Workplace Safety and Health: Safety in the Meat and Poultry Industry, While Improving, Could Be Further Strengthened
Published: 2005-01-12T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Because meatpacking is one of the most dangerous industries in the United States, we were asked to provide the Congress with information on the characteristics of workers in the meat and poultry industry and the conditions in which they work, the types of injuries and illnesses these workers incur, how injury and illness rates have changed over the past decade, and factors that may have affected these rates. We were also asked to determine what is known about the effectiveness of the Occupational Safety and Health Administration's (OSHA) efforts to improve safety and health in the meat and poultry industries.
section_title: What GAO Found
paragraphs: The largest proportions of workers in the meat and poultry industry, according to the Bureau of Labor Statistics (BLS), are young, male, and/or Hispanic. Although the majority of workers are citizens, an estimated 26 percent of them are foreign-born noncitizens. They work in hazardous conditions involving loud noise, sharp tools, and dangerous machinery. Many workers must stand for long periods of time wielding knives and hooks to slaughter or process meat on a production line that moves very quickly. Workers responsible for cleaning the plant must use strong chemicals and hot pressurized water. While, according to BLS, injuries and illnesses have declined over the past decade, the meat and poultry industry still has one of the highest rates of injury and illness of any industry. The most common injuries are cuts, strains, cumulative trauma, and injuries sustained from falls, but more serious injuries, such as fractures and amputation, also occur. According to BLS, the injury and illness rate for the industry has declined from an estimated 29.5 injuries and illnesses per 100 full-time workers in 1992 to 14.7 in 2001. Injury and illness rates can be affected by many factors, such as the amount and quality of training, employee turnover rates, increased mechanization, and the speed of the production line. Some evidence suggests that OSHA's efforts have had a positive impact on the injury and illness rates of workers in meat and poultry plants. However, while the criteria OSHA uses to select plants for inspection--which focus on plants with relatively high injury and illness rates--are reasonable, OSHA could improve its selection process by also considering trends in plants' injury and illness rates over time. In addition, it is difficult to assess the effectiveness of OSHA's efforts because the agency does not assign a unique identifier to each plant, making it hard to compare the data it collects on specific plants' injury and illness rates with the information the agency collects on the results of its plant inspections and other programs.

section_title: Letter
paragraphs: According to data collected by the U.S. Department of Labor’s Bureau of  Labor Statistics (BLS), in 2003, an estimated 527,000 workers were  employed in the animal slaughtering and processing industry. According  to the U.S. Department of Agriculture (USDA), in 2004 there were about  5,700 meatpacking and processing plants in the United States. The modern  meatpacking and processing plant is a complex and highly organized  structure, developed for the streamlined slaughter and progressive  disassembly of animals. The industry includes plants in which animals are  slaughtered and cut into pieces, with some facilities also cooking and  packaging the meat for consumption, as well as plants in which meat  products, such as sausage and ham, are produced by adding ingredients to  the meat. The meat processed includes red meat such as beef, veal, pork,  and lamb, and poultry such as chicken and turkey.
Because meatpacking is one of the most dangerous industries in the  United States, you asked us to (1) describe the characteristics of workers  in meat and poultry slaughter and processing plants and the conditions in  which they work; (2) identify the types of injuries and illnesses workers in  meat and poultry slaughter and processing plants incur, how the injury  and illness rates have changed over the past decade, and the factors that  may affect these rates; and (3) determine what is known about the  effectiveness of the Occupational Safety and Health Administration’s  (OSHA) efforts to improve safety and health at meat and poultry slaughter  and processing plants.
To respond to your request, we reviewed literature on the industry and  interviewed officials from OSHA and other federal agencies, such as USDA  and the Centers for Disease Control and Prevention’s National Institute for  Occupational Safety and Health (NIOSH) within the Department of Health  and Human Services (HHS), as well as individuals from contract cleaning  and sanitation companies, unions, advocacy groups, and key trade  associations. We obtained and analyzed    data on worker demographics from BLS’s Current Population Survey    data on workplace injuries and illnesses from BLS’s Survey of  Occupational Injuries and Illnesses,   data on fatalities from BLS’s Census of Fatal Occupational Injuries,    data from OSHA’s inspections database (the Integrated Management    worksite-specific injury and illness data that OSHA uses to target specific  worksites for inspection (the OSHA Data Initiative),   data on the number and location of meat and poultry plants from USDA’s  Performance Based Inspection System, and lists of plants that participate in OSHA’s cooperative programs.
In addition, we visited six meat and poultry plants and two OSHA area  offices and interviewed inspectors at four additional area offices, selected  because the offices had performed the most inspections of meat and  poultry plants. Finally, we conducted a survey of meat and poultry plants  to obtain data on their workers, factors that affect their injury and illness  rates, plants’ efforts to improve safety and health, and plants’ interactions  with OSHA. See appendix I for detailed information on the scope and  methodology for our work. We performed our work in accordance with  generally accepted government auditing standards between January 2004  and September 2004.
subsections: section_title: Background
paragraphs: According to USDA, there were about 5,700 total meat and poultry plants  in the United States as of September 2004. Most of these—about 4,400— had fewer than 40 employees, and about half of them are even smaller,  with fewer than 10 employees. Figure 1 shows the location of all meat and  poultry plants, regardless of size, in the United States as of September 1,  2004.
