Workplace Safety and Health: Additional Data Needed to Address Continued Hazards in the Meat and Poultry Industry
Published: 2016-04-25T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: DOL is responsible for gathering data on workplace injuries and illnesses, including those in the meat and poultry industry, where workers may experience injuries and illnesses such as sprains, cuts, burns, amputations, repetitive motion injuries, and skin disorders. GAO was asked to examine developments since its 2005 report, which found this industry was one of the most hazardous in the United States and that DOL data on worker injuries and illnesses may not be accurate, and recommended that DOL improve its data collection.
This report (1) describes what is known about injuries, illnesses, and hazards in the meat and poultry industry since GAO last reported, and (2) examines DOL's challenges gathering injury and illness data in this industry. GAO analyzed DOL data from 2004 through 2015, including injury and illness data through 2013, the most recent data available, and examined academic and government studies and evaluations on injuries and illnesses. GAO interviewed DOL and other federal officials, worker advocates, industry officials, and workers, and visited six meat and poultry plants selected for a mix of species and states. The information gathered in these visits is not generalizable to all plants or workers.
section_title: What GAO Found
paragraphs: Injury and illness rates in the meat and poultry slaughtering and processing industry declined from 2004 through 2013, similar to rates in all U.S. manufacturing, according to Department of Labor (DOL) data (see figure), yet hazardous conditions remain. The rates declined from an estimated 9.8 cases per 100 full-time workers in 2004 to 5.7 in 2013. However, these rates continued to be higher than rates for manufacturing overall. Meat workers sustained a higher estimated rate of injuries and illnesses than poultry workers, according to DOL data. Centers for Disease Control and Prevention (CDC) evaluations and academic studies have found that workers continue to face the hazardous conditions GAO cited in 2005, including tasks associated with musculoskeletal disorders, exposure to chemicals and pathogens, and traumatic injuries from machines and tools.
DOL faces challenges gathering data on injury and illness rates for meat and poultry workers because of underreporting and inadequate data collection. For example, workers may underreport injuries and illnesses because they fear losing their jobs, and employers may underreport because of concerns about potential costs. Another data gathering challenge is that DOL only collects detailed data for those injuries and illnesses that result in a worker having to take days away from work. These detailed data do not include injuries and illnesses such as musculoskeletal disorders that result in a worker being placed on work restriction or transferred to another job. Further, DOL does not have complete injury and illness data on meat and poultry sanitation workers because they may not be classified in the meat and poultry industry if they work for contractors. Federal internal control standards require agencies to track data to help them make decisions and meet their goals. These limitations in DOL's data collection raise questions about whether the federal government is doing all it can to collect the data it needs to support worker protection and workplace safety.
section_title: What GAO Recommends
paragraphs: GAO is making three recommendations, including that DOL improve its data on musculoskeletal disorders and sanitation workers in the meat and poultry industry. DOL, USDA, and CDC concurred with GAO's recommendations.

section_title: Letter
paragraphs: Workers in the meat and poultry slaughtering and processing industry  face numerous workplace hazards, including slippery floors, high-speed  repetitive tasks, dangerous equipment and tools, high-pressure water,  and chemical exposure. The Department of Labor’s (DOL) Occupational  Safety and Health Administration (OSHA) is the federal agency  responsible for assuring safe and healthful working conditions, in part by  enforcing related workplace safety and health standards for this and other  industries. DOL’s Bureau of Labor Statistics (BLS) gathers and reports  data on worker injury and illness rates. In 2005, we found that the meat  and poultry slaughtering and processing industry was one of the most  hazardous in the United States, and that DOL’s data may not accurately  reflect plants’ incidences of injury and illness because of underreporting.  The Department of Agriculture’s (USDA) Food Safety and Inspection  Service (FSIS), which is responsible for ensuring food safety for meat and  poultry products, as well as catfish and processed egg products, began  implementing a pilot project in 1998 at certain poultry and hog plants that  allowed for increased slaughter line speeds at evisceration, among other  things. In 2013, we found that some stakeholder groups were concerned  that these faster line speeds endanger worker safety. In 2014, USDA  decided not to increase the maximum evisceration line speeds for chicken  plants, and slightly increased maximum line speeds for turkey plants.
You asked us to review issues related to meat and poultry worker safety.  This report (1) describes what is known about injuries, illnesses, and  hazards in the meat and poultry industry since we last reported, and (2)  examines what, if any, challenges DOL faces in gathering data on injury  and illness rates in this industry.
To describe what is known about worker injuries, illnesses, and hazards  in the meat and poultry industry since we last reported and to examine  the challenges that DOL faces in gathering data, we obtained and  analyzed the most recent data available from:
BLS’s Survey of Occupational Injuries and Illnesses (SOII) for  calendar years 2004 through 2013, including rates of various injuries  such as musculoskeletal disorders (MSD) that resulted in days away  from work in calendar year 2013;
BLS’s Census of Fatal Occupational Injuries (CFOI) for calendar  years 2004 through 2013 to better understand the number of fatalities  and the hazards that may have caused them;
BLS’s pilot study on MSDs, collected from 2011 through 2013, to  obtain more information on the occurrence of MSDs and the  challenges of collecting data on them;  the Current Population Survey (CPS), which is sponsored jointly by  BLS and the Census Bureau, from March 2015 to describe how the  demographics of meat and poultry workers may pose a challenge to  gathering data; and
BLS’s Occupational Employment Statistics (OES) survey data from  May 2014 to describe wage levels of meat and poultry workers.
To assess the reliability of the data, we reviewed documents related to  the data sources and interviewed agency officials knowledgeable about  these data. All estimates produced from the analysis of these data are  subject to sampling errors. We express our confidence in the precision of  the results as a 95 percent confidence interval. We found these data were  sufficiently reliable for our purposes in generally describing injury and  illness rates as well as worker demographics.
In addition, we reviewed literature from peer-reviewed journals, OSHA  documents, and the Centers for Disease Control and Prevention’s (CDC)  National Institute for Occupational Safety and Health’s (NIOSH) health  hazard evaluations in the meat and poultry industry that focused on  factors that affected injury and illness rates and hazards since we last  reported.
To examine the challenges DOL faces in gathering data on injuries and  illnesses, we reviewed relevant federal laws and regulations, as well as  documentation from OSHA and NIOSH, and interviewed officials from  OSHA (including officials from all 10 regional OSHA offices), FSIS, and  NIOSH. We also identified and interviewed 13 stakeholder groups  (unions, worker advocacy groups, and industry trade organizations) with  sufficient knowledge about worker safety in the meat and poultry industry,  in part based on previous work and on referrals from other stakeholder  groups, and reviewed information we obtained from these groups. In  addition, we visited six meat and poultry plants—selected to cover a mix  of species and states, as well as union and non-union plants and two  plants that were part of the FSIS pilot project. We also interviewed plant  management, FSIS management and inspectors, and plant safety and  health staff. To assess DOL’s efforts based on the information gathered in  interviews and site visits, we used federal internal control standards that  call for agencies to track data and to undertake accurate and timely  recording to accomplish agency objectives. The information gathered  from these interviews and documents is not generalizable to all plants or  workers. The methodology described in this paragraph also helped inform  our examination of what is known about worker injuries, illnesses, and  hazards. See appendix I for more information on our scope and  methodology.
We conducted this performance audit from December 2014 to April 2016  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: According to March 2015 CPS data, an estimated 526,000 workers were  employed in the animal slaughtering and processing industry. There  were about 5,350 meat and poultry plants in the United States as of  September 2015, of which around 1,100 were slaughter and processing  plants, according to the USDA (see fig. 1). In 2014, more than 30 million  beef cattle, 100 million hogs, 200 million turkeys, and 8 billion chickens  were slaughtered in the United States, according to USDA’s National  Agricultural Statistics Service data.
Meat and poultry plants are generally designed for an orderly flow from  point of entry of the living animal to the finished food product. Typically,  the animal is brought to the meat or poultry plant and taken to the kill floor  area, where the slaughter occurs. Workers and machines behead and  eviscerate the animal, among other things, after which it is chilled for  several hours. FSIS inspectors ensure that the carcass meets federal  food safety standards. Workers and machines next process the carcass  and may break it into small portions that can be transported directly to  supermarkets. Slaughter and processing of meat and poultry require  workers to perform a high number of repetitive motions. Although plants  have increased automation, much of the work is still done by hand  through the use of saws, knives, and other tools (see fig. 2).
