

[119]

675 13,587 10

Total 3,448 99,882 12

Source: Census of Fatal Occupational Injuries (Deaths) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Nonfatal injuries), Bureau of Labor Statistics [BLS 1999b].

Table 31. Fatal Work-Related Falls to a Lower Level, by Industry and Occupation, United

States

Deaths, 1992-97

Industry 

 Construction

 Services

 Agriculture/forestry/fishing

 Manufacturing

 Transportation/communications/public utilities

 Wholesale trade

 Retail trade

 Public administration

 Finance/insurance/real estate

 Mining

 Unknown

 Total

1877

352

334

283

177

95

86

84

65

63

32

3448

54.4%

10.2%

9.7%

8.2%

5.1%

2.8%

2.5%

2.4%

1.9%

1.8%

0.9%

100.0%
Recommendations for New Hazardous Orders

Deaths, 1992-97

117

In 1992, a 17-year-old courtesy clerk at a grocery store died

after falling 8 feet from a 12-foot wooden ladder while

attempting to return it to its usual storage location. 

Stowing the ladder was not part of the youth’s assigned

duties. Normally, his supervisor performed this task at the

end of the work day, and was unaware the youth had

attempted to do it. The usual procedure was to place the

ladder against the ceiling opening to the second floor, then

climb the back stairway and pull the ladder up from above. 

A nearby co-worker turned to see the youth fall from the

ladder, striking the back of his head on the concrete floor. 

The position in which the ladder was found suggested it

had been placed against a wall, and that it had slid across

the floor with the youth on it. Paramedics transported the

youth to a local hospital, where he died several days later

as a result of cranio-cerebral trauma due to blunt force

injury [California Department of Health Services 1993].

Occupation

 Precision production/craft/repair

 Laborer

 Farming/forestry/fishing

 Executive/administrative/managerial

 Transport and material moving

 Service

 Operatives

 Professional specialty

 Sales

 Clerical

 Technician/support

 Unknown

 Total

1598

592

333

204

190

189

137

71

55

25

22

32

3448

46.3%

17.2%

9.7%

5.9%

5.5%

5.5%

4.0%

2.1%

1.6%

0.7%

0.6%

0.9%

100.0%

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]

Fall Fatalities of Young Workers

CFOI identified 21 fatal falls to

a lower level among youth less

than age 18 between 1992 and

1997. Twelve (57.1%)

occurred in the construction

industry, with the remaining

nine occurring across six other

industry divisions. Six of the

construction industry falls were

to youth employed by firms

engaged in roofing, siding, and

sheet metal work. Of the 12

youth who died in fatal

construction industry falls, 9

were employed as either

roofers or construction

laborers. The most common

fatal fall event among youth

was falls from roofs (9 deaths,

42.9%). The height of the fall,

noted in 14 of the 21 case narratives, ranged from 10 to 300 feet [NIOSH 2001d].

Nonfatal Falls Result in Substantial Numbers of Injuries

In 1997, falls to a lower level resulted in an estimated 99,882 nonfatal injuries and illnesses
Recommendations for New Hazardous Orders

118

requiring days away from work (Table 30). The most common types of nonfatal falls were falls

down stairs or steps and falls from ladders, which together accounted for more than half the

total. Though smaller in number, falls from roofs, scaffolds, and building girders or structural

steel were associated with the highest median days away from work, ranging from 22 to 42 days

[BLS 1999b]. An analysis of this data focusing on youth demonstrated that youth often sustain

serious injuries in falls from ladders. For the 6-year period 1992-1997, an estimated 419 youth

sustained serious bruises and contusions when they fell from ladders, requiring a median of 20

days away from work [Barkume et al. 2000].

OSHA Regulations Applicable to Workers of All Ages Address Fall Hazards at 6 Feet and

Above

OSHA regulations applicable to general industry (29 CFR 1910) and to the construction industry

(29 CFR 1926) require fall protection be used in a variety of work situations. In some instances,

specified means of fall protection must be used; in other cases, the employer may select from

several options. Fall protection may be achieved by means of perimeter guarding systems,

lifelines, safety net systems, personal fall arrest systems, or a combination of these.

Some OSHA regulations specify a minimum height at which fall protection is to be provided. 

Subpart M of 29 CFR 1926 requires that fall protection be used in many work situations in the

construction industry when work is performed at a height of 6 feet or more. With some

exceptions, varying types of fall protection must be provided when workers are at a height of 6

feet or more above lower levels and are:

• Constructing a leading edge, or working where others are doing so [29 CFR 1926.501(b)(2)]

• Working in hoist areas [29 CFR 1926.501(b)(3)]

• Working where there is danger of falling through holes, including skylights [29 CFR

1926.501(b)(4)]

• Working on the face of formwork or reinforcing steel [29 CFR 1926.501(b)(5)]

• On a ramp, runway, or other walkway [29 CFR 1926.501(b)(6)]

• At the edge of an excavation, well, pit, or shaft 6 or more feet deep [29 CFR 1926.501(b)(7)]

• Less than 6 feet above dangerous equipment (in which case workers must be protected from

falling into the equipment through machine guarding or guardrails); or 6 or more feet above

dangerous equipment (in which case workers must be protected from fall hazards by personal

fall arrest systems, guardrails, or safety nets) [29 CFR 1926.501(b)(8)]

• Performing overhand bricklaying or related work, or having to reach more than 10 inches

below the walking or working surface in performing such work [29 CFR 1926.501(b)(9)]

• Performing roofing work on an unprotected low-slope roof or a steep roof [29 CFR

1926.501(b)(10)] and [29 CFR 1926.501(b)(11)]

• Erecting precast concrete members or performing similar work [29 CFR 1926.501(b)(12)]

• Working in residential construction [29 CFR 1926.501(b)(13)]

• Working on, at, above, or near wall openings where the outside bottom edge of the wall

opening is 6 feet or more above lower levels and the inside bottom edge of the wall opening is

less than 39 inches above the walking or working surface [29 CFR 1926.501(b)(14)]

• On any other walking or working surface at a height of 6 feet or more above lower levels [29

CFR 1926.501(b)(15)]
Recommendations for New Hazardous Orders

119

In other construction settings, various types of fall protection are required at heights greater than

6 feet when workers are:

• On jumbo decks (work platforms used in underground construction) more than 10 feet in

height [29 CFR 1926.800(q)(8)(iii)]

• On fixed ladders where the length of the climb is less than 24 feet but the top of the ladder is

more than 24 feet above lower levels, or where the total length of the climb is 24 feet or more

[29 CFR 1926.1053(a)(18)] and [29 CFR 1926.1053(a)(19)]

• On scaffolds more than 10 feet above a lower level [29 CFR 1926.451(g)(1)]

• More than 25 feet above the ground or water surface where the use of ladders, scaffolds, catch

platforms, temporary floors, safety lines, or safety belts is impractical [29 CFR 1926.105(a)]

[NOTE: This regulation specifies that safety nets are to be provided under these

circumstances.]

Fall protection requirements for certain workers in the electric power generation, transmission,

and distribution industry are more stringent than the 6-foot minimum widely applicable in the

construction industry. Workers in the electric power industry on structures that support overhead

electric power generation, transmission, and distribution lines and equipment must have fall

protection while working at elevated locations greater than 4 feet [29 CFR 1910.269(g)(2)(v)].

Other regulations for construction and for general industry state only that fall protection is to be

provided when work is done at heights, but do not stipulate a minimum height. These apply to

workers:

• On float or ship scaffolds [29 CFR 1910.28 (u) (6)]

• On roofs performing building maintenance who are using powered work platforms [29 CFR

1910.66 (e) (3) (i)]

• On suspended working platforms [29 CFR 1910.66 (f) (5) (ii) (M)] and [29 CFR 1910.66 (f)

(5) (iii) (B)]

• On powered work platforms [29 CFR 1910.66 (j)]

• Performing welding tasks on platforms, scaffolds, or runways [29 CFR 1910.252 (b) (1) (i)]

• On aerial lifts [29 CFR 1926.453 (b) (2) (v)]

• On personnel platforms hoisted on load lines of cranes or derricks [29 CFR 1926 (g) (6) (vii)]

Tractors

Recommendation – Establish a new HO for nonagricultural industries prohibiting operating a

tractor or connecting or disconnecting an implement or any of its parts to or from such a tractor. 