Over the past 25 years, the meat and poultry industry has consolidated, as  today’s leading firms built very large plants and some independent firms  disappeared or were bought by larger firms. While many small plants  remain, a few large companies have gained control of the lion’s share of  the market. Today, the top four meatpacking companies slaughter,  process, and package about 80 percent of the beef cattle in the United  States, and the top four pork producers control nearly 70 percent of the  market. The poultry industry is nearly as concentrated, with the top five  companies maintaining a market share in excess of 50 percent.  Consolidation of the various meat industries occurred, in large part,  because of innovations in technology and the relocation of plants near the  source of livestock.
Industry consolidation has been accompanied by significant changes in the  relations between organized labor and the management of meat and  poultry plants. According to a report by USDA’s Economic Research  Service, in 1980, 46 percent of workers in the meat products industry were  union members, a figure that had remained stable since the 1970s.  However, by the end of the 1980s, union membership had fallen to 21  percent. Declining rates of unionization coincided with increases in the  use of immigrant workers, higher worker turnover, and reductions in  wages. Immigrants make up large and growing shares of the workforces at  many plants. Labor turnover in meat and poultry plants is quite high, and  in some worksites can exceed 100 percent in a year as workers move to  other employers or return to their native countries. The frequent  movement of immigrant workers among plants and communities limits the  opportunities of unions to organize meat and poultry workers.
Most of today’s facilities are designed for an orderly flow from point of  entry of the living animal into the plant to the finished food product. The  animal enters the production facility and proceeds directly to the kill floor  area, where slaughter occurs. The carcass is beheaded, eviscerated, and  chilled for several hours. It is then taken to the cutting floor, where it is  cut into smaller cuts of meat. The new processing methods—breaking  down carcasses into small, vacuum-packed portions of meat that can be  shipped directly to supermarkets—have transformed the work into an  assembly line operation requiring workers to perform an increased  number of repetitive motions.
While slaughterhouses have come to rely on greater mechanization over  the last several decades, much of the work is still done by hand,  particularly when animals vary in size, shape, and weight. The main  slaughtering steps of evisceration and cutting are generally done by hand,  using knives. Figure 2 shows a typical assembly line operation at a poultry  plant.
OSHA, established after the passage of the Occupational Safety and Health  Act in 1970, is the federal agency within the Department of Labor  responsible for protecting the safety and health of workers in meat and  poultry plants. OSHA performs a number of functions, including  establishing safety and health standards, conducting routine inspections,  and conducting investigations in response to complaints from workers and  incidents such as fatalities.
Regional administrators in each of OSHA’s 10 regional offices oversee the  enforcement of federal policies within their own regions. Each region is  composed of area offices—of which there are 80 in total—overseen by  area directors. The area directors oversee compliance officers, who are  responsible for conducting inspections and following up on complaints,  and compliance assistance specialists, who provide assistance to  organizations and employers that participate in OSHA’s cooperative  programs. Compliance assistance specialists also help employers correct  hazards identified during inspections.
To determine which plants to inspect, OSHA relies on BLS data on  injuries, illnesses, and fatalities by industry. BLS surveys a sample of  employers annually (182,800 worksites were surveyed for 2002) and asks  them to report information on the number of work-related injuries and  illnesses that occur at their worksites. This information comes from injury  and illness records that most private industry employers with more than  10 employees are required by OSHA to maintain. From this information,  BLS calculates industry-level injury and illness rates. BLS also identifies  fatalities from an annual census of all 50 states, the District of Columbia,  and New York City, which report on all work-related fatalities within their  jurisdictions. BLS requires the reporting entities to corroborate reports of  fatalities from multiple sources, such as death certificates, medical  examiners’ reports, media reports, and workers’ compensation claims.  BLS makes injury, illness, and fatality data available at the national, as well  as at the state, level.
OSHA uses two approaches to ensure general employer compliance with  federal safety and health laws and regulations—enforcement and  cooperative programs. Enforcement, which represents the preponderance  of agency activity, is carried out primarily by using compliance officers to  inspect employer worksites. Worksites and employers that fail to meet  federal safety and health standards face sanctions, such as paying  penalties for violations of health and safety standards. OSHA’s cooperative  approach invites employers to collaborate with the agency through a  number of different programs and uses a variety of incentives to  encourage employers to reduce hazards and institute practices that foster  safer and healthier working conditions.
subsections: section_title: OSHA’s Enforcement Efforts
paragraphs: OSHA selects worksites in selected industries for inspection through its  site-specific targeting (SST) program and through national and local  programs that focus on specific hazards. The SST program focuses on  employers with more than 40 employees, who are required to record all  injuries and illnesses on a log and make this information available to  OSHA. Of the almost 40,000 inspections OSHA conducted in 2003, about  2,000 were SST inspections, and about 25,000 were conducted through  national and local emphasis programs. The agency also conducts  inspections when fatalities or serious injuries occur and when workers file  complaints about serious safety and health hazards. These inspections  constitute nearly half of the total inspections OSHA conducts annually.
For its SST program, OSHA obtains specific information—such as  employer names and addresses—for all worksites with 40 or more  employees, approximately 140,000 worksites each year. OSHA then selects  a portion of these worksites (approximately 80,000) in the industries with  the highest injury and illness rates, and sends them a survey form that  requires them to report (1) the average number of employees who worked  for them during the previous calendar year, (2) the total hours the  employees worked during the previous year, and (3) summary injury and  illness data from their OSHA logs. From this information, OSHA computes  the worksites’ injury and illness rates and sends those with relatively high  rates a letter informing them that they may be inspected. Finally, OSHA  compiles SST inspection targeting lists containing the names of worksites  with relatively high injury and illness rates for inspection.