Workers may sustain many different types of injuries at meat and poultry  plants (see fig. 3).
To carry out its responsibilities under the Occupational Safety and Health  Act of 1970 (OSH Act), OSHA establishes workplace safety and health  standards, conducts inspections, investigates complaints from workers  and reports of fatalities and serious injuries at worksites, and provides  training and outreach, among other activities. To supplement its  enforcement efforts, OSHA offers cooperative programs to help  employers prevent injuries, illnesses, and fatalities in the workplace.  OSHA conducts inspections in response to imminent danger, fatalities,  catastrophic events such as hospitalizations, and worker complaints, and  also selects worksites for programmed inspections based on injury  incidence rates, previous citation history, or random selection. OSHA is  directly responsible for setting and enforcing these standards for private  sector employers, including meat and poultry plants, in 29 states, the  District of Columbia, and 4 U.S. territories. The remaining 21 states and  1 territory have assumed responsibility for workplace safety and health  under an OSHA-approved state plan. These “state-plan states” adopt and  enforce their own standards (which must be “at least as effective” in  providing safe and healthful employment as the federal standards).
The OSH Act and OSHA’s regulations require covered employers to  prepare and maintain records of certain injuries and illnesses sustained  by their workers. Specifically, non-exempt employers are required to  record information about every work-related death and each new work- related injury or illness that results in loss of consciousness, days away  from work, restricted work or transfer to another job, or medical treatment  beyond first aid. OSHA has established three different forms for  employers to record injuries and illnesses: the Form 300 Log of Work- Related Injuries and Illnesses (log), the Form 301 Injury and Illness  Incident Report (incident report), and the Form 300-A Summary of Work- Related Injuries and Illnesses. For each recordable injury or illness, the  employer must record specified information on the log, including the  worker’s name, job title, date of injury or illness, a brief description of the  injury or illness, and, if applicable, the number of days the worker was  away from work, assigned to restricted duties, or assigned to another job  as a result of the injury or illness. Employers must also classify the injury  or illness according to categories provided on the OSHA log. These  categories include injury, skin disorder, respiratory condition, poisoning,  hearing loss, and “all other illnesses.” In addition to the log, for each case  employers must prepare an incident report, which includes descriptive  information about the case, including details about the injury or illness,  how it occurred, and the treatment provided. Finally, employers are also  required to prepare a summary of all injuries and illnesses annually,  which is to be posted at the workplace. Although these three forms are  not routinely provided to OSHA, they must be kept for 5 years and  provided upon request in certain circumstances, such as during an OSHA  inspection or in response to BLS’s SOII. In addition, all covered  employers, including those exempt from the routine recordkeeping  requirements, must report all work-related fatalities to OSHA within 8  hours and all work-related in-patient hospitalizations, amputations, or  losses of an eye within 24 hours.
With respect to federal employers, such as USDA, each federal agency is  generally required to establish and maintain a comprehensive and  effective occupational safety and health program that is consistent with  OSHA’s standards. The mission of USDA’s Safety and Health  Management Division is to develop department-wide policies and  promote and assist the development of USDA safety programs. USDA’s  FSIS occupational safety and health program has safety and health  committees that may analyze injury and illness data to identify the cause  of an injury and develop preventative measures, among other things.  FSIS safety and health specialists investigate safety concerns of FSIS  inspectors in meat and poultry plants.
BLS is responsible for collecting and distributing statistical information on  issues related to labor, and one of the studies it conducts is the SOII.  Employers’ OSHA logs are the main source of data for the annual SOII.  In addition to collecting information on all recorded injuries and illnesses,  the survey, which draws from a sample of about 230,000 employers,  requests detailed case data from employers for injuries or illnesses that  resulted in at least 1 day away from work. This detailed case data  includes information on the type, or nature, of the injury or illness and the  exposure, or event, that caused it. OSHA officials told us that they use  these data to help them develop national and regional emphasis  programs that focus on specific industries or worksite hazards, and to  select high hazard workplaces to receive OSHA support and assistance.
Within the Department of Health and Human Services (HHS), CDC’s  NIOSH is the federal agency that conducts occupational safety and health  research and workplace evaluations, and makes recommendations to  prevent worker injuries and illnesses. At the request of employees,  employee representatives, or employers, NIOSH may conduct a health  hazard evaluation at a work site, such as a poultry plant, to determine if  health hazards—such as chemical exposure or ergonomic hazards—are  present. NIOSH provides assistance and information by phone and in  writing to the requester and may visit the workplace to assess exposure  and employee health.
USDA, under the Federal Meat Inspection Act and the Poultry Products  Inspection Act, is responsible for ensuring the safety and wholesomeness  of meat and poultry products that enter interstate commerce. In 2013,  over 3,700 USDA FSIS inspectors worked in meat and poultry plants to  provide continuous inspection of each meat and poultry carcass and its  parts. Among other regulations, USDA sets maximum line speeds for  slaughter plants in order to allow FSIS inspectors sufficient time to  perform proper inspection procedures.
section_title: Federal Data Show a Decline in Injuries and Illnesses, Yet Meat and Poultry Workers Continue to Face Hazardous Conditions
subsections: section_title: Federal Data Show a Decline in Injury and Illness Rates for Meat and Poultry Workers
paragraphs: Injury and illness rates of total recordable cases in the meat and poultry  industry declined from an estimated 9.8 cases per 100 full-time workers in  calendar year 2004 to 5.7 cases in 2013, according to BLS data (see fig.  4). The decline is comparable to all U.S. manufacturing, which dropped  from an estimated 8.2 cases to 5 cases per 100 full-time workers.  However, the rates in the meat and poultry industry remained higher than  those of manufacturing from 2004 through 2013.
While injury and illness rates have declined in the meat and poultry  industry, meat workers sustained a higher estimated rate of injuries and  illnesses than poultry workers from calendar years 2004 through 2013,  according to BLS data (see fig. 5). For example, in calendar year 2013  there were an estimated 7.8 cases per 100 full-time workers in meat  slaughter and 5.4 cases for meat processing, compared to an estimated  4.5 cases for poultry slaughter and processing.
The highest rates of injuries that resulted in days away from work in 2013  fell under the category of traumatic injuries—defined by BLS as injuries  occurring from a single event over the course of a work shift—and  included sprains, strains, and tears (see table 1). BLS collects data for  injuries and illnesses that resulted in days away from work in order to  understand the types of injuries and illnesses occurring and the events  leading to them. BLS reports these data per 10,000 full-time workers— versus the rate per 100 full-time workers that is used for all injuries and  illnesses. We are unable to show rates for these types of injuries over the  past 10 years because BLS’s changes to some injury classifications in  2011 prevent direct comparisons over time. (Additional information on  injury and illness rate estimates is contained in appendix I.)
The events that led to injuries or illnesses that resulted in days away from  work also varied (see table 2). In calendar year 2013, “overexertion and  bodily reaction,” a term BLS uses to capture injuries and illnesses  resulting from activities such as overexertion when lifting and repetitive  motion, was cited most frequently as the event that led to an injury  (estimated 40.1 per 10,000 full-time workers). This is consistent with the  findings in our 2005 report that back sprains and strains among meat and  poultry workers can be caused from lifting heavy objects or repetitive  lifting of lighter objects.
Some injuries have resulted in fatalities. According to BLS fatality data,  151 meat and poultry workers sustained fatal injuries in calendar years  2004 through 2013.  Over that time, transportation incidents were the  most frequent cause of death. For example, in calendar years 2011  through 2013, 46 meat and poultry workers sustained fatal injuries and 19  of these fatalities were caused by transportation incidents, such as being  struck by a vehicle. Other causes of fatalities included violence from a  person or animal, contact with objects or equipment, and exposure to  harmful substances or environments.
Meat and poultry workers experienced higher illness rates than other  manufacturing workers (see fig. 6). In calendar year 2013, there were an  estimated 159.3 cases per 10,000 full-time meat and poultry workers,  compared to an estimated 35.9 cases for manufacturing overall. To  better understand illness rates, OSHA classifies total recordable cases of  illnesses into five categories, such as skin diseases and respiratory  conditions, which BLS reports per 10,000 workers. In the meat and  poultry industry, illnesses accounted for over one-fourth of all reported  injury and illness cases in calendar year 2013. According to BLS’s  website, working conditions can be difficult in the meat and poultry  industry because workers are exposed to hazards that may lead to an  injury or an illness. In 2013, BLS categorized the poultry industry (104.2  cases per 10,000) and part of the meat industry—animal (except poultry)  slaughtering—(319.7 cases per 10,000) as high-rate industries for  illnesses because these industries had the highest incidence rate of total  illness cases, compared to other industries with at least 500 cases.