An apprentice/student learner exemption is justified, with the condition that tractors must be

equipped with ROPS and seat belt use mandated.

Rationale – Although tractors have primarily been associated with farming, tractors are now

used in many industries outside of agriculture, and are associated with large numbers of deaths

in nonagricultural industries. Tractors are not explicitly covered in the HO in nonagricultural
Recommendations for New Hazardous Orders

120

occupations, although they would be prohibited for youth less than 18 if they were used for

transportation purposes as covered in nonagricultural HO 2. The many hazards associated with

tractor use have been detailed in Agricultural HO 1 (page 67). A new HO prohibiting the use of

tractors in nonagricultural settings is needed due to the widespread use of tractors outside of

agricultural production. An exemption for student learners/apprentices is warranted because of

compelling evidence about the effectiveness of ROPS, used in conjunction with seat belts, in

reducing the risk for tractor-related deaths (see page 71). 

Fatalities Associated with Tractor Use

Tractors [OIICS source code 8530 or 3123] were either the primary or secondary source of

fatality in 1845 work-related fatalities across all industries between 1992-1997, with 424 deaths

in nonagricultural industries, such as construction (54) and manufacturing (41) [NIOSH 2001c] . 

Almost half (47%) of the fatalities were caused by tractor overturns [OIICS event codes 4141

and 4233; Table 32].

Table 32. Fatal Events for Tractor-Related Fatalities, United States

Event [OIICS event code]

Deaths,

1992-1997

Struck by object [02] 158

Caught in or compressed by equipment or objects [03] 115

Fall to lower level [11] 14

Highway accident [41] 220

Nonhighway accident, except rail, air, water [42] 1168

Pedestrian, nonpassenger struck by vehicle, mobile

equipment [43]

122

Railway accident [44] 16

Fire – unintended or uncontrolled [51] 5

Other events 27

Total 1845

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]
Recommendations for New Hazardous Orders

121

In 1998, a 14-year-old youth who worked for

a food processing plant died after being

pinned under the wheel of a lawn tractor that

rolled backward toward a pond on the plant

grounds. The youth worked during the

summer as groundskeeper assistant, and was

supervised by his father the company

manager. The youth had been using the

tractor, which was equipped with a mower

deck, to mow grass in the vicinity of the

pond. When the rear wheel of the tractor

became stuck in mud on the edge of the pond,

the youth apparently got off the tractor to

push it from the rear, and it rolled backward,

pinning him under the tire [Wisconsin

Division of Health 1998].

Youth Tractor Fatalities

Of the 1845 tractor-related deaths identified

in CFOI, 46 were to youth workers under

the age of 18. Twenty of these fatalities

would not be covered under agricultural HO

1, either because the youth was working in a

nonagricultural industry or the youth was 16

or 17 years old. Overturns (OIICS event

codes 4141 and 4233) were the primary

cause of tractor-related fatalities to youth

(63%) [NIOSH 2001d, Table 33).

Table 33. Tractor-Related Deaths to Youth by Age Group and Injury Event, United States

Age Group

Deaths,

1992-1997 Events [OIICS event code]

Less than 12 9 Caught in running equipment or machinery [0310],

Compressed or pinched by rolling, sliding, or shifting objects

[0320], Jack-knifed or overturned – no collision [4141],

Overturned [4233], Pedestrian struck by vehicle, mobile

equipment in parking lot or non-roadway [4330]

12-13 9 Jack-knifed or overturned – no collision [4141], Fell from and

struck by vehicle, mobile equipment [4232], Overturned

[4233], Pedestrian struck by vehicle, mobile equipment in

parking lot or non-roadway [4330]

14-15 10 Fall from nonmoving vehicle [1180], Jack-knifed or

overturned – no collision [4141], Overturned [4233], Collision

between railway vehicle and other vehicle [4420]

16-17 18 Struck by falling object [0210], Collision between vehicles,

mobile equipment unspecified [4110], Collision between

vehicles, mobile equipment moving in same direction [4112],

Jack-knifed or overturned – no collision [4141], Fell from and

struck by vehicle, mobile equipment [4232], Overturned

[4233]

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]
Recommendations for New Hazardous Orders

122

In 1992, a 16-year-old male landscape

laborer died as a result of traumatic injuries

received after being struck by the bucket of a

skid steer loader. Three landscape workers

were using the loader to assist in the removal

of the wooden stakes securing a silt fence

around a drainage pond. To remove each

stake, the bucket of the loader was lowered,

the fence wound around the bucket, and the

bucket raised. While removing one of the

stakes, the loader tipped forwards while the

bucket was in the raised position. The

operator began lowering the bucket to

stabilize the loader. At the same time, the

victim, who was standing to the front and

side of the loader, slipped and fell beneath

the descending bucket. The bucket struck the

victim’s chest and he died shortly afterwards

[Minnesota Department of Health 1992].

Heavy Machinery

 

Recommendation – Establish a new HO for nonagricultural industries prohibiting operating,

repairing, assisting in the operation of excavating machinery, loaders, and road grading and

surfacing machinery or assisting with tasks performed by these machines. An apprentice/student

learner exemption is not recommended.

Rationale – Machinery is responsible for a large number of deaths and serious injuries across all

industries. Although some machines are prohibited by other HOs (e.g., mining, agricultural),

there are several classes of machinery which do not fall into any of the current HOs, but present

many of the same hazards and contribute a substantial number of fatalities. Deaths and injuries

are not restricted to operators, but are also associated with work on machines, assisting in the

operation of machines, and working in close proximity to the machines. An apprentice/student

learner exemption is not recommended because of the diversity of injury hazards which are

frequently outside the control of an individual supervisor or worker. 

Excavating Machinery, Loaders, and Road Grading and Surfacing Machinery Hazardous to

Workers

Excavating machinery and loaders along with tractors, forklifts, and cranes are the types of

machinery most often associated with machinery-related fatalities across all industries [Pratt et

al. 1996]. A study of machinery-related deaths in the construction industry found excavating

machinery, loaders, and road paving machinery to be in the top five for the number of fatalities

and for fatality rates [Pratt et al. 1997]. Many of the hazards associated with these types of

machines are not related to operating the machines per se, but rather from being on-foot in the

vicinity where the machine is being used

[Pratt et al. 2001; Pratt et al. 1997]. A review

of 22 skid-steer loader fatalities found that in

10 of the cases the worker was standing or

working under the raised bucket resulting in

the worker being crushed between the bucket

and frame when the bucket was lowered

[CDC 1996c]

CFOI, 1992-1997, identified 935 fatalities

where excavating machinery, loaders, and

road grading and surfacing machinery were

the primary or secondary source of injury

[NIOSH 2001c]. Although the majority of

the fatalities occurred in construction (468)

and agriculture (134), substantial numbers of

deaths also occurred in other industries

(Table 34). Currently there are HOs which

prohibit youth under 18 from work in mining,

and youth under 16 from operating

agricultural machinery. Excavating
Recommendations for New Hazardous Orders

123

In 2000, a worker suspected to be less than

18 years of age lost his leg when the earth

compactor he was operating overturned in

Georgia. The worker reported that he was 17

years old, though employer records showed

him to be 20 years of age. The worker was

operating the compactor at a municipal

landfill. The compactor overturned on a

steep embankment. The worker was not

wearing a seatbelt and was ejected from the

compactor. The rollcage of the compactor

landed on his legs, severing his right leg

above the knee and injuring his left leg.

[Associated Press State & Local Wire

2000a].

machinery, loaders, and road grading and surfacing machinery, which are used across all

industries, are not prohibited by any of the current HOs. 

Table 34. Excavating, Loaders, Road Grading and Surface Machinery Deaths by Industry

Division, United States.

Industry Division 

Deaths,

1992-1997

Agriculture, Forestry, and Fishing 134

Mining 41

Construction 468

Manufacturing 77

Transportation, Communications, Public Utilities 76

Wholesale and Retail Trade 49

Finance, Insurance, and Real Estate and Public Administration 42

Services 48

Total 935

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]

Table 35 provides data on fatal and non-fatal

injuries by type of machinery. Excavating

machinery and loaders were the most

common source for both fatal and nonfatal

injuries. 

