To determine the effect of the proposed rule on inestablishment worker safety, FSIS compared in-establishment

injury rates between HIMP and traditional establishments1 from 

2002 to 2010. The preliminary analysis has shown that HIMP 

establishments had lower mean injury rates as compared to 

traditional establishments, Table XX.

The data used for the analysis was gathered from the 

Department of Labor (DOL), Occupational Safety and Health 

Administration (OSHA) from the Bureau of Labor Statistics, 

Survey of Occupational Injuries and Illnesses. FSIS subset the 

OSHA data for Hog slaughter plants comparing this data to the

FSIS Public Health Information System data. The analysis 

excluded the 27 lowest volume plants2, leaving 27 plants (5 HIMP 

and 24 Traditional). The results showed HIMP plants had a lower 

mean number of injuries using OSHA injury rates3 as compared to 

traditional plants. The independence of means test was used to 

verify the statistical significance of the analysis, and the 

 1 The analyses included the 5 HIMP establishments and 24 randomly selected 

large and small high volume establishments. Every establishment had an 

annual production value of at least 100,000 heads. 

2 Volume data was acquired for 2011 from the FSIS Public health information 

system and matched to the establishment level data to filter by slaughter 

volume. Plants with the lowest volumes at less than 100,000 head per year 

were excluded. 

3 The OSHA data has three types of indices for an Annual basis, Total Case 

Rate (TCR), Days Away Transferred Restricted (DART), and Days Away From Work 

(DAFW). Please see the OSHA website for more information and for the 

calculation of the indices listed above. 

https://www.osha.gov/oshstats/work.html
equality of variances in the Levene’s test as well as the t-test 

were used to evaluate the HIMP and Traditional injury rate 

means, please see tables below. 

OSHA data does have some limitations, because 

establishments voluntarily submit injury data on an annual 

basis, and the survey is only collected from participating 

States. Establishment data is not available for Alaska; Oregon; 

Puerto Rico; South Carolina; Washington; and Wyoming. Other 

limitations include underreporting of injuries, for instance 

non-inclusion of longer-term injuries such as hearing loss. For 

each data collection cycle, OSHA only collects data from a small 

portion of all private sector establishments in the United 

States (80,000 out of 7.5 million total establishments). The 

data may not be representative of all businesses. For a larger 

list of limitations and studies completed pertaining to the OSHA 

data limitations, please see the Bureau of Labor Statistics 

website, http://www.bls.gov/iif/oshfaq1.htm#q01.

Table XX : Annual Mean Injury Rates by Establishment Type

Type of 

Establishment

Total Case Rate of 

Injuries*(TCR)

Days Away Transferred and 

Restricted* (DATR)

Days Away From 

Work* (DAW)

HIMP 10.46 6.61 1.00

Traditional 16.38 10.16 2.61

* All values are calculated means of incidence rates per 100 employees by establishment. 
Statistical Means and Tests for Significance

The tables below show the statistical output of the analysis for the Levene’s test as well as the various 

OSHA case rate indices used to compare the injury rates in traditional plants to HIMP plants. Overall 

the tests show statistical significance and lower case rates in HIMP plants. 

Observations 

/ Years Mean

Std. 

Deviation

Std. 

Error 

Mean

2012 Count of Swine Slaughtered HIMP (5 

plants) 24 3,165,410 1,381,477 281,993

Traditional 

(24 plants) 119 1,926,069 2,290,391 209,960

Total Case Rate HIMP (5 

plants) 24 10.46 5.62 1.15

Traditional 

(24 plants) 119 16.38 9.15 0.84

Days Away Transferred or 

Restricted

HIMP (5 

plants) 24 6.61 3.77 0.77

Traditional 119 10.16 7.23 0.66

Days Away From Work HIMP (5 

plants) 24 1.00 0.74 0.15

Traditional 

(24 plants) 119 2.61 2.17 0.20

Levene's Test for 

Equality of Variances t-test for Equality of Means

F Sig. t df

Sig. (2-

tailed)