USDA data show that its inspectors experience injuries and illnesses  similar to those experienced by other meat and poultry workers.  According to USDA’s 2014 workers’ compensation claims data, falls,  slips, and trips were the most frequent causes of injuries among meat and  poultry inspectors. USDA inspectors at plants we visited told us injuries  and illnesses among inspectors vary, depending on whether they work in  a meat or poultry plant. Specifically, inspectors told us that compared to  inspectors in poultry plants, inspectors in meat plants sustain more cuts  or lacerations because they make several cuts during hog and cattle  inspections, while poultry inspections generally do not require any cuts to  animal carcasses. Additionally, they said inspectors in poultry plants  sustain more repetitive motion injuries due to faster line speeds. Some  inspectors experience respiratory ailment symptoms due to chlorine used  in poultry plants, according to USDA inspectors.
section_title: Evaluations, Studies, and Stakeholder Views Indicate that Hazardous Work Conditions Persist
paragraphs: Since our findings in 2005 on meat and poultry workers facing hazardous  work conditions, NIOSH health hazard evaluations and academic  studies have found that meat and poultry workers continue to face the  types of hazards we cited, including hazards associated with  musculoskeletal disorders, chemical hazards, biological hazards from  pathogens and animals, and traumatic injury hazards from machines and  tools. NIOSH’s findings are generally supported by OSHA documents  and academic literature we reviewed, as well as by statements from  workers and worker advocacy groups. (See appendix II for more  information on NIOSH’s findings the from eight health hazard evaluations  in poultry plants we reviewed.) In addition, other factors, such as  employer emphasis on safety, worker training, and line speeds, may  affect hazards and the risk of injuries and illnesses, according to literature  we reviewed and the workers and officials we interviewed from federal  agencies, the meat and poultry industry, and worker advocacy groups.
Assessing hand activity and force used by
Reviewing lab testing conducted by other  causes of eye and respiratory irritation  After NIOSH completes an evaluation, the  agency typically makes recommendations to  the employer on how to reduce or eliminate  identified hazards and prevent related injuries  and illnesses. According to officials, NIOSH  disseminates the results of its evaluations as  broadly as possible to help make industry- wide improvements even though evaluations  focus on individual plants. According to  NIOSH’s 2014 annual report, NIOSH received  209 requests and completed 33 field  investigation reports and 118 consultation  letters.
Meat and poultry work continues to require forceful exertions, awkward  postures, and repetitive motions for many job tasks, which can lead to  injuries. In a 2015 health hazard evaluation of a poultry plant, NIOSH  reported 59 percent of the 32 job tasks evaluated—from receiving to  deboning—had average levels of hand activity and force above the  American Conference of Governmental Industrial Hygienists threshold  limit value, and carpal tunnel syndrome among workers likely resulted  from repetitive motion and the forceful nature of these job tasks.  Similarly, in a 2014 health hazard evaluation of a poultry plant, NIOSH  found 41 percent of participants worked in jobs that had levels of hand  activity and force above the American Conference of Governmental  Industrial Hygienists threshold limit values. In a 2008 NIOSH health  hazard evaluation of a turkey plant, NIOSH found that hanging and  unloading racks of turkey franks (hot dogs) during processing increased  the risk of musculoskeletal disorders due to awkward postures, repetitive  motions, and heavy lifting. According to the evaluation, in raw and  cooked production, workers hung and removed franks from racks on 50- inch metal rods weighing up to 38 pounds, and reported discomfort in  their backs and shoulders. NIOSH’s recommendations included job  redesign and job rotation from lifting to non-lifting tasks to alleviate these  hazards. Workers we interviewed also said that the repetitive nature of  meat and poultry work leads to injuries. For example, one meat worker  with more than 20 years of experience told us he almost constantly  experiences discomfort and pain in his hands and that he only gets relief  when he is not working.
subsections: section_title: Chemical Hazards
paragraphs: Chemicals are a hazard in meat and poultry plants because they can  create a harmful environment if they accumulate within an enclosed  space. Findings from two NIOSH health hazard evaluations suggested  that exposure to chlorine may be associated with self-reported symptoms  of respiratory illness or eye irritation. In its 2012 evaluation, NIOSH  found that employees in an exposed group were more likely to report  certain work-related symptoms than employees in an unexposed group,  including chest tightness; sneezing; blurry vision; and burning, itchy, or  dry eyes. NIOSH also found that while chlorine levels met USDA  requirements, chlorine-related by-products called chloramines were often  implicated as a more likely cause of irritation. According to NIOSH,  there is no valid air sampling method to consistently detect levels of this  by-product in plants. Hazardous chemicals in meat and poultry plants also  include ammonia, which is used as a refrigerant. For example, a state  OSHA official told us process safety management related to ammonia  handling is among the top three violations in the meat and poultry  industry. An OSHA regional official said common injuries in the meat  and poultry industry stem from chemicals such as chlorine and ammonia,  among other things.
Peracetic acid, an antimicrobial agent used to kill bacteria on poultry  carcasses, may be harmful to workers. In November 2011 and January  2012, OSHA inspected a poultry plant after the death of a USDA  inspector who worked there, including conducting chemical sampling at  the plant. A regional OSHA official told us that OSHA suspected chemical  exposure as the cause of death for the USDA inspector. According to  OSHA and USDA officials, OSHA was unable to attribute the cause of  death to any work-related conditions. In a June 2014 USDA letter to  OSHA, USDA stated that it conducted additional air sampling at the  poultry plant and did not detect any antimicrobial chemicals. However,  according to an OSHA 2014 news release, OSHA cited the plant for,  among other violations, failure to provide employees with information and  training about the hazards of products that contain peracetic acid and  bleach, as required by OSHA’s hazard communication standard. This  citation was upheld by the Occupational Safety and Health Review  Commission. The administrative law judge who upheld the hazard  communication citation noted that employees told the OSHA compliance  officer they had experienced respiratory ailment symptoms and rashes  consistent with the exposure symptoms described in the chemical  manufacturer’s safety data sheets, but the employer failed to train  workers on chemical hazards, according to OSHA.
section_title: Biological Hazards— Pathogens and Animals
paragraphs: Meat and poultry workers continue to be exposed to biological hazards  associated with handling live animals, including contact with feces, blood,  and bacteria, which can increase their risk for many diseases, according  to a NIOSH evaluation and investigations we reviewed. In a 2012 health  hazard evaluation, NIOSH investigated exposure to the pathogen  Campylobacter in a poultry plant and found gastrointestinal illness  appeared to be common, yet underreported, based on interviews with  workers. In the live hang area at poultry plants, workers lift live poultry  from the supply conveyer belt and hang the birds by their feet from a  shackle conveyor belt. In doing so, workers can be covered with poultry  feces and dust that can carry pathogens and other diseases, according to  OSHA. NIOSH observed that the 20 air vents above the heads of the live  hang area employees could spread contamination, and it advised the  plant to modify the supply vents. NIOSH also observed inconsistent hand  hygiene and use of personal protective equipment in the area and  recommended the plant provide training to all employees. In response,  the plant instituted a monthly safety training meeting; offered  computerized training in English and Spanish, including a competency  test; and provided required personal protective equipment at no cost to  employees, including smocks and safety glasses, as well as optional  respirators and face shields in the live hang area. According to NIOSH,  the number of plant employees with confirmed cases of Campylobacter  infection dropped from 21 in 2011 to 6 in 2013 once these preventative  measures were implemented.