The most common events for fatalities were

nonhighway accidents (259, OIICS event

code 42), being caught in or compressed in

equipment (184, OIICS event code 03), being

struck by an object (178, OIICS event code

02) and a pedestrian or nonpassenger being

struck by equipment (170, OIICS event code

43), most commonly a bucket. In 51% of the

fatalities the worker was operating the

machinery at the time of the incidents, with

the remaining 49% of the cases occurring

while the worker was on-foot in the area where the equipment was being operated.

Eleven fatalities where excavating machinery, loaders, or road grading and surfacing machinery
Recommendations for New Hazardous Orders

124

were the primary or secondary source of injury occurred to youth under the age of 18 for the

years 1992-1997 [NIOSH 2001d]. Loaders were the source of injury in the majority of the

deaths. In five of the fatalities, the youth was not operating the machinery but working nearby,

most often being struck by the bucket. 

Table 35. Deaths and Nonfatal Injuries and Illnesses Requiring Days Away from Work

Associated with Excavating Machinery, Loaders, and Road Grading and Surfacing Machinery,

United States.

Type of Machinery

[OIICS source code]

1° or 2° Source of

Death, 1992-1997

Nonfatal Injuries

and Illnesses

(1° source), 1997

Median Days Away

from Work, 1997

Excavating machines

[321]

414 1643 16

Loaders [322] 363 1185 15

Road grading and

surfacing machines

[325]

167 1040 10

Source: Census of Fatal Occupational Injuries (Deaths) [NIOSH 2001c] and Survey of Occupational Injuries and

Illnesses (Nonfatal injuries), Bureau of Labor Statistics [BLS 1999b].

Welding

Recommendation – Establish a new HO for nonagricultural industries prohibiting work in

welding.

Rationale – Fatality and injury data have identified large numbers of fatal and nonfatal injuries

among welders, as well as additional cases involving welding activities among non-welders. 

Welders are among occupations with the highest lifetime risk of fatal injury. Fatalities of

welders and other workers engaged in welding occur under varied circumstances, with fires and

explosions quite frequent. Young workers may lack the knowledge to recognize hazards

associated with welding around potentially flammable and explosive materials. Welding is also

associated with a variety of adverse health effects, including acute and chronic illness from

inhalation of metal fumes, allergic reactions to metals, and chronic respiratory symptoms. 

Occupational Fatalities Among Welders

Between 1992-1997, CFOI identified 386 fatalities among welders and cutters (BOC occupation

code 783). There were 11.5 deaths per 100,000 employed welders during the 6-year period. 

Nearly two-thirds of the fatalities occurred in the construction (36.0%) and manufacturing

(30.1%) industries [NIOSH 2001c; NIOSH 2001a, Table 36]. 
Recommendations for New Hazardous Orders

125

Fatalities among welders and cutters were associated with a wide variety of fatal events and

primary injury sources. The predominant types of fatal events were fires and explosions

(21.8%), falls to a lower level (18.4%), and being struck by objects (18.1%). The most common

primary injury source was structures and surfaces (20.5%); OIICS coding rules classify most fall

events under this primary injury source. 

In 1990-1991, welders and cutters had a lifetime risk of fatal work-related injury of 5.6 per 1,000

working lifetimes, 29th highest among all occupations [Fosbroke et al. 1997].

Table 36. Characteristics of Work-Related Deaths of Welders, United States

Deaths, 1992-1997

Industry

 Construction

 Manufacturing

 Services

 Transportation/communications/public utilities

 Wholesale trade

 All others

 Total

139 

116 

52 

25 

23 

31 

386 

36.0%

30.1%

13.5%

6.5%

6.0%

8.0%

100.0%

Event [OIICS event code]

 Fire or explosion [50, 51, 52]

 Fall to lower level [11] 

 Struck by object [02]

 Transportation event [4]

 Caught in or compressed by equipment or objects

[03]

 Contact with electric current [31]

 All other

 Total

84

 71

 70

46

25

24

66

386

21.8%

18.4%

18.1%

11.9%

6.5%

6.2%

17.1%

100.0%

Primary Source of Injury [OIICS source code]

 Structures and surfaces [6]

 Parts and materials [4] 

 Vehicles [8]

 Fire, flame, smoke [934]

 Containers [1]

 Machinery [3]

 Chemicals and chemical products [0]

 All others [2, 5, 7, and 9 (excl. 934)]

 Total

79

76

62

38

36

27

20

48

386

20.5%

19.7%

16.1%

9.8%

9.3%

7.0%

5.2%

12.4%

100.0%

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]
Recommendations for New Hazardous Orders

126

Welding-related Fatalities Occur Among Workers Other Than Welders

The above fatality rate for welders does not consider the additional 114 deaths during 1992-1997 

of workers in occupations other than welding who were engaged in welding activities at the time

of the fatality. These additional cases were identified through text searches of narrative fields

for mention of welding. The majority of these workers (73, 64.0%) were employed in precision

production, craft, and repair occupations, most frequently as structural metal workers (17

deaths). Fatalities involving fires or explosions made up a much higher proportion of fatalities

in this group of non-welders than among workers in welding occupations (51.8% vs. 21.8%). 

Fatalities due to contact with electric current were also more common among the non-welders

(16.7% vs. 6.2%). 

Nonfatal Injuries Among Welders

Data from the NEISS, which provides surveillance of nonfatal occupational injuries treated in

emergency departments, yielded a national estimate of 34,972 nonfatal injuries among welders

in 1998 [NIOSH 2001b]. There were an estimated 22,452 additional injuries that occurred

among workers other than welders in which “weld” appeared in the case narrative. Of the total

57,424 injuries to these two groups of workers, an estimated 15,953 involved welding torches

(OIICS source code 7263), and 12,751 were caused by chips and particles (OIICS source code

951). The most common injury event was exposure to welding light (“welder’s flash” [OIICS

event 362], 17,913 injuries). Large numbers of injuries also resulted from being struck by a

dislodged flying object (OIICS event code 0221) (7,259 injuries), and rubbing or abrasion by

foreign matter in the eye (OIICS event code 053) (4,837 injuries).

Adverse Health Effects of Welding

A wide range of inhalation exposures may occur in welding, depending on the materials and

welding processes used and the concentration of substances in the air [Sferlazza and Beckett

1991]. Air contamination by chromium, nickel, manganese, fluorides, ozone, and aluminum

oxide may occur in welding of mild steel, stainless steel, and aluminum, resulting in upper

respiratory irritation and lung injury [Lewis 1990]. Chemical pneumonitis is caused by

inhalation of high concentrations of irritant gas or gas/particulate mixtures, causing acute

inflammation of the lung parenchyma, pulmonary infiltrates, hypoxemia, and in severe cases,

adult respiratory distress syndrome. Hypersensitivity pneumonitis may be triggered if an allergy

to the metal develops. The symptoms of hypersensitivity pneumonitis are similar to and

sometimes indistinguishable from chemical pneumonitis [Sferlazza and Beckett 1991]. Allergies

to chromium and nickel, both of which are common air contaminants produced during the

welding of stainless steel, are common in the general population. Contact dermatitis due to these

and other metal ions occurs in 10-15% of the human population [Budinger and Hertl 2000].

Metal fume fever is an acute respiratory illness of welders caused by inhalation of metal fumes

formed by welding of zinc (most common), copper, and magnesium. Zinc oxide fumes form

when zinc-coated (galvanized) metal or zinc alloys are heated sufficiently to vaporize zinc. 

Metal fume fever is a self-limited syndrome that occurs several hours after exposure and lasts

about 24-48 hours. It is characterized by high fever, cough, myalgias, malaise, sweating,
Recommendations for New Hazardous Orders

127

excessive thirst, and a sweet, metallic taste in the mouth [Sferlazza and Beckett 1991; Lewis

1990]. Exposure to metal fumes has also been shown to cause an acute decrease in lung function

from the beginning of a welding shift to the end [Sobaszek et al. 2000; Fishwick et al. 1997].

Chronic respiratory effects of welding exposures include chronic bronchitis, chronic pulmonary

function abnormalities, and benign pneumoconiosis due to deposition of iron oxide particles in

the lung (also known as welder’s siderosis) [Bradshaw et al. 1998; Sferlazza and Beckett 1991]. 