OSHA also has special emphasis programs that focus on a particular safety  or health hazard or the hazards of a specific industry, selected by the  agency’s headquarters office for attention. While OSHA’s headquarters  provides direction to its area offices in implementing these national  emphasis programs, the area offices have considerable flexibility in  selecting actual worksites for attention. In addition, regional and area  offices use regional and local emphasis programs to highlight industries or  hazards within their jurisdictions that they believe are especially  hazardous.
Because musculoskeletal disorders are prevalent in several industries— including the meat and poultry industry—but there is no specific standard  that allows OSHA to cite employers for hazards relating to these injuries,  the agency designed a four-pronged approach to address these injuries  that focuses on industries and employers with known high injury and  illness rates. The approach includes (1) developing industry or task- specific guidelines for a number of industries based on current incidence  rates and available information about effective and feasible solutions;  (2) conducting inspections for ergonomic hazards, issuing citations under  the general duty clause of the Occupational Safety and Health Act, and  issuing ergonomic hazard alert letters where appropriate; (3) providing  assistance to businesses, particularly small businesses, and helping them  to proactively address ergonomic issues in the workplace; and (4)  chartering an advisory committee authorized to, among other things,  identify gaps in research about the application of ergonomics and  ergonomic principles in the workplace.
section_title: OSHA’s Cooperative Programs
paragraphs: OSHA’s cooperative programs provide incentives to employers, such as  free consultations, deferrals from SST inspections, and recognition for  exemplary safety and health management systems, for making  improvements to their safety and health management systems. OSHA has  implemented these programs incrementally to reach different employers  and worksites in various ways. OSHA has four primary programs: (1) the  On-Site Consultation Program, (2) the Voluntary Protection Programs,  (3) the Strategic Partnership Program, and (4) the Alliance Program.
The On-Site Consultation Program is a broad network of occupational  safety and health services primarily funded by federal OSHA, but is  delivered by the states. The service, which originated in 1974, focuses on  helping small employers comply with OSHA and state occupational safety  and health standards. The program assigns priority to companies in high- hazard industries and is offered free of charge to eligible employers.  States provide consultation visits at employers’ requests in order to  identify safety and health hazards and discuss techniques for their  abatement. Small employers receiving consultation services may qualify  for recognition in the Safety and Health Achievement Recognition  Program—part of the On-Site Consultation Program—which exempts  them from SST inspections during the period that their certification is  valid, either 1 or 2 years. Participants in this program, who are considered  models for good safety and health practices in their field, must have, at a  minimum, safety and health management systems in place to prevent and  control occupational hazards, as well as illness and injury rates below the  national average for their industry.
The Voluntary Protection Programs, established in 1982, recognize single  worksites with exemplary safety and health management systems. In  calendar year 2003, the average participating worksite had approximately  250 employees, and about 50 percent of the participating sites had 200  employees or less. To participate in this program, employers must have  worksites that exceed OSHA standards and must commit to a process of  continual improvement. After receipt of a site’s application, OSHA  conducts an onsite review of the site to verify the effectiveness of its  safety and health management system.
The Strategic Partnership Program, established in 1998, was designed to  address specific safety and health management systems in high-hazard  workplaces by promoting collaboration between employers, employees,  other affected organizations, and OSHA. Each partnership has a written  agreement that outlines goals (such as the reduction of injuries),  strategies, and measures, and identifies how the partners will work  together to achieve their desired results. Partnerships may focus on  specific hazards or industry issues, or may aim for broader impact through  focus on safety and health management systems. OSHA verifies partner  commitment and success in achieving goals, and while the program does  not offer employers exemption from inspection, it offers other incentives,  such as limiting SST inspections to only the most serious prevailing  hazards and reducing penalties for hazards cited during inspections.
OSHA’s Alliance Program targets trade, professional, and other types of  organizations to work collaboratively with OSHA to promote workplace  safety and health issues. In contrast to OSHA’s other three cooperative  programs, which typically include safety and health management systems  at specific employer worksites, alliance agreements focus on goals such as  training, outreach, and increasing awareness of workplace safety and  health issues. Alliance participants and their members are not exempt  from OSHA inspections and do not receive any enforcement-related  incentives for being part of an organization participating in an alliance.  Instead, OSHA officials informed us that trade and professional  associations have used the program to address existing and emerging  workplace safety and health issues, such as ergonomics.
In addition to these formal programs, OSHA conducts other compliance  assistance activities, such as outreach and training activities, to aid  employers in complying with OSHA standards and to educate employers  on what constitutes a safe and healthy work environment.
section_title: Meat and Poultry Workers Tend to Be Young, Male, and/or Hispanic, and Face Hazardous Working Conditions
paragraphs: The meat and poultry workforce tends to be young (43 percent under age  35), male (65 percent), and/or Hispanic (42 percent). These characteristics  are more pronounced in the meat and poultry industry than in the U.S.  manufacturing sector overall. Meat and poultry workers typically earn  substantially less than workers in the U.S. manufacturing sector as a  whole. Most large plants are located in the Midwest and South, and  workers in the industry often work in difficult and dangerous conditions.
subsections: section_title: Meat and Poultry Workers Are Predominantly Young, Male, and/or Hispanic, and Most Large Plants Are Located in the Midwest and South
paragraphs: Workers in the meat and poultry industry tended to be younger than  workers in the manufacturing sector as a whole, and almost all of the  workers are employed on a full-time basis. According to CPS data, in 2003,  the median age of workers in the meat and poultry industry was 37 years.  About 43 percent of all meat and poultry workers were under age 35,  compared with about 29 percent of all U.S. manufacturing workers.  These workers also tend to be male. In 2003, men made up 65 percent of  the workforce in the meat and poultry industry. In 2003, in this industry  and in U.S. manufacturing overall, about 95 percent of the employees  worked full-time.