In 2007, NIOSH assisted CDC and the Indiana, Minnesota, and Nebraska  departments of health in their investigations of a progressive neurological  disorder among workers in three hog slaughter plants, and in 2008  NIOSH conducted a health hazard evaluation at the hog slaughter plant in  Minnesota. These plants had replaced saws with compressed air  devices to reduce the risk of amputation, but the devices increased brain  tissue splatter, causing a neurological disorder in several workers when  they inhaled the animal matter, according to state officials. According to  state and NIOSH investigators, workers at two of the plants also said line  speed was a factor because the faster speeds meant they were unable to  place the skulls completely on the device before triggering the  compressed air, causing greater splatter. According to state officials, no  new cases emerged after the three plants discontinued use of  compressed air devices and the brain removal job task.
section_title: Traumatic Injury Hazards— Machines and Tools
paragraphs: Dangerous machines and tools remain a hazard within the meat and  poultry industry, according to OSHA officials, workers we interviewed, and  an academic study we reviewed. According to OSHA, moving machine  parts can cause severe workplace injuries, such as crushed fingers or  hands, amputations, burns, or blindness. OSHA officials we spoke with  cited a lack of machine guarding—safety features on manufacturing  equipment to prevent contact with the body or to control hazards from the  machine—as a top safety violation at meat and poultry plants. Workers  we spoke with experienced injuries from this hazard. For example, one  meat worker showed us his scarred hand and said it had been caught in a  machine, which crushed his finger and removed skin, necessitating a skin  graft. Another worker’s apron was caught in a machine, which pulled her  arm in before the machine could be turned off. As a result, she told us  she can no longer work or perform daily activities with that arm. In  addition to machinery, meat and poultry workers frequently use tools such  as sharp knives, hooks, and saws. An academic study we reviewed  examining the incidence of injuries, lacerations, and infections among  poultry and pork processing workers employed by 10 companies found  sharp tools were most frequently reported as sources of lacerations. A  former meat worker we interviewed said he was injured twice by a  neighboring worker’s hook when the other worker moved too close to him  while trying to perform his task (see fig. 7).
section_title: Additional Factors May Affect Hazardous Conditions
paragraphs: Emphasis on worker safety, training, and line speeds may affect the risk  of injuries and illnesses in the meat and poultry industry, but the  underlying conditions remain, according to literature we reviewed, NIOSH  health hazard evaluations, and interviews with federal officials, workers,  and representatives of worker advocacy and industry groups.
Emphasis on worker safety: Emphasis placed on worker safety is a  factor affecting workplace hazards, according to workers we  interviewed and representatives from worker advocacy and industry  groups. Some workers told us plants do not emphasize safety even  when workers complain about hazardous conditions, but workers from  two plants we visited said their company has a strong emphasis on  worker safety. In at least half of the NIOSH health hazard evaluations  we reviewed, NIOSH recommended or encouraged implementing  worker safety programs or OSHA’s safety guidelines to help resolve  identified hazards. Industry officials and a worker advocacy group told  us plants should emphasize safety because it is in their best interest.  Representatives from a worker advocacy group and industry officials  told us that larger employers in the meat and poultry industry tend to  have better worker safety practices than smaller ones.  Representatives of meat and poultry industry associations also  highlighted the implementation of worker safety programs in some  plants over the last 20 years. In one study we reviewed, the authors  suggested that workplace safety practices—such as the importance of  safety to management, worker training, and proper use of safety  equipment—can be modified to improve hazardous conditions in  poultry plants.
Training: Worker training is critical to mitigating hazards and ensuring  safety in the meat and poultry industry, but it remains a challenge,  according to industry officials and workers with whom we spoke. In at  least half of the NIOSH health hazard evaluations we reviewed,  NIOSH recommended implementing proper training of workers.
However, industry officials said providing proper training can be a  challenge because of different languages spoken by workers. For  example, staff at two plants we visited said there are at least 20  languages spoken in their plants. At most of the plants we visited,  managers told us that workers receive training during orientation and  additional training may include annual training and working side-by- side with an experienced worker on the production line. Workers told  us new hires receive video training on hazards and personal  protective equipment, and acknowledge receipt of this training by  signing an attestation document. Some meat and poultry workers told  us the training is not always adequate. A hog plant worker said  supplementary training should be provided on the job and at slower  line speeds to ensure workers know how to do their jobs properly.  One study we reviewed found that when workers in Nebraska and  Iowa hog plants used an alternative method to accomplish a task,  such as using different equipment, or performed a task in a different  location within the plant, it was associated with increased risk of  lacerations. The authors recommended expanded training and  evaluation of tool sharpening procedures.
Line speed: High line speeds resulting from increased automation and  other factors may exacerbate hazards, according to plant workers and  worker advocacy groups. In 2013, 15 stakeholder groups petitioned  OSHA and USDA, asking OSHA to establish a “work-speed”  workplace safety and health standard—a regulation that would set the  number of animals or products processed per minute on a production  line in relation to staffing levels—to protect workers in the meat and  poultry industry. The petition also requested that USDA and OSHA  ensure that worker safety be protected in any rulemaking related to  line and work speeds in this industry. USDA acknowledged receipt of  the petition in 2013 and officials told us the agency made several  changes to the poultry inspection final rule that addressed some of the  issues in the petition, namely not increasing the maximum  evisceration line speed in young chicken plants. In 2015, OSHA  denied the petition and cited limited resources as its reason for not  conducting a comprehensive analysis and rulemaking. Plant  workers told us that meat and poultry plants are primarily concerned  with production, and employers do not want the line to slow down  even when the plant is understaffed. Industry officials we met with  disagreed. According to representatives of a meat industry trade  association, staffing is typically increased when line speed increases,  and it is important to staff the line so that plant workers and USDA  inspectors can accomplish all work tasks effectively. According to  NIOSH officials, increasing line speed and workers may increase the  risk of “neighbor cuts” due to workers’ close proximity. OSHA and  NIOSH officials told us line speed—in conjunction with hand activity,  forceful exertions, awkward postures, cold temperatures, and other  factors such as rotation participation and pattern—affects the risk of  both musculoskeletal disorders and injuries among workers. NIOSH  examined the effect of increased evisceration line speed on worker  safety at one plant in a 2014 health hazard evaluation, but the agency  could not draw conclusions about its impact. Specifically, NIOSH  stated in a 2014 letter to USDA that it could not draw conclusions on  line speed and safety because the amount of time between the first  and second visits (10 months) was not sufficient for a change in  workers’ health to appear and the manner in which the plant modified  the production lines resulted in no change in exposure to risk factors  for musculoskeletal disorders for any individual worker, among other  things. NIOSH stated that the plant’s consolidated evisceration lines  resulted in a reduction of the number of birds processed because the  plant combined two separate lines at 90 birds per minute into one line  operating at approximately 170 birds per minute. In a 2015 health  hazard evaluation, NIOSH found hand activity and force above  recommended levels, as noted above, and after the evaluation the  plant automated several jobs; however, the agency concluded that  musculoskeletal disorder risks remain for many workers.
section_title: DOL Faces Challenges Gathering Data on Injury and Illness Rates Because of Industry Characteristics and Inadequate Data Collection
subsections: section_title: Meat and Poultry Worker Vulnerability and Employer Practices May Contribute to Underreporting of Injuries and Illnesses
paragraphs: Workers and employers may underreport injuries and illnesses in the  meat and poultry industry because of worker concerns over potential loss  of employment, and employer concerns over potential costs associated  with injuries and illnesses, according to federal officials, worker advocacy  groups, and studies. As a result, the injury and illness rates discussed in  the previous section may not reflect complete data. In 2009, we reported  on concerns about underreporting across all industries, including  discrepancies between BLS’s annual survey used to calculate injury and  illness rates and other data such as medical records. Due to concerns  about reporting and also in response to findings and recommendations  from our work in 2005 and 2009, OSHA undertook its Injury and Illness  Recordkeeping National Emphasis Program. For this program, OSHA  inspected recordkeeping and reporting accuracy in a nongeneralizable  sample of over 300 establishments, primarily in industries with high  average rates of injuries and illnesses. A 2013 analysis of data from this  program indicates that OSHA identified reporting errors at establishments  it inspected, but the prevalence of underreporting cannot be determined  based on these data. While OSHA and BLS recognize that  underreporting exists, the extent is unknown.
Underreporting continues to occur in the meat and poultry industry,  according to worker advocacy groups and selected OSHA hazard alert  letters we reviewed. Some meat and poultry workers may be less likely  to report injuries and illnesses because of their vulnerable status as  undocumented or foreign-born workers, according to federal officials and  representatives of worker advocacy groups we interviewed. About 28.7  percent of meat and poultry workers were foreign-born noncitizens in  2015 compared to about 9.5 percent of all manufacturing workers,  according to CPS data. The meat and poultry industry has been a  starting point for new immigrants, as many jobs require little formal  education or prior experience, according to a meat industry trade  association. According to an OSHA official, worker advocacy groups, and  plant managers at one plant we visited, some employers in the meat and  poultry industry recruit refugees—in part, to replace undocumented  workers—and some companies hire prison labor. Further, according to  data from BLS, the meat and poultry industry had an hourly mean wage  of $12.50 per hour in 2014 and an annual mean wage of $26,010. While  above the federal minimum wage of $7.25 per hour, these wages are just  above the 2014 federal poverty guidelines for a family of four.  Workers  who face economic pressures or have a tenuous immigration status may  fear job loss or deportation if they report or seek treatment for work- related injuries and illnesses, according to federal officials and worker  advocacy groups. For example, a community-based doctor told us that  soon after he approved some injured meat workers’ work restriction  requests, they returned and asked him to send a note to their workplace  to end their work restriction because their employer had threatened to fire  them if they could not do their jobs. Language barriers can also make it  difficult for some of these workers to communicate about and report  injuries, according to a worker advocacy group. In addition, NIOSH  officials told us that in some cultures someone who reports an injury or  illness is considered weak.