Other health effects that have been described include increased risk of spontaneous abortion in

spouses of welders [Hjollund et al. 2000], neuropsychiatric symptoms in welders exposed to

aluminum, lead, or manganese for a long period of time [Sjogren et al. 1990], and occupational

asthma [Sferlazza and Beckett 1991]. A review of studies examining the incidence of lung

cancer in welders concluded that there is a possible association [Sferlazza and Beckett 1991]. 

Assessment of lung cancer risk in welders is confounded by other exposures such as cigarette

smoking, asbestos exposure (such as in shipyards), and other environmental carcinogens

[NIOSH 1988b].

Evidence for Effectiveness of Safety Training

There is little information in the scientific literature about the effectiveness of safety training for

welders. One relevant study examined the value of different levels of feedback about

performance compared with training and goal-setting without feedback among welders, machine

shop, and boiler shop workers [Chhokar and Wallin 1984]. The researchers found that periodic

feedback resulted in improved safety performance beyond training and goal-setting

interventions, and that withdrawal of the feedback resulted in performance declines.

Confined Spaces

Recommendation – Establish a new HO for nonagricultural industries prohibiting work inside

any confined space. No apprentice/student learner exemption is recommended.

Rationale – Confined spaces are extremely dangerous, and result in considerable numbers of

work-related fatalities, including deaths among youth. The hazards associated with confined

spaces exist in both agricultural and nonagricultural industries. Although work in confined

spaces in production agriculture (e.g., silos, grain bins, pits) is prohibited for youth under 16 in

agricultural HO 8, there is no protection for youth workers in nonagricultural industries. 

Confined spaces are associated with atmospheric and physical hazards which have already been

detailed in agricultural HO 8 (beginning on page 86). A new hazardous order addressing work

in confined spaces is needed for youth working in nonagricultural industries due to the many

hazards associated with work in these dangerous environments. The complexity of measures to

identify confined space hazards, and the need for personal protective equipment and strict

adherence to safe work practices when working in confined spaces argue against an

apprentice/student learner exemption.

Fatalities Associated with Work in Confined Space
Recommendations for New Hazardous Orders

128

In 1994, a 17-year-old laborer was cleaning

the inside of metal molds used to form plastic

containers. This task involved applying

tetrachloroethylene, a degreasing agent, to a

cloth rag which was then used to wipe the

interior surface of the mold. The mold in

which the body of the laborer was found

formed a 40-gallon container and measured

19 1⁄2 inches in diameter and 32 inches deep. 

The employee had propped the mold in an

upright position and leaned into the mold to

clean the bottom. The youth was overcome

by the fumes and his body was discovered

eight hours later when a co-worker arrived on

the scene [Colorado Department of Health

1994b].

NIOSH has defined a confined space as a space which by design has limited openings for entry

and exit; unfavorable natural ventilation which could contain or produce dangerous air

contaminants, and which is not intended for continuous employee occupancy [NIOSH 1994d;

NIOSH 1979]. Confined spaces include such structures as silos, tanks, pits, wells, and pipelines. 

Within OIICS, there is no single code which defines confined space incidents. Fatalities were

identified in CFOI, 1992-1997, through a combination of event codes [e.g., caught in collapsing

materials (0400, 0420, 0490), inhalation of enclosed, restricted, or confined space (3411), and

oxygen deficiencies (3930, 3940, 3890)] and keyword search [e.g., confine, silo, etc.]. A review

of the case narratives identified 330 fatalities associated with work in a confined space [NIOSH

2001c]. The majority of these were identified by their event code and subsequent narrative

review, with only 2% being identified by the keyword search. Of the 330 fatalities, 236 (72%)

occurred in industries other than agricultural production, mainly in manufacturing (22%) (Table

37). A large number of fatalities occurred inside bins, silos, and tanks (Table 37).

Risks Associated with Confined Space

Chemicals or chemical fumes were the primary source of injury for over 40% of these fatalities.

Breathing in toxins in a confined space (OIICS event code 3411) was associated with over 42%

of fatalities. In many instances, workers were cleaning or repairing tanks and were overcome by

chemical residue or gases. Another common fatality event was being caught in or crushed in

collapsing materials (35%). Confined space incidents often result in multiple fatalities when

rescues are attempted. CFOI identified 21 rescue attempts resulting in 37 fatalities.

Youth Fatalities in Confined Space

Fourteen fatalities to youth less than 18

associated with confined spaces were

identified in CFOI, 1992-1997 [NIOSH

2001d]. Thirty-six percent of the deaths

were in nonagricultural industries. 

Approximately 70% of the fatalities were

caused by being caught in or crushed in

collapsing materials, with the remainder

attributable to oxygen deficiency. In seven of

the fatalities, the youth was working in a bin

and became submerged in the contents (e.g.,

grain, corn, beans). 
Recommendations for New Hazardous Orders

129

Table 37. Characteristics of Confined Space Deaths, United States.

Deaths,

1992-1997

Industry

Agriculture/Forestry/Fishing 100

Manufacturing 73

Construction 37

Transportation/communication/public utilities 36

Wholesale and Retail Trade 32

Mining 19

Services 19

All others 14

Total 330

Type of Confined Space

Bin/Hopper 106

Tank/Vat 72

Silo 47

Manhole 22

Pit 21

Well 11

Pipeline 8

All other 43

Total 330

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]
Recommendations for New Hazardous Orders

130

Work Involving Powered Conveyors in Manufacturing

Recommendation – Establish a new HO for nonagricultural industries prohibiting work

involving powered conveyors in manufacturing. The HO should cover operation, repair, and

maintenance of conveyors, as well as cleanup duties in the vicinity of conveyors that are in

operation or energized. No apprentice/student learner exemption is recommended.

Rationale – Fatality and injury data identified large numbers of injuries and deaths associated

with work on and around powered conveyors in nonagricultural industries. Half of the

conveyor-related deaths outside of agricultural production occurred in manufacturing industries. 

A large number of conveyor-related fatalities were associated with being caught in running

machinery. In these events, procedures for controlling hazardous energy may not have been in

place or may not have been followed. Young workers are unlikely to have control over

implementation of hazardous energy control policies that would reduce their exposure to

conveyor-related hazards. For this reason, an apprentice/student learner exemption is not

recommended.

Fatalities and Injuries are Associated with Work Involving Powered Conveyors

CFOI identified 219 worker fatalities between 1992 and 1997 in which a powered conveyor was

the primary or secondary source of injury. An additional 50 fatalities were identified through a

keyword search for “convey.” Of the 269 total conveyor-related fatalities, 223 (83%) occurred in

industries outside of agricultural production, primarily manufacturing (116 deaths) [NIOSH

2001c, Table 38]. 

In 1997, there were an estimated 6,020 nonfatal injuries and illnesses requiring days away from

work for which the primary source of injury was a powered conveyor. These injuries resulted in

a median 8 days away from work [BLS 1999b].

Work with Powered Conveyors Presents a Variety of Injury Hazards

The primary fatal event associated with work on or around powered conveyors was being caught

in or compressed by equipment or objects; 155 of the 171 involved being caught in running

machinery (Table 38). However, conveyor-related fatalities also occurred as a result of other

exposures, including contact with electric current, collapsing materials, falls, and being struck by

objects. Almost two-thirds of the case narratives for the 269 conveyor-related fatalities

contained enough information to identify the work task associated with the fatality. The most

common tasks were repair or maintenance, cleanup, and clearing jammed material. 

The predominant risk factor for conveyor-related fatalities was failure to control hazardous

energy, particularly for those associated with being caught in running machinery and those

involving electric current. Some involved failure to lock out or de-energize the conveyor before

performing repair or maintenance, while in other instances a worker was caught after clearing

jammed material. Workers who were performing general cleanup duties in the vicinity of

running conveyors were also caught in machinery.
Recommendations for New Hazardous Orders

131

Table 38. Characteristics of Deaths Associated with Work with Powered Conveyors, United

States

Deaths, 1992-1997

Industry Division

 Manufacturing

 Agricultural production

 Transportation/communications/public utilities

 Mining

 Construction

 Wholesale trade

 All others

 Total

116 

46 

30 

24 

19 

17 

17 

269 

43.1%

17.1%

11.2%

8.9%

5.9%

6.3%

6.3%

100.0%

Event [OIICS event code]

 Caught in or compressed by equipment or objects

[03]

 Fall to lower level [11] 

 Contact with electric current [31]

 Struck by object [02]

 Caught in or crushed in collapsing materials [04] 

 All other

 Total

 171

 28

27

23

9

11

269

63.6%

10.4%

10.0%

8.6%

3.3%

4.1%

100.0%

Work Task

 Repair, maintenance

 Cleanup

 Clearing jammed material

 Operating conveyor

 Loading or unloading

 Transporting conveyor

 Not enough information in narrative to identify

 Total

79

32

25

17

13

10

93

269

29.4%

11.9%

9.3%

6.3%

4.8%

3.7%

34.6%

100.0%

Source: Census of Fatal Occupational Injuries [NIOSH 2001c]
Recommendations for New Hazardous Orders

132

Pesticide Handling

Recommendation– Establish a new HO for non-agricultural industries prohibiting the

performance of any tasks that would fall under the EPA definition of “pesticide handler,” in 40

CFR Part 170 - The Worker Protection Standard. The definition of “pesticide handler” as

written in the Worker Protection Standard can be found on page 91 under the recommendation

for agricultural HO 9, prohibiting the handling of pesticides in agricultural occupations. No

apprentice/student learner exemption is recommended.