The racial composition of the meat and poultry workforce is  disproportionately Hispanic. As shown in figure 3, according to the CPS, in  2003, about 42 percent of meat and poultry workers were Hispanic or  Latino, 32 percent were white, and 20 percent were black. These figures  compare with those for U.S. manufacturing as a whole, in 2003, where  about 14 percent of the workforce was Hispanic, about 70 percent was  white, and about 9 percent was black. Further, the percentage of Hispanic  or Latino meat and poultry workers in 2003 reflects a 17 percent increase  from 1994, when about 25 percent of meat and poultry workers were  Hispanic or Latino. In addition, in 1994, a larger percentage of the meat  and poultry workforce—46 percent—was white, and 25 percent was black.
Foreign-born noncitizens are more highly represented within the meat and  poultry workforce than in manufacturing as a whole. A significant  proportion—about 26 percent—of all workers in this industry are foreign- born noncitizens, compared with only about 10 percent of all  manufacturing workers in the United States. An even larger percentage of  the production and sanitation workers in the meat and poultry industry— 38 percent—are foreign-born noncitizens. In 1994, 28 percent of  production and sanitation workers were foreign-born noncitizens.
In certain areas of the United States, a number of communities have  concentrated groups of immigrant workers—including groups from  regions such as Central America, Southeast Asia, and Eastern Europe— who are employed in the meat and poultry industry. In such areas,  employees from these immigrant groups may make up a relatively large  percentage of the workforce and population in and around meat and  poultry plants. For example, in 2000, the population of one county in  Kansas (which, according to USDA, was one of the largest meat-producing  counties in the nation) was about 43 percent Hispanic, compared with  only 7 percent of the population in the state. According to some industry  officials, the increasingly fragmented nature of the tasks in slaughtering  and processing has diminished the need for a skilled and more highly paid  workforce, a fact that supports the industry’s recruitment and employment  of unskilled immigrant labor.
While plants are distributed throughout the United States, larger plants— those with more than 500 employees—tend to be concentrated in  particular regions and produce the majority of the meat. Of these larger  meat and poultry plants, about 87 percent are located in the South and the  Midwest, 54 percent and 33 percent, respectively. Another 9 percent are  located in the West and 4 percent in the Northeast. Figure 4 shows plants  with more than 500 employees.
Meat and poultry workers tend to earn substantially less than  manufacturing workers in general. In 2003, meat and poultry workers  earned a median salary of about $21,320 per year, while manufacturing  workers earned about $33,500 per year. In addition, the rate of employee  turnover among meat and poultry workers can be high. A plant official  with whom we spoke indicated that some workers who are hired have no  intention of staying for a long period of time and approach employment at  meat and poultry plants as a temporary arrangement. According to some  experts, high turnover may benefit plants because they save on some  costs, such as health benefits and vacation pay, while others argue that  high turnover is costly for plants because they must constantly recruit and  train new employees.
section_title: Workers Face Several Hazardous Conditions in Meat and Poultry Slaughter and Processing Plants
paragraphs: The work environment in meat and poultry plants can be risky because of  the current procedures used in the industry. Meat and poultry plants  present risks greater than those faced by workers in many other  manufacturing operations. For example, production lines can require  workers to stand close together while wielding tools necessary for cutting  pieces of meat. Final product processing involves a number of packaging  machines and conveyors that can present a wide range of safety risks to  workers. Workers are also frequently handling or in close proximity to  sources of infectious diseases, such as those carried by animal tissues and  organs. Pathogens can infect workers from open abrasions or through  inhalation. For example, hydrogen sulfide, methane, and carbon dioxide  can be released from decomposing animal manure and waste. In addition,  workers are exposed to many chemicals, including a range of gases, such  as ammonia, and Freon. Table 1 summarizes the hazardous working  conditions in meat and poultry plants.
section_title: Meat and Poultry Workers Are Injured in a Variety of Ways, and Their Injury and Illness Rates, though Declining, Remain among the Highest of Any Industry
paragraphs: Meat and poultry workers suffer high rates of many types of injuries and  illnesses, including those affecting the back, trunk, arms, fingers, and  wrists. Although injury and illness rates have declined over the last  decade, according to BLS, those in meat and poultry plants continue to be  among the highest of any industry.
subsections: section_title: Workers Sustain Many Different Types of Injuries and Illnesses
paragraphs: Workers in the meat and poultry industry, including contract cleanup and  sanitation workers, can suffer a host of serious injuries and illnesses, most  often musculoskeletal disorders. (See fig. 5 for an illustration of the types  of injuries workers suffer.) Many of the injuries—such as those to the  arms, hands, and wrists—are due to the repetitive motions associated with  the meat production process, such as performing the same cutting motions  over time, and can become crippling. For example, carpal tunnel  syndrome, caused by repetitive motion or cumulative trauma, can severely  damage a nerve running through the wrist.
Workers can also be cut by their own knives during the butchering and  cutting processes. For example, according to an OSHA publication, one  worker in a meatpacking plant was blinded when the knife he was using to  pick up a ham prior to boning slipped out of the ham, striking him in the  eye. The report also described an incident in which another worker’s face  was permanently disfigured when his knife slipped out of a piece of meat  and struck his nose, upper lip, and chin. In another incident, according to  OSHA, a worker who attempted to replace his knife in the scabbard  hanging from his belt missed the opening and pushed the knife into his leg,  severed his femoral artery, and died. In addition, workers can be cut by  the knives wielded by coworkers. According to OSHA’s report, these  “neighbor cuts” are usually the direct result of overcrowded working  conditions.