Some meat and poultry industry employers may not record worker injuries  and illnesses because of certain disincentives, according to federal  officials and representatives of worker advocacy groups we interviewed.  We previously found that generally, employers may not record workers’  injuries and illnesses because of disincentives such as fear of increasing  their workers’ compensation costs or jeopardizing their chances of being  awarded contracts for new work. Federal officials and representatives of  worker advocacy groups we interviewed told us that some employers in  the meat and poultry industry may underreport workplace injuries to keep  workers’ compensation insurance premiums low. In addition, some  employers may underreport to avoid triggering OSHA inspections or  promote the image of a safe workplace, according to a worker advocacy  group and managers at one plant we visited. At one meat plant we  visited, workers recalled incidents in which supervisors told injured  workers they were not hurt and to go back to work rather than report their  injury. NIOSH officials and a worker advocacy group attribute some  underreporting in the meat and poultry industry to lack of paid sick leave,  which may cause injured or ill workers to stay on the job so they can get  paid. For example, some poultry plants use point systems to track sick  days and may penalize workers for taking too many, according to worker  advocacy groups. A former meat worker who was injured on the job told  us he was suspended for three days after taking time off from work to  recover and was later terminated. Workers and representatives of worker  advocacy groups told us these systems discourage workers from  reporting their injuries and illnesses. OSHA officials also expressed  concerns that employer-sponsored safety programs with incentives— such as those that offer rewards for no injuries over time—may pressure  meat and poultry workers to not report work-related injuries and  illnesses.
Plant health units, which provide certain types of medical assistance to  workers with injuries and illnesses at some plants, may also discourage  reporting of injuries and illnesses, according to OSHA and worker  advocacy groups. In an effort to maintain a clean safety record and  avoid recording injuries in their OSHA logs, some plant health units may  repeatedly offer first aid treatments—for example, compresses and over- the-counter painkillers and ointments—rather than refer workers to a  doctor, according to two OSHA hazard alert letters, worker advocacy  groups, and workers we interviewed.  We were told about multiple  incidents in which meat and poultry workers were punished for visiting the  health unit too often or ignored by heath unit staff when they sought  further medical care. For example:  In 2014, OSHA sent a hazard alert letter to a poultry plant,  recommending that the plant voluntarily take steps to improve its  medical management practices. In the letter, OSHA identified  practices that were contrary to good medical practice for managing  work-related MSDs, including prolonged treatment by nursing station  staff without referral to a physician. The letter included one example in  which a worker made over 90 visits to the nursing station before  referral to a physician.
In 2015, OSHA sent a hazard alert letter to another poultry plant, also  recommending voluntary improvements to the plant’s medical  management practices. The letter noted that based on OSHA’s  investigation, it appeared that the plant used its first aid station to  prevent injuries from appearing on the plant’s OSHA log, such as by  not referring workers to a physician for evaluation or treatment when  appropriate.
One worker told us that after he fell off a platform, the health unit  provided ice and denied his request to be referred to a physician for x- rays. When he received an x-ray several days later, it confirmed that  he had a fracture.
A representative of a worker advocacy group told us about an incident  in which a nurse gave a worker with an injured wrist some cream and  sent him home. The worker sought medical treatment on his own,  which confirmed that he had a fractured wrist.
Meat and poultry industry representatives said underreporting is not a  major issue, although some employers may not understand all of the  reporting requirements. A meat industry trade association we interviewed  noted that they organize seminars on reporting requirements and  encourage employers to record all incidents in order to document  improvement and avoid OSHA citations. Industry group representatives  also stated that the decline in injury and illness rates discussed above is  due in part to increased automation and industry efforts to enhance plant  safety. OSHA officials concurred that increased automation in the industry  has positively affected safety in limited areas of meat and poultry plants.
section_title: DOL Lacks Information That Could Help It Address Meat and Poultry Workers’ Musculoskeletal Disorders
paragraphs: DOL lacks key information about MSDs in the meat and poultry industry  because of the way it gathers information on these conditions. It is  particularly challenging to gather data on MSDs because the gradual  nature of these injuries makes it harder for workers to recognize and  report them, according to experts and worker advocacy groups. As  discussed earlier, existing federal data and health hazard evaluations  suggest that MSDs in the meat and poultry industry are common and can  be disabling. In 2013, the incidence rate of MSDs that resulted in at least  1 day away from work was an estimated 39.2 cases per 10,000 workers  in the meat and poultry industry overall and 25.2 cases per 10,000  workers in the poultry industry, according to BLS’s SOII. The 2013  incidence of carpal tunnel syndrome—an MSD—for cases that resulted in  days away from work in the meat and poultry industry was an estimated  4.1 cases per 10,000, compared to 2.1 cases per 10,000 for  manufacturing overall. A 2015 health hazard evaluation of a poultry  plant by NIOSH found that over one-third of the workers who participated  in the study had evidence of carpal tunnel syndrome. A 2014 NIOSH  health hazard evaluation of poultry plant workers found that over two- thirds of workers interviewed reported experiencing pain, burning,  numbness, or tingling in their hands over the preceding 12 months and  that over half reported pain, aching, or stiffness in their backs during the  same timeframe (see fig. 8).
OSHA and worker advocacy groups have also documented the  debilitating effects of MSDs. OSHA reports, for example, that MSDs can  be painful and disabling, and may cause permanent damage to  musculoskeletal tissues.
Despite these concerns, DOL lacks information about MSDs in the meat  and poultry industry because of how the data are collected. Specifically,  BLS’s annual SOII only collects injury and illness details—such as the  type of injury or illness—on cases that result in workers having to take  days off from work. For example, the survey does not collect detailed  information on MSDs that resulted in a worker being placed on work  restriction, transferred to a different job, or continuing in the same job  after medical treatment, making it more difficult to identify and track these  MSDs. From 2011 to 2013, BLS conducted a pilot study, for which the  SOII was modified to collect data for six selected industries (including  food manufacturing) on the case circumstances and worker  characteristics for cases where the worker was placed on work restriction  or transferred to a different job. This pilot study found many of the MSDs  occurring in the food manufacturing industry—which includes the meat  and poultry industry—result in the worker being transferred to other jobs  or restricted from activity in a current job without days away from work.  For each calendar year from 2011 through 2013, the BLS study found  that far more MSD cases in the food manufacturing industry resulted in  job transfer or restricted work than in days away from work. For example,  in 2013, the most recent data available, there were about 13,000 cases  with job transfer or restricted work in this industry, compared to about  6,000 with days away from work.
The OSHA log, which employers use to respond to BLS’s SOII, also does  not specifically classify recorded injuries or illnesses as MSDs. For each  injury or illness recorded on the log, OSHA requires employers to check  off a column indicating whether it is an injury or one of four specified  types of illnesses: skin disorder, hearing loss, poisoning, or respiratory  condition. Otherwise, the employer is to check “all other illnesses” (see  fig. 9). However, the OSHA log does not include a place where employers  can check off whether a recorded injury or illness is an MSD. Such  information would only be included in the incident report, which is  maintained by the employer and generally not sent to OSHA or BLS.  Attempting to compile MSD data using individual incident reports would  be difficult.
A former OSHA official said the agency added these columns to the log  because OSHA determined that tracking these particular conditions was  important to overseeing worker safety and health. Having these columns  enables OSHA to more easily distinguish specific illnesses and conditions  from other recorded cases.