Mean 

Difference

2012 Count of Swine 

Slaughtered

Equal variances 

assumed 9.749 .002 2.554 141 .012 1,239,341.49

Equal variances 

not assumed 3.525 52.429 .001 1,239,341.49

Total Case Rate Equal variances 

assumed 5.503 .020 -3.050 141 .003 -5.92

Equal variances 

not assumed -4.165 51.308 .000 -5.92

Days Away Transferred 

Restricted

Equal variances 

assumed 6.980 .009 -2.340 141 .021 -3.55

Equal variances 

not assumed -3.497 62.936 .001 -3.55

Days Away From Work Equal variances 

assumed 11.593 .001 -3.588 141 .000 -1.62

Equal variances 

not assumed -6.450 108.261 .000 -1.62
From: Maculloch, Bryan - FSIS

To: Pugliese, Andrew - FSIS

Subject: FW: Question

Date: Tuesday, February 27, 2018 1:58:13 PM

Attachments: OSHA Hogs.msg

From: Furey, Todd M. - FSIS

Sent: Thursday, March 24, 2016 4:25 PM

To: Catlin, Michelle - FSIS <Michelle.Catlin@fsis.usda.gov>

Cc: Maculloch, Bryan - FSIS <Bryan.Maculloch@fsis.usda.gov>; Anderson, Don - FSIS

<Don.Anderson@fsis.usda.gov>

Subject: RE: Question

Yes, Bryan, Don Anderson and I worked on this project.  We used OSHA data and linked it to PHIS. 

Bottom line –

“the HIMP plants have statistically-low OSHA case rates than either of the comparison sets of

Traditional plants.”

The complete details are attached.

Todd

From: Catlin, Michelle - FSIS 

Sent: Thursday, March 24, 2016 4:07 PM

To: Furey, Todd M. - FSIS

Subject: Question

Was it someone on your staff who looked at injury data in hog himp vs non-himp? If so, what data

did they use? (In phil's office on call with hill staff - just in case it comes up phil asked about it)

Sent from my Android phone using Symantec TouchDown (www.symantec.com)
From: Maculloch, Bryan - FSIS

To: Pugliese, Andrew - FSIS

Subject: FW: OSHA

Date: Thursday, April 7, 2016 8:27:49 AM

Attachments: OSHA.docx

Hi Andrew,

Thanks!

Bryan

From: Maculloch, Bryan - FSIS 

Sent: Thursday, January 14, 2016 4:42 PM

To: Furey, Todd M. - FSIS; Pugliese, Andrew - FSIS; Ajmera, Richa - FSIS

Subject: RE: OSHA

Here you go Todd.

Thanks,

Bryan

From: Furey, Todd M. - FSIS 

Sent: Thursday, January 14, 2016 4:13 PM

To: Pugliese, Andrew - FSIS; Ajmera, Richa - FSIS

Cc: Maculloch, Bryan - FSIS

Subject: Hogs

 Please extract it and send a copy to me.

Thank you, Todd

Sent from my Android phone using Symantec TouchDown (www.symantec.com)

(b) (5)

(b) (5)

(b) (5)
From: Maculloch, Bryan - FSIS

To: Pugliese, Andrew - FSIS

Subject: FW: OSHA Hogs

Date: Tuesday, February 27, 2018 2:08:19 PM

Hi Andrew, I found this as well.

Bryan

_____________________________________________

From: Anderson, Don - FSIS

Sent: Wednesday, December 2, 2015 10:13 AM

To: Maculloch, Bryan - FSIS <Bryan.Maculloch@fsis.usda.gov>; Pugliese, Andrew - FSIS

<Andrew.Pugliese@fsis.usda.gov>; Furey, Todd M. - FSIS <Todd.Furey2@fsis.usda.gov>

Subject: RE: OSHA Hogs

OK, let me know if you need any more help

Don Anderson 202-821-9396

_____________________________________________

From: Maculloch, Bryan - FSIS

Sent: Wednesday, December 02, 2015 9:14 AM

To: Anderson, Don - FSIS; Pugliese, Andrew - FSIS; Furey, Todd M. - FSIS

Subject: RE: OSHA Hogs

Thanks for your help on this.