Rationale– Many young workers are employed in non-agricultural industries where pesticides

are used. Approximately one-third of work-related pesticide exposures to young workers occur

in these industries. This HO should be consistent with the HO for agricultural occupations

(discussed beginning on page 90). An apprentice/student learner exemption is not recommended

because of the need for personal protective equipment and strict adherence to safe work practices

when handling pesticides.

Pesticides are Used in Nonagricultural Settings where Many Youth Work

Exposure to pesticides may occur in industries other than agricultural production (SIC 01 and

02). In 1997, 151 million pounds of pesticide active ingredients (12% of total U.S. usage) were

used in non-agricultural industries. This includes all pesticide applications to industrial,

commercial, and government facilities, buildings, sites, and land, as well as commercial

applications to homes and lawns [Aspelin and Grube 1999]. A survey of pesticide users in Iowa

and North Carolina, where all users must obtain a licence or be certified (70% of all 51,256

applicators completed the questionnaire), revealed that 50% of commercial applicators applied

pesticides to homes, lawns, and gardens [Alavanja et al. 1998]. 

Analysis of data from the 1997 Current Population Survey [NIOSH 2001a] indicates that

approximately 45,000 youth age 15 through 17 worked in landscape and horticultural services

(BOC code 020) such as lawn mowing, seeding, spraying, and fertilizing services, over 6,000

worked in agricultural services (BOC code 030) such as corn detasseling, irrigation system

operation, and other crop services that may not be performed in actual agricultural production

industries, and over 5,000 worked in retail nurseries and garden stores. 

Pesticide-Related Illnesses Occur in Nonagricultural Occupations

An analysis of survey and poison control data over the period 1988-1999 revealed that about

32% of acute occupational pesticide-related illnesses in workers under 18 occurred in

nonagricultural industries (industries other than BOC codes 010 [agricultural production, crops],

011 [agricultural production, livestock], 012 [veterinary services], 020 [landscape and

horticultural services], and 030 [agricultural services, n.e.c.]) [Calvert 2001]. 
Recommendations for New Hazardous Orders

133

Exposure to Lead

Recommendation– Establish a new HO prohibiting youth from performing work with potential

exposure to lead. No apprentice/student learner exemption is recommended.

Rationale– Exposure to lead may occur in settings not covered under the current HOs or the

proposed HO on construction work. Exposure to lead is associated with severe acute and

chronic toxic effects on many organ systems. Lead exposure in children is associated with

developmental and neurologic impairment, and has been linked with mental retardation, poor

academic performance, and juvenile delinquency. An apprentice/student learner exemption is

not recommended because of the need for personal protective equipment and strict adherence to

safe work practices when working around potential lead exposures.

Occupational Exposure to Lead

Occupational lead exposure is discussed under nonagricultural HO 15 (Wrecking, Demolition,

and Shipbreaking Operations, beginning on page 58) and under the recommendation for a new

HO prohibiting work in construction occupations (page 101). Young workers may be exposed to

lead in these settings, but exposures may also occur in other settings. The primary use of lead is

in the manufacture of storage batteries. Lead compounds and alloys are also used in pipes and

cable sheathing, solder material for electrical applications, paints and plastics as pigments and

stabilizers, and glazes for ceramics [Lewis 1990]. Exposure to lead may occur via inhalation or

ingestion during abrasive blasting, welding, cutting, and torch burning of surfaces coated with

lead-based paint, lead pipes, solder, and other lead-containing building materials. Operations

involving recycling of batteries may also involve lead exposures. The OSHA lead standard for

general industry provides a mechanism for employers to identify those jobs with potential

occupational exposure to lead so that youth can be prohibited from working in these positions. It

requires employers to determine if any employee may be exposed to lead at or above a defined

action level [29 CFR 1910.1025 (d)(2)]. The standard provides several options for how to

perform such a determination. The standard was originally promulgated in 1978. In addition,

new environmental regulations under EPA’s Toxic Release Inventory (TRI) will require

facilities that manufacture, process, or otherwise use more than 100 pounds of lead or lead

compounds in a given year to submit that information to a publicly accessible database. [40 CFR

Part 372]. The first reports under the new rule must be submitted by July 1, 2002 for the 2001

reporting year. This will also serve to increase awareness about overall lead use among

employers and community members.

The CDC estimated that approximately 90%-95% of adults with blood lead levels of 25

micrograms per deciliter (:g/dL) or greater were exposed at work [CDC 1999b]. The geometric

mean blood level for adults ages 20-49 is 2.1 :g/dL (95% CI 2.0-22) and for adults ages 50-69 is

3.1 :g/dL (95% CI 2.9-3.2) [Pirkle 1998]. Based on data from the Third National Health and

Nutrition Examination Survey (NHANES III, 1988-1991), an estimated 700,000 adults in the

U.S. had blood lead levels $ 25 :g/dL [CDC 1999b].

In California, laboratories are required to report blood lead levels $ 25 :g/dL to the

Occupational Lead Poisoning Prevention Program (OLPPP) [California Department of Health
Recommendations for New Hazardous Orders

134

Services 2001]. The 10 industries that reported the highest number of workers with blood lead

levels $ 25 :g/dl during 1995 are listed in Table 39. 

Table 39. Industries with the Highest Number of Lead-Exposed Workers in 1995 (California)

Industry Description* Workers with blood lead

levels $ 25 :g/dl, 1995

Number %

Storage battery

manufacturing

362 37%

Nonferrous secondary

smelting

181 18%

Automotive repair shops

(radiator repair)

68 7%

Painting 52 5%

Amusement & recreation

(firing ranges)

37 4%

Masonry & other stonework 35 4%

Copper/ brass foundries 35 4%

Scrap & waste materials 21 2%

Industrial inorganic

chemicals manufacturing

19 2%

Motor vehicle parts &

accessories manufacturing

15 2%

Source: The California Occupational Blood Lead Registry [California Department of Health Services 2001]

* SIC code not given

Health Hazards of Lead Exposure

The hazards of lead exposure are discussed under nonagricultural HO 15 (Wrecking, Demolition,

and Shipbreaking Operations, beginning on page 58) and under the recommendation for a new

HO prohibiting construction work (page 101). Lead exerts toxic effects on many organ systems

by disrupting basic cellular functions, including interfering with enzymes, competing with

essential metals, and disturbing ion transport mechanisms. Acute effects include hemolytic

anemia, abdominal colic, neurological effects, kidney disorders, and sterility. Seizures and coma

may occur if blood lead levels increase rapidly. Long-term effects include chronic anemia,

kidney damage, hypertension, neurological, gastrointestinal, and reproductive effects [Levin and
Recommendations for New Hazardous Orders

135

Goldberg 2000]. Lead exposure in children has been linked with mental retardation, poor

academic performance, and juvenile delinquency [EPA 2001]. The International Agency for

Research on Cancer [IARC 1987] has concluded that lead is a possible human carcinogen.

Exposure to Silica

Recommendation– Establish a new HO prohibiting youth from performing work with potential

exposure to crystalline silica dust. No apprentice/student learner exemption is recommended.

Rationale– Exposure to crystalline silica dust is associated with chronic lung disease and cancer. 

Not all industries and occupations where exposures to silica occur are covered under current

HOs. An apprentice/student learner exemption is not recommended because of the need for

personal protective equipment and strict adherence to safe work practices when working with

silica. 