Before 2001 the OSHA log included a column for “repeated trauma”  cases, which included some, but not all, MSDs, as well as some non- MSD cases such as hearing loss. OSHA revised its recordkeeping  regulations in 2001 and replaced this column with two, one column for  MSDs and another for hearing loss. However, the MSD column never  went into effect, and in 2003, the agency deleted the MSD column after  determining the column was not necessary or supported by the record.  Some public commenters had also expressed concern that the column  was not necessary, did not clearly define MSDs, and imposed a  paperwork burden. Because the column was deleted, the current OSHA  log does not specifically classify MSDs, although MSDs must be recorded  as injuries or illnesses on the log if they meet the criteria in OSHA’s  recordkeeping regulations. In 2010, OSHA again proposed a rule that  would have required employers to check off in a separate column on the  OSHA log whether an already-recorded injury or illness was an MSD,  stating that information generated from the column would improve the  accuracy and completeness of national occupational injury and illness  statistics, provide valuable industry-specific information to assist the  agency in its activities, inform workers and employers, and would not be  cost-prohibitive. However, the Department of Labor Appropriations Act,  2012 prohibited any funds from being used for the MSD column proposed  rule. The prohibition was extended by the 2013 appropriations act, but  was not included in subsequent appropriations. Since then, OSHA has  not attempted to add an MSD column to the OSHA logs.
OSHA officials told us that it is vital to have accurate data on MSDs in the  meat and poultry industry, and OSHA stated in its 2010 proposed rule to  add a column to track MSDs that data from the column would assist the  agency in targeting its inspections, outreach, guidance, and enforcement,  among other things. BLS officials told us it would be a significant  improvement if there were data that would quantify the extent of MSDs,  as current data collection methods fall short. Although they stated they  did not see a need for a column, representatives of trade associations for  the meat and poultry industry we interviewed agreed that tracking MSDs  at the plant level helps employers prevent and respond to these  injuries. More MSD data would be helpful to OSHA and researchers,  and a column on the OSHA injury log dedicated to MSDs could also make  it simpler for employers to calculate their MSD rates, according to  representatives of worker advocacy groups. Currently, employers must  examine numerous entries in their OSHA injury log to calculate these  rates. According to CDC, the first step in addressing health issues such  as injuries is obtaining a full understanding of the extent of the problem.  Federal internal control standards also call for accurate and timely  recording to accomplish agency objectives. Without improving data on  MSDs, BLS’s statistics on these conditions will remain limited and  OSHA’s efforts to oversee employers and ensure workplace safety and  health will continue to be hindered.
section_title: DOL Lacks Information on Injury and Illness Rates of Meat and Poultry Sanitation Workers
paragraphs: DOL does not know the extent to which injuries and illnesses occur  among meat and poultry sanitation workers—who may be employed  directly by a plant or work for a separate contract sanitation company— because of how data on these workers are collected. Although they  labor in the same plants and under working conditions that can be as  hazardous as those of production workers, in 2005 we found sanitation  workers employed by contract sanitation companies were not classified  by BLS in the SOII as working in the meat and poultry industry. We  concluded that OSHA, as a result, was not considering all injuries and  illnesses at a plant when selecting plants to be inspected because some  worker injuries and illnesses were not included in OSHA logs at those  sites. We recommended that DOL require certain plants to provide OSHA  with worksite-specific data of injuries and illnesses of workers employed  by contract cleaning and sanitation companies so these data could be  included in the rates OSHA uses to select plants for inspection. DOL  did not implement this recommendation, citing a decision it had already  made against requiring employers in the construction industry to collect  contract worker data because of the burden to that industry, among other  things.
DOL has not taken action to improve data on sanitation workers, despite  continued concerns expressed by OSHA about how sanitation work by  both plant employees and contracted workers is one of the most  hazardous occupations in the industry. Many sanitation workers work  overnight during a plant’s “third shift” and are responsible for cleaning  floors, machinery, and all product contact surfaces throughout the plant to  comply with USDA requirements. Workplace hazards for sanitation  workers employed directly by plants and those employed by contract  sanitation companies include potential exposure to electrical, mechanical,  hydraulic, and other sources of energy and potentially harmful chemicals.  In 2013, for example, a 41-year-old sanitation worker was killed when he  fell into an industrial blender at a meat plant, according to a fatality  investigation report by the Oregon Fatality Assessment and Control  Evaluation program of the Oregon Institute of Occupational Health  Sciences. In 2015, according to an OSHA citation, a sanitation worker at  a poultry plant lost two of his fingertips when a machine he was cleaning  was mistakenly turned on. Two weeks later at the same plant, according  to the same citation, a 17-year-old sanitation worker lost part of his leg  when he was caught in a machine that lacked safety mechanisms.
Another challenge in tracking injury and illness rates among sanitation  workers is that even for those workers directly employed by meat and  poultry plants (as opposed to those working for a contractor), the plants  use different occupational titles for these workers on their OSHA logs.  Employers record the injured workers’ job titles on their OSHA log, then,  in its SOII, BLS codes these data using a standardized system. BLS  officials told us that under this system these workers’ occupations may be  listed as “janitors and cleaners,” “cleaners of vehicles or equipment,” or  other occupational categories such as “production workers-all other” or  “food processing workers-all other.” As a result of using these various  occupational titles, which may cover regular production workers as well,  DOL is not able to determine which injuries and illnesses pertain to meat  and poultry sanitation workers.
According to BLS, it also may not be possible to gather separate injury  and illness data on those meat and poultry sanitation workers who are  employed by contract sanitation companies. Under OSHA’s  recordkeeping requirements, either the contract sanitation company or  the plant may be required to track these workers’ injuries, depending on  which entity is providing day-to-day supervision. As a result, injury and  illness data for these workers in BLS’s SOII may be coded according to  their employer’s industry—janitorial services, for example—and would  therefore not be captured in injury and illness rates for the meat and  poultry industry. Officials at four of the six plants we visited told us that  the contract sanitation company they work with maintains the injury log for  these workers. Officials at one contract sanitation company told us that  both they and the plants with which they contract keep OSHA logs, and  that the data the company sends to BLS from its OSHA log are coded  under the “janitorial services” industry. BLS officials told us that it may  not be possible to require contract sanitation companies to identify the  industry of the companies they contract with because many of these  companies provide services to a wide variety of businesses.
As a result of how DOL gathers information on meat and poultry  sanitation workers’ injuries and illnesses, OSHA has little data to work  with when determining how to oversee these workers’ safety and health.  Federal internal control standards call for agencies to track data to help  them make decisions and meet their goals. According to OSHA,  inaccurate data can lead to misleading conclusions regarding incidence,  trends, causation, and effectiveness of abatement strategies. Because of  limitations in the BLS data on injuries and illnesses of workers in meat  and poultry plants, OSHA cannot fully assess the extent to which it is  fulfilling its worker safety mission or successfully carrying out its  enforcement and other activities. In addition, the agency may not be  doing all it can to ensure sanitation workers are protected from workplace  hazards.
Several new developments may make it easier for OSHA to obtain more  data on sanitation workers at meat and poultry plants. As of January  2015, employers covered by federal OSHA are required to report all work- related in-patient hospitalizations, amputations, and losses of an eye  directly to OSHA within 24 hours. Previously, OSHA received more  limited information on amputations and hospitalizations through direct  employer reports. Reports on such cases involving meat and poultry  sanitation workers may provide OSHA with additional details on injuries to  this population. In addition, in October 2015, OSHA initiated two regional  emphasis programs for the poultry industry in the southern United States.  These programs—along with an ongoing regional emphasis program on  poultry industry sanitation workers in the same region—mean OSHA will  conduct more poultry plant inspections and gather more data on risks to  sanitation and other workers, a former OSHA official told us.