Other injuries that workers can experience include respiratory irritation  and, in some instances, asphyxiation from exposure to pathogenic  respiratory substances. For example, workers have died from being  overcome by hydrogen sulfide gas and from drowning when they entered  manure waste pits or unknowingly worked near manure waste “lagoons”  without taking the proper precautions, such as conducting an air test and  wearing a safety harness and respirator; such precautions are particularly  critical when workers are in confined spaces. According to OSHA, one  worker died from chemical exposure after being sprayed with 400 pounds  of toxic liquid ammonia while attempting to fix a pipe.
Workers may also suffer injuries and illnesses from contact with animals.  If the animals are still dying when they are hung on the line, they may  struggle and thrash about wildly, resulting in injuries that range from  broken arms to permanent disfigurement and—in the most severe cases— death. Contact with different bacteria can cause fever, headaches,  vomiting, diarrhea, and kidney damage. In addition, illnesses that can be  contracted from diseased animals continue to raise concerns. According  to USDA officials, the transmission of disease from animals to humans in  the meat and poultry industry is uncommon because of concerted efforts  in the United States and abroad. However, recent outbreaks of bovine  spongiform encephalopathy among cattle (commonly known as “mad cow  disease”) are related to incidences of a disease that affects humans,  according to the Centers for Disease Control and Prevention. While beef  consumption is recognized as a mode of infection, it is unknown whether  this disease can be transmitted in other ways, such as exposure to waste  or blood.
Workers can also suffer back injuries or other types of injuries from  overexertion, including sprains, strains, tears, hernias, and fatigue. They  can suffer injuries, and even death, from falling or being struck by an  object. For example, workers have been killed by falling ice and forklift  parts, and falls due in part to a lack of functioning safety devices. In one  incident, an employee was killed when a rack of sausage fell from a  manual overhead conveyor system and struck him.
Workers can be burned by heat sealant machines when they wrap meat.  Workers may also sever fingers or hands or even lose limbs on machines  that are either improperly locked or inadequately guarded. For example, in  2002, a sanitation worker at an Alabama plant lost both legs when another  worker activated the meat grinder in which he was standing. In another  incident, an employee dropped his knife into a meat grinder, reached in to  retrieve it, and suffered the amputation of his arm. In yet another incident,  an employee’s fingers were amputated when they were caught in the  mixing and blending machine he was operating.
Workers can be injured by falling on slippery floors and exposure to  extreme heat or cold. Such cold temperatures can stress joints and  exacerbate existing conditions such as arthritis and cardiovascular  illnesses. As shown in figure 5, workers may sustain many types of  injuries, and several different parts of the body may be affected.
As shown in figure 6, workers in the meat and poultry industry typically  wear several types of safety and other equipment in an effort to protect  themselves from injury and illness.
section_title: Injury and Illness Rates Have Declined but Remain among the Highest of Any Industry
paragraphs: Injury and illness rates in the meat and poultry industry fell steadily from  1992 to 2001, according to BLS data (see fig. 7). The meat and poultry  industry’s annual rate of incidence of illness and injury in 2001, at an  estimated 14.7 cases per 100 workers, was about half its 1992 rate of 29.5  cases. The incidence rate across all U.S. manufacturing dropped to about  two-thirds of its former rate over the same period, from 12.5 cases to 8.1  cases per 100 full-time workers.
Despite this decrease, injury and illness rates among meat and poultry  plants remain among the highest of any industry. According to BLS data on  injuries and illnesses, in 2002, meatpacking plants recorded an average  annual injury and illness rate of 14.9 cases per 100 full-time workers;  sausages and other prepared meats plants recorded a rate of 10.9 cases;  and poultry plants recorded a rate of 9.7 cases. The average annual injury  and illness rate for all U.S. manufacturing was 7.2 cases.
Within the meat and poultry industry, the incidence rate for specific  injuries and illnesses, as reported by employers, dropped in recent years.  According to BLS data on injuries and illnesses, for example, carpal tunnel  injuries dropped from 24 cases per 10,000 workers in 1992 to 6.8 cases in  2001; strains and sprains dropped from 189.4 cases to 51.9 cases;  tendonitis dropped from 23.6 cases to 3.5 cases; cuts and punctures  dropped from 76.2 cases to 17.9 cases; chemical burns dropped from 9.6  cases to 4.4 cases; and amputations dropped from 5.3 cases to 3.2 cases.
Compared with workers in all U.S. manufacturing industries, meat and  poultry workers sustain a higher rate of certain injuries, such as chemical  burns, amputations, heat burns, tendonitis, and carpal tunnel syndrome. In  2002, meatpacking workers suffered more of these types of injuries, but  relatively fewer sprains and strains and fractures. The rate of injuries and  illnesses involving repetitive motion in the meat and poultry industry at  22.2 cases per 10,000 full-time workers was one and a half times greater  than the rate of 14.7 for all U.S. manufacturing in 2002.
A number of injuries sustained by meat and poultry workers are fatal;  according to BLS fatality data, from 1992 to 2002, 229 workers died from  their injuries. Of the 229 worker deaths, almost one-quarter occurred off  plant property, rather than during production, in transportation accidents.  The deaths that occurred in plants over this period included 60 that were  caused by contact with objects and equipment (37 of these by being  caught in or compressed by equipment or objects, including running  machinery); 25 by falling; 35 from exposure to harmful substances; 4 from  fires and explosions; and 22 from assaults and violent acts, including  homicides.