Thanks,

Bryan

_____________________________________________

From: Anderson, Don - FSIS

Sent: Wednesday, December 02, 2015 9:10 AM

To: Maculloch, Bryan - FSIS; Pugliese, Andrew - FSIS; Furey, Todd M. - FSIS

Subject: RE: OSHA Hogs

I have been out of town for a week or so. I don’t remember if I heard back from anyone on

this work. Can you give me a status report of where we are since I sent this and

whether/what more work we have to do? Thanks, don

Don Anderson 202-821-9396

_____________________________________________

(b) (5)
From: Anderson, Don - FSIS

Sent: Monday, November 16, 2015 11:11 AM

To: Maculloch, Bryan - FSIS; Pugliese, Andrew - FSIS; Furey, Todd M. - FSIS

Subject: OSHA Hogs

This document compares the OSHA case rates in the 5 HIMP plants to TWO different

“comparison sets” of plants.

On page 1, the comparison group is 24 Traditional Plants that slaughter at least 100,000

Swine.

(For these comparisons I am using Andrew’s 2012 slaughter data because it is the closest in

time to the OSHA data but the first complete year of PHIS data).

The mean slaughter volume in HIMP is about 3.1 million/year; traditional 1.9 Million/year

The SECOND page narrows the number of traditional plants even more, by using a 1 million

head threshold.

Mean HIMP is of course still 3.1 million; the Mean in the 10 Traditional plants is 4.2 million.

Either way you look at it, and by any of the 3 OSHA measures, the HIMP plants have

statistically-low OSHA case rates than either of the comparison sets of Traditional plants.

I am also attaching a spreadsheet with just the HIMP and 2 comparison plant sets. Column F

‘Comparison Group” has a filter on it.

Select 1 and 100,000 to see HIMP plus Traditional plants over 100,000 (including those over 1

million)

Select 1 and 1,000,000 to see HIMP plus Traditional plants over 1 million.

Schedule a meeting sometime if you want. What we probably should be thinking about is

what other differences between HIMP and Traditional plants- besides slaughter volume- can

and should we be trying to control for- data permitting.

<< File: osha data modified comparison plants 2012 slaughter.xlsx >>

<< File: One Hundred Thousand and One Million Hogs.docx >>

Don Anderson

Management Control and Audit Division

Office of Investigation, Enforcement & Audit

Food Safety and Inspection Service- USDA

202-821-9396
From: Maculloch, Bryan - FSIS

To: Pugliese, Andrew - FSIS

Subject: FW: OSHA Hogs

Date: Tuesday, February 27, 2018 2:08:55 PM

Attachments: One Hundred Thousand and One Million Hogs.docx

osha data modified comparison plants 2012 slaughter.xlsx

swine osha match2002.xls

_____________________________________________

From: Furey, Todd M. - FSIS

Sent: Wednesday, December 30, 2015 10:24 AM

To: Maculloch, Bryan - FSIS <Bryan.Maculloch@fsis.usda.gov>

Subject: FW: OSHA Hogs

_____________________________________________

From: Maculloch, Bryan - FSIS

Sent: Wednesday, December 30, 2015 10:11 AM

To: Furey, Todd M. - FSIS

Subject: FW: OSHA Hogs

Hi Todd,

Here’s how Don calculated the average rates, and the data he used. The data is at the bottom

of the email below.

Bryan

_____________________________________________

From: Anderson, Don - FSIS

Sent: Monday, November 16, 2015 11:11 AM

To: Maculloch, Bryan - FSIS; Pugliese, Andrew - FSIS; Furey, Todd M. - FSIS

Subject: OSHA Hogs

This document compares the OSHA case rates in the 5 HIMP plants to TWO different

“comparison sets” of plants.

On page 1, the comparison group is 24 Traditional Plants that slaughter at least 100,000

Swine.

(For these comparisons I am using Andrew’s 2012 slaughter data because it is the closest in

time to the OSHA data but the first complete year of PHIS data).