OSHA may also be able to work with NIOSH to gather information about  sanitation worker injuries and illnesses. NIOSH officials told us that they  recently were able to conduct studies in other industries because OSHA  had negotiated their access after issuing citations. OSHA officials agreed  that NIOSH reports could be useful to their inspections. NIOSH’s last  health hazard evaluation of meat and poultry sanitation workers was  conducted in 2002. At that time, NIOSH examined the use of sanitizing  agents, such as bleach, in a meat processing plant, and analyzed their  connection to respiratory disorders among five sanitation workers in that  plant. All five sanitation workers reported symptoms consistent with  known irritant effects of bleach, such as throat irritation and burning or  stinging eyes, and the symptoms disappeared when the use of bleach  was discontinued. Since then, NIOSH has not conducted any additional  health hazard evaluations on meat and poultry sanitation workers, since  they must rely on plant management, workers, or worker representatives  to request a health hazard evaluation. However, NIOSH can also self- initiate studies on occupational safety and health issues and may conduct  studies in response to requests from federal, state, or local agencies.  In the absence of additional studies on meat and poultry sanitation  workers, both OSHA and NIOSH may be missing an opportunity to learn  more about the nature and extent of sanitation worker injuries and  illnesses.
section_title: Conclusions
paragraphs: While overall injury and illness rates have decreased since our last report,  meat and poultry workers continue to face worksite hazards that put them  at risk of severe and lasting injury. Obtaining complete information about  injuries and illnesses in the meat and poultry industry continues to be a  challenge that affects DOL’s ability to calculate accurate rates and ensure  safe and healthy workplaces. Recent OSHA inspections suggest that  more injuries occur than are reported, although the extent of  underreporting is not known, and vulnerable workers such as immigrants  and noncitizens may fear for their livelihoods and feel pressured not to  report injuries. Our findings raise questions about whether the federal  government is doing all it can to ensure it collects the data it needs to  support worker protection and workplace safety. Strengthening DOL’s  data collection on worker injuries and illnesses is the first step towards  achieving that goal. Collecting accurate and complete data on MSDs is  particularly important, because these disorders are common among this  workforce and can be severe and debilitating. However, OSHA does not  have a cost-effective method for distinguishing MSDs from other recorded  cases, hindering OSHA’s efforts to ensure workplace safety and health. In  addition, OSHA and BLS continue to face challenges determining the  rates of injury and illness among meat and poultry sanitation workers.  Until DOL is able to gather more complete data on sanitation workers in  these plants, it does not have an accurate picture of total injuries and  illnesses in the meat and poultry industry, and it cannot know how to best  protect these sanitation workers. New developments provide an  opportunity for DOL to learn more about the injuries and illnesses  suffered by these workers and to develop ways to better track them.  NIOSH, the federal agency responsible for researching workplace safety  and health, may be well-placed to conduct an in-depth study on the  injuries and illnesses experienced by this population.
section_title: Recommendations for Executive Action
paragraphs: We are making the following three recommendations:  To strengthen DOL’s efforts to ensure employers protect the safety and  health of workers at meat and poultry plants, the Secretary of Labor  should direct the Assistant Secretary for Occupational Safety and Health,  working together with the Commissioner of Labor Statistics as  appropriate, to develop and implement a cost-effective method for  gathering more complete data on MSDs.
To develop a better understanding of meat and poultry sanitation workers’  injuries and illnesses:
The Secretary of Labor should direct the Assistant Secretary for  Occupational Safety and Health and the Commissioner of Labor  Statistics to study how they could regularly gather data on injury and  illness rates among sanitation workers in the meat and poultry  industry.
The Secretary of Health and Human Services should direct the  Director of the Centers for Disease Control and Prevention to have  NIOSH conduct a study of the injuries and illnesses these workers  experience, including their causes and how they are reported. Given  the challenges to gaining access to this population, NIOSH may want  to coordinate with OSHA to develop ways to initiate this study.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Secretary of Labor, the Secretary  of Agriculture, and the Secretary of Health and Human Services for their  review and comment. DOL and HHS provided comments, reproduced in  appendixes IV and V, respectively. DOL generally agreed with our  recommendations and stated that their implementation would make a  difference in working conditions in the meat and poultry industry. DOL  also noted that it may not be easy to implement our recommendations  due to resource constraints. We are pleased that DOL agreed with our  recommendations.
HHS concurred with our recommendation to have NIOSH conduct a study  of the injuries and illnesses of sanitation workers in the meat and poultry  industry. HHS noted the previous difficulties NIOSH has had gaining  access to these workplaces and the potential resource commitment  involved in conducting such a study. In the report we acknowledged the  access challenge and noted that OSHA has negotiated access for NIOSH  in other industries, which is why we suggested in the recommendation  that NIOSH may want to coordinate with OSHA.
USDA generally agreed with our findings and recommendations, and  provided technical comments, which we incorporated as appropriate.
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section_title: Appendix I: Scope and Methodology
paragraphs: This report (1) describes what is known about injuries, illnesses, and  hazards in the meat and poultry industry since we last reported, and (2)  examines what, if any, challenges the Department of Labor (DOL) faces  in gathering data on injury and illness rates in this industry.
To describe what is known about injuries, illnesses, and hazards in the  meat and poultry industry since we last reported, we analyzed and  reported survey data from DOL’s Bureau of Labor Statistics’ (BLS) Survey  of Occupational Injuries and Illnesses (SOII) for calendar years 2004  through 2013 (the most recent year for which data were available). The  SOII provides estimates of the number and frequency (incidence rates) of  workplace injuries and illnesses by industry and also by detailed case  circumstances, such as injury type and event, and worker characteristics  for cases that result in days away from work, based on data from logs  kept by employers (survey respondents)—private industry and state and  local governments. Survey respondents provide counts for all recordable  injuries and illnesses under Occupational Safety and Health  Administration (OSHA) recordkeeping regulations. Survey respondents  also provide additional information for a subset of cases, specifically  those that involved at least 1 day away from work. In 2011, the BLS  Occupational Injury and Illness Classification System and definitions of  some injuries changed, thereby preventing direct comparison of case  characteristics over time. We report estimates of detailed case  characteristics from various injuries and illnesses, such as carpal tunnel  syndrome, that resulted in days away from work in the most recent  calendar year available, 2013.
To report SOII data from the meat and poultry industry (using North  American Industry Classification System (NAICS) code 31161 for the  animal slaughtering and processing industry) and manufacturing overall  (NAICS codes 31-33), BLS provided estimates of each industry’s injury  and illness incidence rates and their associated relative standard errors.  All estimates produced from the analysis of the SOII data are subject to  sampling errors. We express our confidence in the precision of the results  as a 95 percent confidence interval. This is the interval that would contain  the actual population value for 95 percent of the samples the respective  agency could have drawn. For estimates derived from BLS’s SOII data,  we used the agency-provided relative standard errors to estimate the  associated confidence intervals. All estimates we report have the  associated 95 percent confidence interval provided.
We also reviewed BLS’s Census of Fatal Occupational Injuries (CFOI)  data for calendar years 2004 through 2013, the most recently available  data, to better understand the number of fatalities and their  circumstances, including causes in the meat and poultry industry. The  CFOI is a federal-state cooperative program that has been implemented  in all 50 states and the District of Columbia since 1992. According to BLS,  the CFOI program uses diverse state, federal, and independent data  sources to identify, verify, and describe fatal work injuries to ensure  counts are as complete and accurate as possible. CFOI compiles a count  of all fatal work injuries occurring in the United States during the calendar  year. Fatal injury counts exclude illness-related deaths unless precipitated  by an injury event. As previously stated, in 2011 the classification  systems and definitions of some data elements changed, and this change  may not allow comparing CFOI data within specific fatality categories to  previous years. Therefore, we reported total fatalities over a 10-year  period rather than annual totals within each major fatality category.
To assess the reliability of BLS SOII and CFOI data, we reviewed  documents related to the data sources, such as BLS’s Handbook of  Methods, and we interviewed agency officials knowledgeable about these  data. We found that SOII and CFOI data were sufficiently reliable for our  purposes in generally reporting estimated incidence rates of injuries and  illnesses in the meat and poultry industry and manufacturing overall,  describing injuries and illnesses, and reporting total fatalities in the meat  and poultry industry.
We also obtained and reviewed fiscal year 2014 workers’ compensation  data from USDA’s Food Safety and Inspection Service (FSIS) to describe  the injuries, illnesses, and hazards experienced by inspectors in meat and  poultry plants. USDA’s workers’ compensation data includes injuries and  illnesses from workers who filed a workers’ compensation form. A  limitation of this data source is that workers’ compensation data likely  undercounts injuries and illnesses. To assess the data’s reliability, we  interviewed agency officials, reviewed documentation on FSIS’s workers’  compensation program, and checked the data for discrepancies. We  found the data were sufficiently reliable for our purposes.
We reviewed literature from peer-reviewed journals, Centers for Disease  Control and Prevention’s (CDC) National Institute for Occupational Safety  and Health (NIOSH) health hazard evaluations, and OSHA guidance  documents on factors that affected injury and illness rates and hazards in  the meat and poultry industry since we last reported.