BLS’s data on injuries and illnesses, however, may not accurately reflect  plants’ incidences of injury and illness. OSHA, researchers, and union  officials have all stated that the underreporting of injuries and illnesses is a  problem in the meat and poultry industry. In the late 1980s, after observing  what appeared to be underreporting of worker injuries, OSHA’s offices in  region 7 focused their attention on the meatpacking industry. Beginning  with an exhaustive review and reconstruction of a large Nebraska  meatpacker’s records, OSHA documented dozens of cases of  underreporting and assessed the company more than $2.5 million in  penalties. Because of OSHA’s findings during this inspection and others  like it, Congress held hearings on the underreporting of occupational  injuries from March to September 1987. In 1987, after a National  Academy of Sciences review of the methods BLS used to collect  employers’ injury and illness data highlighted several deficiencies, and in  response to the congressional hearings, BLS began a multi-year effort to  redesign and test an improved safety and health statistical system for  collecting these data, which was fully implemented in 1992. However, the  accuracy of employers’ occupational injury and illness data remains a  concern. OSHA conducted a series of record-keeping inspections of meat  and poultry plants in region 7 throughout the late 1980s and 1990s. As a  result of these inspections, several plants were assessed penalties for  record-keeping violations, including five plants that were assessed  penalties ranging from $290,000 to $998,360. OSHA continues to find some  measure of underreporting of employers’ injury and illness information  through the agency’s record-keeping audits each year.
In addition, we reported in 1998 that the U.S. Immigration and  Naturalization Service (now the Citizenship and Immigration Services) had  often found illegal aliens employed in meatpacking plants; one agency  official estimated that up to 25 percent of workers in meatpacking plants  in Nebraska and Iowa were illegal aliens. As recently as March 2004, as the  result of an internal audit, one large meatpacking company found 350  undocumented workers employed in one of its plants in the Midwest.  Because large numbers of meat and poultry workers are immigrants—and  perhaps employed illegally—they may fear retaliation or loss of  employment if they are injured and cannot perform their work, and they  may be hesitant to report an injury. Furthermore, according to data from  OSHA and academic researchers published in a BLS periodical, some  plants offer employees or groups of employees incentives, such as money  or other prizes, for maintaining low injury and illness rates. According to  the report, while these incentives may improve safety, they also may  discourage workers from reporting injuries that could result in their not  winning the incentive prize or preventing an entire group of workers from  obtaining the prize. In addition, some plants judge the performance of line  supervisors based on the number of days their workers go without an  injury or illness. These supervisors, also influenced by performance  incentives, may underreport injuries or encourage workers not to report  injuries or illnesses. Several of the plant officials we interviewed told us  that they provide incentives and rewards to employees or groups of  employees who work for extended periods of time without injury.
section_title: Many Factors Affect Injury and Illness Rates
paragraphs: Injury and illness rates may be affected by many factors, such as employer  or employee emphasis on safety, the amount and quality of training,  employee turnover rates, and the speed of the production line.
Officials from a company, union, or trade association may take steps that  affect worker safety and health. For example, a company may form a plant  safety committee that reviews incidents of injury and illness to identify  safety issues and take steps to address weaknesses. In addition, company  officials may influence worker safety and health by showing their  commitment to safety through actions such as establishing medical safety  management programs at the plants, providing personal protective  equipment to workers, and disciplining workers who do not follow safety  procedures. Unions can also play a role in worker safety and health by  negotiating with company officials to take a more proactive approach to  addressing work conditions. Trade associations may offer training courses  and conferences on safety issues, guidance on meeting OSHA  requirements, and other assistance to companies in improving safety and  health.
Both OSHA and industry officials noted that training is a critical factor in  worker safety and health. Companies provide employee training in a  number of forms, including classroom instruction, on-the-job training, and  written and video training materials (generally in English and Spanish).  Meat and poultry plants typically offer several days of training at the  beginning of a worker’s employment covering both job-specific and  general safety training. Plants periodically offer additional training classes  or updates—many of which are mandatory—such as annual refreshers on  workplace safety and health. Many plants also offer or require annual  specialized training on safety issues, such as knife sharpening, which can  reduce strain on line workers, and accident prevention such as “lock- out/tag-out” procedures that ensure that machinery is manually locked or  disconnected from a power source when not in use and tagged to note that  it has been locked or should not be used. In addition, one plant assigns  mentors, or buddies, to new workers to help them work more safely in an  introductory period.
Turnover rates can also affect the safety and health of workers. Turnover  tends to be high in the meat and poultry industry and, according to a  report by USDA’s Economic Research Service, turnover rates of 100  percent a year or more are not uncommon. High turnover can affect  safety and health at meat and poultry plants, according to one plant safety  official, because new employees are more likely to sustain an injury or  illness than more experienced workers. In the first few months of  employment, an employee may take shortcuts—because of the lack of  familiarity with proper procedures—that increase his or her vulnerability  to injury or illness. Plant officials often attribute high turnover to difficult  working conditions, extreme temperatures, and the fact that many of the  industry’s jobs are physically demanding and stressful.
The speed at which production employees are expected to work, often  determined by the speed of the production line, or line speed, may also be  an important factor influencing their safety and health. The faster the pace  at which the production line moves, the less able workers may be to  perform tasks needed for safety. For example, according to industry  research, at certain line speeds workers may be unable to take the seconds  required to perform certain critical tasks, such as the frequent sharpening  of knives, to ensure that their jobs can be conducted safely. Some  respondents to our survey also noted that line speed is an important factor  affecting worker safety and health. While some trade association  representatives and plant officials told us that the risks associated with  line speed can be mitigated by adding more workers to the line or rotating  workers to other jobs, advocacy group and union representatives have  discounted that argument, stating that some plants may not have either the  additional employee resources to add to the line or the additional space in  the line configuration needed to add more workers.