The mean slaughter volume in HIMP is about 3.1 million/year; traditional 1.9 Million/year

The SECOND page narrows the number of traditional plants even more, by using a 1 million

head threshold.
Mean HIMP is of course still 3.1 million; the Mean in the 10 Traditional plants is 4.2 million.

Either way you look at it, and by any of the 3 OSHA measures, the HIMP plants have

statistically-low OSHA case rates than either of the comparison sets of Traditional plants.

I am also attaching a spreadsheet with just the HIMP and 2 comparison plant sets. Column F

‘Comparison Group” has a filter on it.

Select 1 and 100,000 to see HIMP plus Traditional plants over 100,000 (including those over 1

million)

Select 1 and 1,000,000 to see HIMP plus Traditional plants over 1 million.

Schedule a meeting sometime if you want. What we probably should be thinking about is

what other differences between HIMP and Traditional plants- besides slaughter volume- can

and should we be trying to control for- data permitting.

Don Anderson

Management Control and Audit Division

Office of Investigation, Enforcement & Audit

Food Safety and Inspection Service- USDA

202-821-9396
From: Maculloch, Bryan - FSIS

To: Pugliese, Andrew - FSIS

Subject: FW: swine slaughter volumes

Date: Tuesday, February 27, 2018 2:09:54 PM

_____________________________________________

From: Anderson, Don - FSIS

Sent: Friday, November 13, 2015 2:38 PM

To: Maculloch, Bryan - FSIS <Bryan.Maculloch@fsis.usda.gov>; Pugliese, Andrew - FSIS

<Andrew.Pugliese@fsis.usda.gov>; Furey, Todd M. - FSIS <Todd.Furey2@fsis.usda.gov>

Subject: swine slaughter volumes

Regarding selecting a subset of “traditional” plants to better compare with HIMP plants.

Remember, there are now 56 plants in the “osha” data set- 5 HIMP and 51 Traditional

Using the 2012 slaughter data Bryan forwarded me, note that the mean annual slaughter

volume is about 1.2 million head, but with a big SD

Descriptive Statistics

 N Minimum Maximum Mean Std. Deviation 

2012SwineHead 56 12 7,901,152 1,202,262.84 2,014,099.205 

Valid N (listwise) 56 

In the figure below, I have EXCLUDED 27 plants that slaughtered fewer than 100,000 head in

2012 (all excluded plants are traditional, not HIMP).

Thus, the 29 plants below (5 HIMP and 24 Traditional) have slaughter volumes equal to or

higher than 100,000 head.

You can see the HIMP plants in Red, and the 24 traditional plants in Blue.

I think we could easily make a case for excluding the 27 lowest-volume plants that I already

have.

(b) (5)
Don Anderson

Management Control and Audit Division

Office of Investigation, Enforcement & Audit

Food Safety and Inspection Service- USDA

202-821-9396

(b) (5)
From: Anderson, Don - FSIS

To: Maculloch, Bryan - FSIS; Pugliese, Andrew - FSIS; Furey, Todd M. - FSIS

Subject: OSHA Hogs

Date: Monday, November 16, 2015 11:11:01 AM

Attachments: One Hundred Thousand and One Million Hogs.docx

osha data modified comparison plants 2012 slaughter.xlsx

This document compares the OSHA case rates in the 5 HIMP plants to TWO different

“comparison sets” of plants.

On page 1, the comparison group is 24 Traditional Plants that slaughter at least 100,000

Swine.

(For these comparisons I am using Andrew’s 2012 slaughter data because it is the closest in

time to the OSHA data but the first complete year of PHIS data).

The mean slaughter volume in HIMP is about 3.1 million/year; traditional 1.9 Million/year

The SECOND page narrows the number of traditional plants even more, by using a 1 million

head threshold.

Mean HIMP is of course still 3.1 million; the Mean in the 10 Traditional plants is 4.2 million.

Either way you look at it, and by any of the 3 OSHA measures, the HIMP plants have

statistically-low OSHA case rates than either of the comparison sets of Traditional plants.

I am also attaching a spreadsheet with just the HIMP and 2 comparison plant sets. Column F

‘Comparison Group” has a filter on it.