Exposure to Silica Dust is Associated with Chronic Lung Disease

As described in the recommendation for HO 13 (Brick, Tile, and Kindred Products, beginning on 

page 54), exposure to respirable crystalline silica dust is associated with the development of

silicosis, lung cancer, pulmonary tuberculosis, and airway diseases such as chronic obstructive

pulmonary disease and bronchitis [NIOSH 2001j; Zuskin et al. 1998; Liou et al. 1996; Burge et

al. 1995; Myers and Cornell 1989]. Additionally, exposure may be related to the development of

autoimmune disorders, chronic renal disease, and other adverse health effects [NIOSH 2001j]. 

Crystalline silica is classified by the International Agency for Research on Cancer [IARC 1997]

as a Class 1 Carcinogen, meaning there is a causal relationship between exposure to crystalline

silica and human cancer.

While silicosis-associated deaths most commonly occur in persons 65 years of age or older with

long-term exposures, deaths also occur in younger adults due to recent exposures to high

concentrations of crystalline silica [CDC 1998]. A case of a sandblaster who died of acute

silicosis at 23 years of age is described in the text box on page 55. 

Silicosis Occurs in Industries Not Covered by Other HOs

Industries and occupations most frequently recorded for decedents with silicosis are shown in

Table 41 [NIOSH 1999a]. Current HOs would cover some, but not all, of the situations where

youth may be exposed to silica dust.
Recommendations for New Hazardous Orders

136

Table 41. Silicosis: Most Frequently Recorded Occupations and Industries on Death Certificate,

Residents Age 15 and Over, Selected Statesa and Years, 1987-1996

 

Occupation [1980 BOC code] % Industry [1980 BOC code] %

Mining machine operators [616] 14.7% Construction [060] 10.8%

Laborers, except construction

[889]

11.1% Metal mining [040] 10.0%

Managers and administrators,

n.e.c.[019]

3.7% Coal mining [041] 6.5%

Supervisors, production

occupations [633]

3.4% Blast furnaces, steelworks, rolling

and finishing mills [270]

6.5%

Janitors and cleaners [453] 3.1% Miscellaneous nonmetallic mineral

and stone products [262]

6.2%

Molding and casting machine

operators [719]

2.8% Nonmetallic mining and quarrying,

except fuel [050]

5.6%

Construction laborers [869] 2.6% Iron and steel foundries [271] 5.0%

Crushing and grinding machine

operators [768]

2.4% Not specified manufacturing

industries [392]

4.1%

Farmers, except horticulture

[473]

2.4% Machinery, except electrical, n.e.c.

[331]

2.7%

Machine operators, not specified 2.4% Agricultural production, crops [010] 2.1%

All other occupations 48.7% Structural clay products [252] 2.1%

Occupation not reported 2.4% Pottery and related products [261] 2.1%

Non-paid worker or non-worker

[961]

2.1%

All other industries 31.7%

Industry not reported 2.8%

Source: NIOSH, Work-Related Lung Disease Surveillance Report 1999, Tables 3-6 and 3-7 [NIOSH 1999a] 

aData on industry and occupation were available for 24 states for most years.
Recommendations for New Hazardous Orders

137

Non-Agricultural and Agricultural Occupations

Work Requiring the Use of Respiratory Protection

Recommendation– Establish a new HO for both agricultural and nonagricultural occupations

prohibiting young workers from performing any work that requires the use of respiratory

protection. No apprentice/student learner exemption is recommended.

Rationale– The use of respiratory protective devices implies the presence of hazardous

atmospheric conditions. Effective use of respirators is dependent on proper fit and usage. Young

workers may have difficulty with respirator fit due to their smaller physical size. In order to

ensure proper use of respirators, workers should be extensively trained. Because youth may

have increased susceptibility to toxins, as discussed previously in this report, exposing young

workers to hazardous atmospheric conditions where respiratory protection would be required

poses unnecessary risk. 

Respiratory Protection is Used to Protect Against a Hazardous Atmosphere

Respiratory protective equipment should be used in the following circumstances: when toxic and

potentially hazardous chemicals are present in the atmosphere; where atmospheric materials are

likely to cause physical discomfort or increase the risk of injury; in an oxygen-deficient

atmosphere; or any combination of these situations [Ballantyne 1981]. Tasks where the routine

use of respirators is necessary include abrasive blasting, fire fighting, working in confined

spaces, and certain maintenance and cleaning tasks [NIOSH 1994a]. Hazardous respirable

materials present in the atmosphere may exist as: gases and vapors (substances that exist in a

gaseous state depending on temperature, pressure, and molecular weight), aerosolized particles

(such as dust, fumes, smoke, mist, or fog), or fibers (such as asbestos or synthetic fibers). These

materials may produce local effects (damage or irritation) on the respiratory tract, systemic

effects (acute or chronic) due to absorption into the bloodstream through the respiratory tract, or

both [Ballantyne and Schwabe 1981].

Respiratory Protection Standards are Based on Research on Adults

Few studies of the use of respiratory protective devices in children have been undertaken

[Mauritzson-Sandberg 1995]. Based on studies of adults, the effectiveness of respiratory

protection has been found to be highly dependent on fit of the apparatus and its proper use

[NIOSH 1987]. A study examining facial dimensions and respirator fit with regard to leakage

found a strong association between poor fit and female gender [Oestenstad 1994]. Adolescents

would presumably have similar problems with respirator fit. According to the ANSI Standard

for Respiratory Protection [ANSI 1992], an effective respiratory protection program for workers

includes extensive training for respirator wearers. Wearers should: be aware of the respiratory

hazards that exist and engineering and administrative controls being used; be familiar with the

respirator’s function, capabilities, and limitations; be able to properly wear the respirator and

check for appropriate fit; be familiar with respirator maintenance, inspection, and storage; and be

able to recognize and react to an emergency situation. 
138

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Further Research Needs

139

In South Carolina, a 17-year-old assistant

manager of a fast-food restaurant was shot

and killed in an armed robbery, along with an

18-year-old former employee who was on the

premises. An 18-year-old employee was also

shot, but survived [Associated Press State

and Local Wire 2000b].

VI. AREAS REQUIRING FURTHER RESEARCH

There are other serious and potentially fatal occupational safety and health hazards to young

workers under age 18 which are of considerable concern, but for which there is insufficient

documentation to support recommendations for new HOs at this time. It is also important that

further research be initiated to determine the extent and severity of other emerging hazards to

young workers, and whether they pose risks of serious injury, illness, or fatality. Additionally,

research is needed on the effectiveness of youth safety training programs to help ensure that

exemptions for apprentice and student-learner programs are effective in facilitating a safe

training environment. The ability of the HOs to protect the health and safety of youth is

dependent on employers understanding and complying with these regulations, as well as

knowledge and attitudes about HOs among employers, parents, youth, and other stakeholders. 

Also, research quantifying and characterizing employer best practices, could be used to increase

the effectiveness of outreach and educational campaigns. 

Little is Known about Risk Factors for Workplace Violence

More research is needed on workplace

violence, which has been identified as a

leading cause of job-related deaths for youth

[Windau et al. 1999; Castillo and Malit 1997;

Castillo et al. 1994]. Work-related homicides

occur in all types of work places, but the

majority occur in retail establishments where

cash is handled, such as grocery stores,

convenience stores, and restaurants [Sygnatur

and Toscano 2001]. Over half of all

employed youth 15 to 17 years old work in this sector, and youth are most commonly hired as

cashiers [NRC/IOM 1998, pp. 46-47]. Though homicide rates are elevated in these common

youth workplaces, the rates are not sufficiently high to warrant industry-wide prohibitions. 

Circumstances are not always known, but available data suggest that most work-related

homicides of youth and adults are associated with robbery [Windau et al. 1999; Jenkins 1996]. 

A study of employee injuries in convenience store robberies found that risk factors associated

with injury to an employee during the course of a robbery included the presence of customers,

the type of weapon used, whether money was stolen, and whether the store had been previously

robbed. The number of employees present and the time of day did not appear to influence the

percentage of employee injuries in the event of a robbery in this study [Amandus et al. 1997]. 

Hypothesized risk factors for work-related homicide include handling cash, working alone or in

small numbers, and working in the late evening and early morning hours [Jenkins 1996]. 