Line speed is regulated by USDA to permit adequate inspection by food  safety inspectors. According to USDA, when the maximum speeds were  originally set and when they are adjusted by the agency, the safety and  health of plant production workers is not a consideration. OSHA has made  recommendations to companies to slow their line speed, as well as to  make other safety improvements when citing companies for repetitive  motion injury issues, according to an OSHA official. Research is lacking,  however, on the full effects of line speed on worker safety and health.  Industry and OSHA officials told us that the differences across slaughter  and cutting lines prevent systematic comparison, analysis, and regulation  of line speed. According to these officials, because machinery is arrayed  differently on each line, research that might isolate ergonomic limits and  improvements, or examine the incidence of other line-related injuries, is  difficult to accomplish. However, a memorandum issued in 2000 by  Nebraska’s Lieutenant Governor recommended that OSHA “undertake a  legitimate study of the speed of the line in meatpacking plants” and that  “the industry should work cooperatively on that study.” NIOSH officials  and nongovernmental ergonomic experts told us that line speed should be  further researched in order to understand its impact on worker safety and  health.
While USDA has established regulations on line speed, the purpose of the  agency’s authority is not to protect workers, but to protect consumers.  USDA sets maximum line speeds based on how quickly its inspectors can  properly inspect the carcasses to ensure the safety of the meat. According  to trade association officials we interviewed, plants set their line speeds at  a rate at or below the maximum while considering such factors as (1) the  speed at which employees can work and still produce a quality product  and (2) the number of animals that need to be processed. While a high- ranking OSHA official we spoke to stated that he believed that the agency  has the regulatory authority to set its own line speed maximums, he also  said that it would be a difficult area to regulate.
section_title: While OSHA’s Programs May Have Improved the Safety and Health of Meat and Poultry Workers, Programmatic Weaknesses Make Determining Effectiveness Difficult
paragraphs: OSHA has several efforts that target the meat and poultry industry, and  there is some evidence that these efforts have had a positive effect on  worker safety and health. However, the criteria OSHA uses to select  worksites for inspection may allow some plants with high injury and  illness rates to avoid inspection. OSHA’s selection criteria do not require  the agency to examine trends in worksites’ injury and illness rates in order  to select plants for inspection that have recently reported significant  changes in their rates. In addition, some of the data on which OSHA bases  its selection may be underreported and are incomplete. Furthermore,  OSHA’s data collection efforts make determining program results difficult.
subsections: section_title: Some of OSHA’s Enforcement Efforts Target Compliance in the Meat and Poultry Industry
paragraphs: Some of the inspections of employer compliance with federal safety and  health standards that OSHA conducts are of meat and poultry worksites.  As shown in table 2, OSHA conducted about 1,900 inspections of plants in  the meat and poultry industry from 1995 to September 15, 2004. These  inspections represented less than 1 percent of OSHA’s total inspections.
OSHA also has efforts that focus on solutions to injuries prevalent in the  meat and poultry industry, such as repetitive stress disorders. For  example, OSHA’s current ergonomics inspection plan uses its worksite- specific injury and illness database to identify workplaces in industries  with higher than average injury rates. OSHA focuses its ergonomics  inspection resources on industries with relatively high rates of injuries  that appear to be related to ergonomic hazards. In addition, OSHA’s  regional or area offices may implement local emphasis programs in  industries with high musculoskeletal disorder or repeated trauma rates  and known ergonomic hazards. The agency also responds to employee  complaints about ergonomic hazards.
section_title: OSHA Has Involved the Meat and Poultry Industry in Its Cooperative Programs
paragraphs: In 2002, OSHA formed an alliance with the American Meat Institute to  promote safe and healthful working conditions for meat industry  workers. The alliance is meant to help reduce ergonomic hazards in the  workplace. It sets specific goals and priorities; key among them is for both  OSHA and the institute to develop and disseminate information and  guidance, particularly through their Web sites. The goal is to provide the  institute’s members and others in the meat industry with information to  help protect workers’ health and safety, with a focus on reducing and  preventing exposure to ergonomic hazards. The alliance also calls for both  organizations to provide training on ergonomics techniques, program  structure, and applications in the meat industry. Another goal is for OSHA  and the American Meat Institute to promote and encourage the institute’s  members to participate in OSHA’s cooperative programs such as the  Voluntary Protection Programs and mentor other members in helping  them qualify for participation.
The American Meat Institute also assists OSHA in maintaining and  updating information on safety and health in the meat industry on its Web  site. The institute, along with other stakeholders, provided information to  OSHA for the safety and health topics page on the agency’s Web site  entitled “OSHA Assistance for the Meat Packing Industry,” and the  agency’s Web-based training tool (“eTools”) for ammonia refrigeration.  OSHA provides information on eTools on many topics pertinent to the  meat and poultry industry, including ammonia refrigeration, machine  guarding, lock-out/tag-out procedures, poultry processing, confined space,  and ergonomic hazards.
Through its Strategic Partnerships Program, OSHA has established  national and regional partnerships within the meat and poultry industry.  OSHA has partnered with companies such as    Tyson Foods. Initiated in 2001, this partnership covers two poultry  processing facilities. The 5-year agreement has a goal of improving and  strengthening the company’s safety and health management systems,  reducing injuries and illnesses, and serving as a model for improved  worker protection throughout the company.