Select 1 and 100,000 to see HIMP plus Traditional plants over 100,000 (including those over 1

million)

Select 1 and 1,000,000 to see HIMP plus Traditional plants over 1 million.

Schedule a meeting sometime if you want. What we probably should be thinking about is

what other differences between HIMP and Traditional plants- besides slaughter volume- can

and should we be trying to control for- data permitting.

Don Anderson

Management Control and Audit Division

Office of Investigation, Enforcement & Audit

Food Safety and Inspection Service- USDA

202-821-9396
ANDERSON Nov 16 2015

1

Group Statistics Establishments Over 100,000 Head

Obs/Yrs Mean Std. Deviation

Std. Error 

Mean

2012SwineHead HIMP (5 plants) 24 3,165,410 1,381,477 281,993

Traditional (24 plants) 119 1,926,069 2,290,391 209,960

TotalCaseRate HIMP (5 plants) 24 10.46 5.62 1.15

Traditional (24 plants) 119 16.38 9.15 0.84

DaysAwayTransferredRestricted HIMP (5 plants) 24 6.61 3.77 0.77

Traditional 119 10.16 7.23 0.66

DaysAwayFromWork HIMP (5 plants) 24 1.00 0.74 0.15

Traditional (24 plants) 119 2.61 2.17 0.20

Independent Samples Test Establishments Over 100,000 Head

Levene's Test for Equality of 

Variances t-test for Equality of Means

F Sig. t df Sig. (2-tailed)

Mean 

Difference

2012SwineHead Equal variances assumed 9.749 .002 2.554 141 .012 1,239,341.49

Equal variances not assumed 3.525 52.429 .001 1,239,341.49

TotalCaseRate Equal variances assumed 5.503 .020 -3.050 141 .003 -5.92

Equal variances not assumed -4.165 51.308 .000 -5.92

DaysAwayTransferredRestricted Equal variances assumed 6.980 .009 -2.340 141 .021 -3.55

Equal variances not assumed -3.497 62.936 .001 -3.55

DaysAwayFromWork Equal variances assumed 11.593 .001 -3.588 141 .000 -1.62

Equal variances not assumed -6.450 108.261 .000 -1.62
ANDERSON Nov 16 2015

2

Group Statistics Establishments Over 1 Million Head

Obs/Yrs Mean Std. Deviation

Std. Error 

Mean

2012SwineHead HIMP (5 plants) 24 3,165,410 1,381,477 281,993

Traditional (10 plants) 49 4,227,168 1,911,402 273,057

TotalCaseRate HIMP (5 plants) 24 10.46 5.62 1.15

Traditional (10 plants) 49 18.09 11.37 1.62

DaysAwayTransferredRestricted HIMP (5 plants) 24 6.61 3.77 0.77

Traditional 49 11.35 8.72 1.25

DaysAwayFromWork HIMP (5 plants) 24 1.00 0.74 0.15

Traditional (10 plants) 49 1.77 1.35 0.19

Independent Samples Test Establishments Over 1 Million Head

Levene's Test for Equality of 

Variances t-test for Equality of Means

F Sig. t df Sig. (2-tailed)

Mean 

Difference

2012SwineHead Equal variances assumed 1.217 .274 -2.425 71 .018 -1,061,757.28

Equal variances not assumed -2.705 60.757 .009 -1,061,757.28

TotalCaseRate Equal variances assumed 20.992 .000 -3.099 71 .003 -7.63

Equal variances not assumed -3.837 70.974 .000 -7.63

DaysAwayTransferredRestricted Equal variances assumed 14.492 .000 -2.539 71 .013 -4.74

Equal variances not assumed -3.233 70.277 .002 -4.74

DaysAwayFromWork Equal variances assumed 17.242 .000 -2.623 71 .011 -0.77

Equal variances not assumed -3.162 69.884 .002 -0.77
Billing Code 3410-DM-P

DEPARTMENT OF AGRICULTURE

Food Safety and Inspection Service

9 CFR Parts 301, 309, and 310

[Docket No. FSIS-2016-0017]

RIN 0583-AD62

Modernization of Swine Slaughter Inspection

AGENCY: Food Safety and Inspection Service, USDA.