We conducted a literature search for studies that examined factors  affecting injury and illness rates, as well as hazards in the meat and  poultry industry. Based on our literature review, we reported  information from four peer-reviewed studies. To identify studies from  peer-reviewed journals, we conducted searches of various databases,  such as Web of Science, Scopus, and ProQuest and requested  suggestions from officials we interviewed. We further limited our  review to studies on meat and poultry workers only; therefore, we  excluded any studies that made comparisons between workers in the  meat and poultry industry and other industries. From this review, we  identified 19 studies that appeared in peer-reviewed journals between  2005 and 2015. Of the 19 studies, we excluded two studies that  summarized findings from two NIOSH health hazard evaluations that  we had previously obtained and reviewed. We noted that 8 of the 17  studies relied on a community-based approach to obtain participants  rather than recruiting them directly from plants. These studies focused  exclusively on a subset of the worker population within the meat and  poultry industry, namely women and Hispanic or Latino poultry  workers in North Carolina. We included observations from 1 of the 8  studies, which focused on Hispanic poultry workers, but we noted  study limitations in the report. We included findings from 3 of the other  9 studies: (1) a study on a neurological disorder experienced by  workers in three hog plants that illustrated hazards related to animals,  (2) a study on lacerations in meatpacking describing hazards related  to machines and tools, and (3) a study on laceration injuries  experienced by meat and poultry workers employed by 10 companies  representing 22 poultry plants and 8 pork plants to illustrate factors  that may affect injury and illness rates in the meat and poultry  industry.
We identified and reviewed eight NIOSH health hazard evaluations  published from 2007 to 2015 that describe various hazards in poultry  plants, as well as factors that may affect injury and illness rates in this  industry. NIOSH officials told us the agency has not conducted  similar evaluations in meat plants to those it conducted in poultry  plants because the agency has not received any requests to do so.  Findings from NIOSH evaluations we reviewed are not generalizable  to illustrate hazards in all poultry processing plants in the United  States.
We reviewed OSHA guidance documents on hazards in meat and  poultry plants, including OSHA’s e-Tool for poultry processing which  details workplace hazards by job task in the poultry industry.
To examine the challenges DOL may face in gathering data on injury and  illness rates in this industry, we reviewed relevant federal laws and  regulations, as well as OSHA documentation. We also reported BLS data  and reviewed documentation on musculoskeletal disorders (MSD),  including a pilot study on cases involving job transfer and work restriction  from data collected from 2011 through 2013. We obtained and analyzed  data on worker demographics from the Current Population Survey (CPS),  jointly sponsored by BLS and the Census Bureau, from March 2015, the  most recent data available. We assessed the reliability of CPS data by  reviewing documentation, interviewing knowledgeable agency officials,  and performing electronic data testing, and determined the data were  sufficiently reliable for our purposes. Because the CPS estimates are  based on probability samples, they are subject to sampling error. For the  CPS estimates in this report, we estimated sampling error and produced  confidence intervals using the methods provided in the technical  documentation of CPS’s March 2015 supplement. To report wages of  meat and poultry workers, we used estimates of average annual and  monthly wages for slaughterers and meat packers (Standard  Occupational Classification code 513023) in the animal slaughtering and  processing industry (NAICS 31161) and their associated relative-standard  errors from BLS’s Occupational Employment Statistics (OES) survey data  from May 2014. We used the relative-standard errors to calculate 95  percent confidence intervals for estimates derived from BLS’s OES  survey data. We found the BLS and CPS data were sufficiently reliable for  our purposes. We interviewed OSHA officials—including officials from all  10 regional OSHA offices—and FSIS and NIOSH officials. We also  interviewed Georgia Tech Research Institute staff who conducted  research on sanitation workers in the poultry industry to learn about  hazards faced by sanitation workers in the meat and poultry industry.  Moreover, to describe challenges in gathering data on sanitation workers,  we reviewed a 2002 NIOSH evaluation on sanitation workers and  interviewed one sanitation company that provides cleaning services in the  meat and poultry industry. Of the two other sanitation companies we  approached, one declined to meet with us and other company did not  respond to our request.
To respond to both objectives, we interviewed representatives from  stakeholder groups and visited several meat and poultry plants. We  identified and interviewed 13 stakeholder groups (unions, worker  advocacy groups, and industry trade organizations) with sufficient  knowledge about worker safety in the meat and poultry industry, in part  based on previous work as well as referrals from other stakeholder  groups. We also reviewed information obtained from these groups. These  stakeholder groups were the American Federation of Government  Employees/National Joint Council of Food Inspection Locals, the  Government Accountability Project, Legal Aid of North Carolina, the  National Chicken Council, the National Council for Occupational Safety  and Health, the National Turkey Federation, Nebraska Appleseed, the  North American Meat Institute, Oxfam America, the Southern Poverty  Law Center, Student Action with Farmworkers, the United Food and  Commercial Workers International Union, and the U.S. Poultry and Egg  Association. We attended a meat industry conference on worker safety,  as well as a worker safety conference organized by the National Council  for Occupational Safety and Health. Finally, we visited six meat and  poultry plants—selected to cover a mix of species (chicken, turkey, hog,  and cattle) and states (Missouri, Nebraska, North Carolina, and Virginia),  as well as union and non-union plants and two plants that were part of the  FSIS pilot project—where we met with plant management, USDA’s FSIS  management and inspectors, and plant safety and health staff. We also  met with current and former workers, who were selected either by unions,  worker advocacy groups, or plant managers. The information gathered in  these interviews is not generalizable to all plants or workers. To assess  DOL’s efforts based on the information gathered in interviews and site  visits, we used federal internal control standards that call for agencies to  track data and to undertake accurate and timely recording to accomplish  agency objectives.
We conducted this performance audit from December 2014 to April 2016  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Summary of Selected Health Hazard Evaluations in the Poultry Industry Conducted by the National Institute for Occupational Safety and Health, 2007-2015
paragraphs: The National Institute for Occupational Safety and Health (NIOSH)  conducted eight health hazard evaluations published from 2007 to 2015  that describe various hazards in poultry plants. Table 3 presents a  summary of selected findings and recommendations from these health  hazard evaluations. Selected findings on hazards are not generalizable to  all poultry processing plants in the United States. This table is not  intended to be a complete list of NIOSH’s findings and recommendations;  for more complete information, refer directly to the cited NIOSH health  hazard evaluation.
section_title: Appendix III: OSHA’s Form 300—Log of Work-Related Injuries and Illnesses
section_title: Appendix IV: Comments from the Department of Labor
section_title: Appendix V: Comments from the Department of Health and Human Services
section_title: Appendix VI: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to the contacts named above, Blake Ainsworth, (Assistant  Director), Mary Denigan-Macauley (Assistant Director), Eve Weisberg  (Analyst-in-Charge), Nkenge Gibson (Analyst-in-Charge), Leah English,  Monika Gomez, Susan Aschoff, James Bennett, Sarah Cornetto, and  Lorraine Ettaro made significant contributions to this report.
Also contributing to this report were Diann Baker, Carl Barden, Carol  Bray, Angela Clowers, Marcia Crosse, Grant Mallie, Sheila McCoy, John  Mingus, and Michelle Sager.
section_title: Related GAO Products
paragraphs: Food Safety: USDA Needs to Strengthen Its Approach to Protecting  Human Health from Pathogens in Poultry Products. GAO-14-744.  Washington, D.C.: September 30, 2014.
Food Safety: More Disclosure and Data Needed to Clarify Impact of  Changes to Poultry and Hog Inspections. GAO-13-775. Washington,  D.C.: August 22, 2013.
Workplace Safety and Health: OSHA Can Better Respond to State-Run  Programs Facing Challenges. GAO-13-320. Washington, D.C.: April 16,  2013.
Workplace Safety and Health: Further Steps by OSHA Would Enhance  Monitoring of Enforcement and Effectiveness. GAO-13-61. Washington,  D.C.: January 24, 2013.
Workplace Safety and Health: Multiple Challenges Lengthen OSHA’s  Standard Setting. GAO-12-330. Washington, D.C.: April 2, 2012.
Workplace Safety and Health: Enhancing OSHA’s Records Audit Process  Could Improve the Accuracy of Worker Injury and Illness Data.  GAO-10-10. Washington, D.C.: October 15, 2009.
Workplace Safety and Health: Safety in the Meat and Poultry Industry,  While Improving, Could Be Further Strengthened. GAO-05-96.  Washington, D.C.: January 12, 2005.
Food Safety: Weaknesses in Meat and Poultry Inspection Pilot Should Be  Addressed Before Implementation. GAO-02-59. Washington, D.C.:  December 17, 2001.
Community Development: Changes in Nebraska’s and Iowa’s Counties  with Large Meatpacking Plant Workforces. GAO/RCED-98-62.  Washington, D.C.: February 27, 1998.