However, data are not available to quantify the level of risk for each of these factors making it

difficult to identify a reasonable and promising approach for an HO to address the risk for

violence to young workers. 

Unique Susceptibilities of Youth
Further Research Needs

140

Prevention and control measure addressing workplace hazards to which adolescents are exposed

were designed for adults. Therefore, further research on the unique susceptibilities and

exposures of young workers is needed.

Most research on the special susceptibilities of children has been limited to the effects of

chemicals on young children and infants, with little attention to adolescents. Except for infancy,

adolescence is the time of most rapid growth and maturation of vital organ systems, including

the reproductive, respiratory, skeletal, immune, and central nervous systems [Bruckner and Weil

1999]. Toxic chemicals, such as endocrine disruptors and neurotoxins may affect adolescents by

disrupting the function or the maturation of these systems [Golub 2000]. These chemicals may

induce reproductive changes, developmental defects, immunologic deficits, and carcinogenesis.

Adolescence is a period of very rapid growth: 15-20% of a person’s height is gained during the

teenage years [Marks and Cohen 1978]. Injuries during bone growth can result in degeneration

and abnormal regrowth of bone [Kao and Smith 1997; Garrick 1992]. Youth are exposed to

risks for musculoskeletal disorders known to be work-related among adults, including

cumulative trauma disorders and overexertion injuries. Little research to address potential

unique susceptibilities of adolescents to musculoskeletal disorders has been conducted

[NRC/IOM 1998]. The impact of adolescent occupational musculoskeletal injuries and illnesses

on future quality of life is also not known. 

Characterization of Young Worker Health Exposures

Available data on youth employment and associated tasks suggest that youth are working in

environments and doing tasks that have known health risks. The extent to which work in these

environments poses risk for illness that would adversely affect quality and productivity of

youth’s lives is not known, however. More research is needed to characterize the types of

exposures that youth experience at work that may result in debilitating illness, and to assess the

effectiveness of existing work controls and practices to sufficiently protect youth from exposures

such as noise, vibration, cumulative trauma, dusts, solvents, and temperature extremes

[NRC/IOM 1998; National Committee for Childhood Agricultural Injury Prevention 1996].

Little is known about exposure of working youth to bloodborne pathogens in health care settings. 

An annual average of approximately 67,000 youth ages 15 to 17 worked in health services

(hospitals, clinics, nursing homes, doctor’s offices and laboratories) at some time between 1992

and 1998 [NIOSH 2001a]. Exposure to bloodborne pathogens is among the recognized health

hazards in health care settings [Lipscomb and Borwegen 2000]. Research is needed to identify

the degree to which youth are exposed to bloodborne pathogens and other potentially hazardous

substances in health care settings, and the extent to which efforts to prevent exposure among

health care providers and emergency workers also protect youth in these settings.

Although asthma is the most common chronic disease of childhood [Clark et al. 1999],

investigation of occupational exposures may be overlooked. Occupational asthma is another

example of a health-related concern for working youth. Occupational asthma has become the

most common work-related lung disease in developed nations [Banks and Wang 2000]. Workrelated asthma can only be positively diagnosed if a specific exposure has been identified [Banks
Further Research Needs

141

In 2000, a 17-year-old youth on a hay hauling crew

died from injuries he received when he fell from a

moving hay truck and was run over by the vehicle’s

tire. The bed of the hay truck did not have

sideboards or rails, and was not equipped with seats

and safety belts for all passengers. The youth

apparently fell off the truck as he stood up when the

driver was negotiating a curve on a paved road

[Oklahoma State Department of Health 2000]. One

of the recommendations in this report is that the

agricultural HO addressing motor vehicle operation

be expanded to include serving as an outside helper. 

Even if this recommendation were acted upon, it

would not impact deaths such as this among 16- and

17-year-old youth working in agriculture.

and Wang 2000]. Therefore, youth’s exposures to agents associated with asthma should be

characterized.

The potential for work place exposure to asbestos among young workers also merits further

research. As previously noted in the discussion of HO 15 (Wrecking, Demolition, and

Shipbreaking Operations), and in the proposed HO for construction work, asbestos exposure is

associated with severe debilitation and potentially fatal lung disease. A number of existing and

proposed HOs (such as prohibitions against mining, construction work, and work requiring

respiratory protection) would limit youth exposure to asbestos. However, potential exposures

may also occur in work settings and tasks not covered by existing or proposed HOs. For

example, work as a custodian in asbestos-containing schools and buildings, or work in

automotive repair shops performing brake and clutch repair may entail exposure to asbestos on

occasion, with uncertain frequency. Although asbestos is clearly a very dangerous work-related

exposure, it is not clear to what extent working youth are exposed. Also not known is the extent

to which employers are aware of the presence of asbestos in the workplace, and the extent to

which exposure is controlled through changes in work process and the use of control

technologies. Scientific research such as this should be considered prior to proposing new

regulations.

Effectiveness of Training Programs

Exemptions from HOs for apprentice and student learner programs facilitate youth gaining

valuable work training in jobs recognized to be hazardous by requiring training and supervision

to minimize the risk for injury. Although the weight of existing evidence generally supports the

value of training, research into the effectiveness of training programs have given mixed and

inconclusive results [Cohen and Colligan 1998; NIOSH 1999d]. Evaluations of apprentice,

student learner, and tractor and machinery certification programs are needed to ensure they are

effective in reducing the risk for serious injury or illness to youth, and to identify modifications

that should be made to increase

effectiveness [Castillo et al. 1999a].

Knowledge of and Attitudes Toward

Child Labor Laws and Health and

Safety Issues Among Stakeholders

Information on knowledge and

attitudes about child labor laws, and

employer best practices, could be

used to increase the effectiveness of

efforts such as Work Safe This

Summer and Spring Into Safety, and

to raise awareness and compliance

with child labor regulations. The

National Research Council report,

Protecting Youth at Work, stated that

based on unpublished data, it is
142

common for employers to be unaware of child labor laws. One survey found that over threequarters of employers were not familiar with prohibited jobs for youth and hours youth may

work [NRC/IOM 1998, pp. 185-186]. Lack of awareness of laws and health and safety issues

among these stakeholders has been identified as a major obstacle to preventing injury and illness

in young workers by organizations such as the American Academy of Pediatrics, the American

Public Health Association, and NIOSH [NRC/IOM 1998, p. 185]. 
Regulatory Barriers

143

In 1999, an eleven-year-old youth, who worked on

his family’s farm, died when the tractor he was

operating overturned into a drainage ditch. On the

day of the incident, the boy and his father were

returning from the cattle pasture where they had

hauled hay bales. The father had gone ahead of the

boy in a pick-up truck. The boy was operating a

tricycle-front-end tractor with a homemade twowheeled round-hay-bale trailer attached on a wellmaintained gravel county road. The father had

trained the boy on operating the tractor earlier in the

year, and had just recently allowed him to operate it

alone. The event was not witnessed, but apparently

the boy lost control of the tractor as it neared a

drainage ditch and culvert. The tractor veered off of

the left side of the road and overturned into the ditch.

[Missouri Department of Health 2000].

VII. BARRIERS TO PREVENTING YOUTH DEATHS, SERIOUS INJURIES AND

ILLNESSES THROUGH REGULATION

Recommendations in this report are limited to changes to HOs which fall within the regulatory 

authority of DOL. It is expected that changes recommended in this report would help to reduce

the incidence of fatal and serious youth work-related injuries and illnesses each year. However,

it must be recognized that considerable numbers of youth work-related deaths and serious

injuries would not be impacted by these recommended changes. Many deaths and serious

injuries occur among youth not covered by the FLSA, or in situations that would be difficult to

regulate under the current framework of the FLSA. Additionally, revisions or additions of new

HOs alone will not prevent all work-related deaths. Efforts are needed to raise awareness and

compliance with HOs to ensure youth are not inappropriately employed in recognized hazardous

work settings. 