ACTION: Proposed Rule.

D. Overview of the Proposed Rule’s NSIS

Eight of the proposed rule’s provisions apply to only those 

establishments that voluntarily participate in the NSIS. Meeting 

these provisions will likely increase an establishment’s labor 

and training costs. Additionally, only market hogs are eligible 

to participate in the NSIS. Due to these economic constraints

discussed above, we expect that only large and small high volume 

establishments that exclusively slaughter market hogs would 

voluntarily participate in the NSIS. In 2016 there were 40 high 

volume establishments that exclusively slaughter market hogs, 27 
large1 (5 HIMP + 22 non-HIMP)2 and 13 small establishments, Table 

4. These establishments account for 92 percent of total swine 

slaughter, Table 4. Given their large share of the market and 

the ability to slaughter a sufficient amount of market hogs to 

justify the likely costs associated with NSIS, these 

establishments are expected to voluntarily implement the 

proposed NSIS. Therefore, this analysis calculates the costs and 

benefits associated with the voluntary provisions for these 40 

market hog establishments. However, because the 5 HIMP 

establishments are already practicing the proposed NSIS methods, 

they are not expected to incur any additional new costs nor 

contribute to any increase in quantified benefits associated 

with adopting the NSIS. 

 1 HACCP size: Very Small Establishment = Less than 10 employees or less than 

$2.5 million in annual sales; Small Establishment = 10-499 employees; Large 

Establishment = 500 or more employees. 2 In 2016 there was 1 large establishment that did not exclusively slaughter 

market hogs. 
1

Brook, Mark - FSIS

From: Pugliese, Andrew - FSIS

Sent: Thursday, July 27, 2017 2:02 PM

To: Hammar, Melissa - FSIS

Subject: RE: Swine modernization - FSIS Staffing 

Thank you for keeping me in the loop.  This doesn’t change anything on my side.  

From: Hammar, Melissa - FSIS 

Sent: Thursday, July 27, 2017 1:56 PM 

To: Pugliese, Andrew - FSIS 

Subject: FW: Swine modernization - FSIS Staffing 

FYI. 

From: Wagner, Roberta - FSIS 

Sent: Wednesday, July 26, 2017 5:04 PM 

To: Hammar, Melissa - FSIS 

Cc: Edelstein, Rachel - FSIS 

Subject: Re: Swine modernization - FSIS Staffing 

I think that is fine for proposal ‐  

Sent from my iPhone 

On Jul 26, 2017, at 2:37 PM, Hammar, Melissa ‐ FSIS <Melissa.Hammar@fsis.usda.gov> wrote: 

(b) (5)

(b) (5)
2

From: Sidrak, Hany - FSIS 

Sent: Wednesday, July 26, 2017 1:25 PM 

To: Wagner, Roberta - FSIS; Edelstein, Rachel - FSIS; Michael, Matthew - FSIS; Hammar, Melissa - FSIS 

Cc: Smith, William C. - FSIS; Kiecker, Paul - FSIS; Gilmore, Keith - FSIS 

Subject: FW: Swine modernization - FSIS Staffing 

  

Happy to further discuss.  Thank you.  Hany

From: Hammar, Melissa - FSIS 

Sent: Tuesday, July 25, 2017 10:58 AM 

To: Sidrak, Hany - FSIS 

Cc: Edelstein, Rachel - FSIS; Wagner, Roberta - FSIS; Michael, Matthew - FSIS 

Subject: RE: Swine modernization: 1-3 online inspectors

  

From: Hammar, Melissa - FSIS 

Sent: Tuesday, July 25, 2017 10:27 AM 

To: Sidrak, Hany - FSIS 

Cc: Edelstein, Rachel - FSIS; Wagner, Roberta - FSIS; Michael, Matthew - FSIS 

Subject: Swine modernization: 1-3 online inspectors

(b) (5)

(b) (5)

(b) (5)
3

  

Hi Hany,

As requested, here’s the section of the preamble that talks about how FSIS may assign 1‐3 inspectors 

per line.

(b) (5)