Agricultural Work is Less Stringently Regulated than Nonagricultural Work

Thirty-five percent of the young workers killed over the 1992-1997 period lost their lives in

agricultural production jobs (SIC 01 and 02) (136 agricultural production deaths/394 total

deaths) [NIOSH 2001d]. Despite the

well-documented hazards and

consistently high rates of injury and

fatalities, youth in agricultural

workplaces are afforded less protection

than youth in nonagricultural

occupations. This is true even with

respect to the same hazards, such as

machinery. In fact, the current

distinctions between HOs for

agricultural and nonagricultural

occupations are frequently artificial,

given that the same machinery,

activities and exposures are often

present in both settings. Yet the

minimum age for similar hazardous

work in agriculture is 16, compared to

18 in nonagricultural occupations. For

the 6 year period 1992-1997, there were

39 deaths of youth 16- and 17-years of

age in agricultural production [NIOSH

2001d]. Changes to HOs could not be expected to impact these young worker injury deaths

since they fall outside the coverage of the FLSA. Additionally, youth working on their family’s

farms are exempt from the FLSA, unlike most other types of family businesses. It is not possible

for NIOSH to determine from the CFOI research file provided by BLS the numbers of

agricultural production deaths of youth less than 16 years of age that would not be covered by

the FLSA because the youth was working on the family farm. A previous analysis of CFOI by

BLS researchers suggested that more than half of the farming related deaths of youth less than
Regulatory Barriers

144

In 1999, one 15-year-old boy was killed and

another 15-year-old boy was seriously

injured while working in two different

chicken processing plants. In Arkansas, the

15-year-old was electrocuted. In Missouri,

the boy fell into an auger, seriously injuring

both legs [Tagami 2001]. The FLSA

prohibits youth less than 16 years of age from

working in workplaces where goods are

manufactured or otherwise processed. The

Department of Labor found three other

underage youth at the Missouri plant where

the 15-year-old was seriously injured. As a

result of surprise inspections in 51 chicken

processing plants nationwide, the Department

of Labor uncovered a dozen underage youth

at two plants [Tagami 2001].

18 years of age occurred on farms owned by the victim’s families [Windau et al. 1999]. 

State Child Labor Laws May Be Less Protective than Federal Laws

Under current law, states are not required to have child labor laws that are at least as protective

as federal law (unlike the federal Occupational Safety and Health Act which requires state laws

to be at least as protective as federal law). There are numerous cases in which the federal HOs

cannot be applied because the jurisdictional thresholds of the Act are not met, and state law does

not cover the particular hazards addressed in the federal HOs. Many states have not

incorporated all the federal HOs, and some states’ child labor regulations are less protective than

the federal HOs [NRC/IOM 1998, pp. 229-230]. 

Workplace Violence Is Not Addressed by HOs

Work-related homicides accounted for 18% of the work-related fatalities to youth between 1992-

1997 [Windau et al. 1999]. As discussed on page 139, hypothesized risk factors for workplace

violence, such as working late at night or early in the morning and working in high crime areas,

cannot be addressed in the form of an HO. For instance, federal child labor laws make no

restrictions on hours worked, at what times of day youth 16 years and older may work, or their

job location [DOL 2001]. Consequently, none of the existing or recommended HOs specifically

address these hypothesized risk factors. Therefore, changes recommended in this report will do

nothing to address the hazards of work place violence.

The Extent of Employer Awareness of and Compliance with Child Labor Laws is Unknown

New HOs and revisions of existing HOs will not protect youth unless recognized and complied

with by employers. A number of studies

have suggested that many young worker

deaths are associated with work typically

prohibited by child labor laws. Studies of

varying geography, jurisdiction, and time

periods have reported that between 38 and

85% of young worker injury deaths are

associated with work typically prohibited by

child labor laws [Castillo et al. 1994; Dunn

and Runyan 1993; Suruda and Halperin 1991;

GAO 1991b]. Until barriers to employer

compliance are better understood, and

strategies are developed to address them,

little progress can be expected in this arena.
145

VIII. APPENDIX. Listing of all SIC industry groups with fatality rates (for all workers) higher

than 10 per 100,000 workers (twice the average rate for all workers) by descending rate and

description of HO coverage.

Industry (SIC Code)

Fatality

rate per

100,000

workers

Number

of deaths

1992-1997 Covered by current

HOs

Covered by

recommended HO

expansions and

additions

Outside the scope of

HO recommendations

Fishing, hunting, and

trapping (09)

114.2 436 Proposed new HO for

fishing

Logging (241) 103.1 874 Covered by HO 4

Taxicab service (412) 82.4 556 Primarily assault

fatalities

Coal mining (12) 42.2 255 Covered by HO 3

Agricultural Production,

crops (01)

41.1 2324 Covered by Ag HOs

Water transportation (44) 37.5 377 Proposed new HO for

water transportation

industries

Agricultural services,

n.e.c. (071, 072, 075,

076)

31.5 329 Primarily crop dusters -

covered by age

regulations for pilots

Oil and gas extraction

(13)

26.0 522 Covered by proposed

expansion for HO 9

Metal mining (10) 24.4 84 Covered by HO 9

Executive and legislative

offices (911-913)

23.2 210 No basis for HO -

misclassification of

cases from various

industries

Trucking service (421,

423)

22.6 2801 Primarily

transportation

fatalities, covered by

HO 2

Nonmetallic mining and

quarrying, except fuel

(14)

21.6 143 Covered by HO 9

National security and

international affairs (97)

20.0 867 Primarily military

Miscellaneous petroleum

and coal products (295,

299)

18.3 27 Primarily transportation

and assault fatalities
APPENDIX (continued). Listing of all SIC industry groups with fatality rates (for all workers)

higher than 10 per 100,000 workers (twice the average rate for all workers) by descending rate

and description of HO coverage.

Industry (SIC Code)

Fatality

rate per

100,000

workers

Number

of deaths

1992-1997 Covered by current

HOs

Covered by

recommended HO

expansions and

additions

Outside the scope of

HO recommendations

146

Mobile home dealers,

retail (527)

18.0 31 Primarily

transportation

fatalities, covered by

HO 2

Farm products raw

materials (515)

17.5 86 Proposed new HO for

the farm product raw

materials wholesale

trade industry

Liquor stores (592) 16.6 126 Primarily assaults

Forestry (08) 16.6 82 Covered by proposed

expansion to HO 4

Cement, concrete,

gypsum, and plaster

products (324, 327)

15.9 181 Primarily

transportation

fatalities, covered by

HO 2

Scrap and waste

materials, wholesale

(5093)

15.0 187 Proposed new HO for

work in scrap and waste

materials industries

Sanitary services (495) 14.8 276 Proposed new HO for

work in refuse

occupations

Construction (15, 16, 17) 14.4 6304 Proposed new HO for

construction occupations

Agricultural production,

livestock (02)

14.4 1053 Covered by Ag HOs

Landscape and

horticultural services

(078)

13.8 606 Covered by HO 5

(machinery) and HO 2

(transportation)

Petroleum products,

wholesale (517)

13.0 101 Primarily

transportation

fatalities, covered by

HO 2

Railroads (40) 12.8 208 Proposed new HO for

the railroad industry

Gasoline service stations

(554)

12.8 306 Primarily assaults
APPENDIX (continued). Listing of all SIC industry groups with fatality rates (for all workers)

higher than 10 per 100,000 workers (twice the average rate for all workers) by descending rate

and description of HO coverage.

Industry (SIC Code)

Fatality

rate per

100,000

workers

Number

of deaths

1992-1997 Covered by current

HOs

Covered by

recommended HO

expansions and

additions

Outside the scope of

HO recommendations

147

Air transportation (45) 12.5 555 Age regulations for

pilots

Administration of

environmental quality and

housing programs (95)

12.3 188 No basis for HO -

misclassification of

cases from various

industries

Warehousing and storage

(422)

11.9 106 Primarily

transportation

fatalities, covered by

HO 2

Motor vehicles and

equipment, wholesale

(501)

11.8 151 Primarily

transportation

fatalities, covered by

HO 2

Fuel dealers, retail (598) 11.7 83 Primarily assaults

Sawmills, planing mills,

and millwork (242, 243)

11.4 256 Covered by HO 4

Iron and steel foundries

(332)

11.4 67 Various exposures

including machinery,

transportation, and falls

which are either already

covered or would be

with proposed changes

Detective and protective

services (7381, 7382)

11.2 325 Primarily assaults

Agricultural chemicals

(287)

10.1 25 Various exposures

including machinery,

transportation, and falls

which are either already

covered or would be

with proposed changes

Source: Census of Fatal Occupational Injuries [NIOSH 2001c] and Current Population Survey [NIOSH 2001a].
148

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149

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