ConAgra Refrigerated Foods. This multiregional partnership, which  ended in January 2002, was meant to improve safety and health programs  and improve the relationship among OSHA, ConAgra, and the United Food  and Commercial Workers union and to prepare plants working toward  participation in OSHA’s Voluntary Protection Programs.
Odom’s Tennessee Pride Sausage Inc. Through its regional partnership  with OSHA’s region 6, Odom’s has committed to reducing its illness and  injury rates and working toward participation in OSHA’s Voluntary  Protection Programs.
OSHA’s Omaha area office has implemented the following two  partnerships:    Nebraska’s meat processing industry. In February 2000, members of  Nebraska’s meat processing industry and OSHA initiated a voluntary  partnership program intended to address the high fatality, injury, and  illness rates that have plagued the industry. The group meets bimonthly to  learn about current safety and health practices, share safety-related best  practices that have proven successful in their facilities, and discuss safety  issues of concern to participants. Company representatives provide injury  and illness data to OSHA for tracking purposes on a semiannual basis.
Nebraska cleaning and sanitation companies. Citing the hazardous  working conditions encountered by employees of companies that provide  contract cleaning and sanitation services to meat and poultry plants, in  2003, OSHA’s Omaha Area Office decided to establish a partnership with  these companies in order to help reduce injuries and illnesses.  Representatives of five companies have committed to a regional  partnership with OSHA’s region 7 in an effort to work cooperatively and  collaboratively to reduce workplace fatalities, injuries, and illnesses  common to cleaning contractors such as strains, lacerations, contusions,  burns, fractures, amputations, dermatitis, and crushing injuries. The goals  of the partnership are to reduce days away from work by 4 percent and to  improve existing safety and health management programs.
OSHA has not, however, implemented programs similar to the Omaha Area  Office’s partnerships in other areas of the country with large  concentrations of meatpacking plants or extended this type of program to  poultry plants. A high-ranking OSHA official told us that each area office  develops its own initiatives, which may be directed at other industries or  hazards than those in the meat and poultry industry. In addition, according  to the official, there were individuals in the Omaha office who had a keen  interest in the partnering approach used in the meatpacking industry and  had the entrepreneurial spirit to start these programs. The office has  presented its approach to at least one other office in an effort to share its  experience.
section_title: Several of OSHA’s Special Efforts Target the Meat and Poultry Industry
paragraphs: OSHA has other special compliance efforts that target the meat and  poultry industry. For example, several pages of OSHA’s Web site are  dedicated to the meat and poultry industry; they list the standards the  agency uses to combat hazards prevalent in this industry. OSHA also has  several directives specific to the industry, such as guidance on the  acceptable methods for guarding meat-cutting saws. In addition, OSHA  issues interpretations and compliance letters on issues specific to the meat  and poultry industry.
subsections: section_title: Ergonomic Guidelines for the Meat and Poultry Industry
paragraphs: OSHA has also produced the following two sets of ergonomic guidelines  for the meat and poultry industry:    Ergonomic Program Management Guidelines for Meat Packing Plants.
This document, jointly developed by OSHA and the American Meat  Institute, was developed in 1990 and contains advisory information on  management commitment and employee involvement, including  preventive program elements and detailed guidance.
Guidelines for Poultry Processing. This document, published by OSHA in  September 2004, offers practical recommendations for employers to  reduce the number and severity of musculoskeletal disorders throughout  the industry. In developing the guidelines, OSHA reviewed existing  ergonomics practices and programs, state OSHA programs, as well as  available scientific information. OSHA also consulted with stakeholders,  such as the National Turkey Federation, to gather information on the  ergonomic problems present in the poultry-processing environment and  the practices that have been used successfully in the industry.
section_title: Memorandum of Understanding with USDA
paragraphs: Because USDA inspectors are a constant federal presence in plants, OSHA  has established agreements with USDA, the latest of which is meant to  improve compliance in meat and poultry plants. In 1994, USDA and OSHA  jointly revised an existing memorandum of understanding between the  agencies that established a process and framework for (1) training USDA  meat and poultry inspection personnel to improve their ability to  recognize serious workplace hazards within the meat and poultry industry,  (2) reinforcing procedures for meat and poultry inspection personnel to  report unsafe and unhealthy working conditions to which they are  exposed to the appropriate authorities, (3) instituting new procedures for  USDA’s meat and poultry inspection personnel to refer serious workplace  hazards affecting plant employees to OSHA, and (4) coordinating possible  inconsistencies between OSHA’s job safety and health standards and  USDA’s sanitation and health standards.
According to the agreement, OSHA’s training of USDA inspectors would  not be expected to supplant OSHA expertise in identifying serious  workplace hazards. In addition, USDA inspectors would not be trained to  recognize and refer serious workplace hazards affecting plant employees  that tend to arise only after protracted, cumulative exposure, such as  those related to repetitive motion and noise.
According to USDA officials, the memorandum was revised after a  devastating poultry plant fire in 1991 that killed 25 workers. According to  reports about the fire, the plant’s fire doors had been padlocked from the  outside by the factory owner, who had locked the doors as a “loss control  technique” to prevent workers from stealing product. A USDA poultry  inspector was often present at the plant and testified at a congressional  hearing on the fire that he knew the doors were regularly locked in  violation of safety codes and had reported this to plant officials. He did  not, however, contact OSHA.
Although the purpose of the revised memorandum of understanding was  to educate USDA inspectors on recognizing and referring workplace  hazards, the agencies’ efforts to implement the agreement, such as  providing training to USDA inspectors and evaluating the effectiveness  and impact of the training, have lapsed. According to OSHA officials,  although the agency put together training materials for USDA inspectors,  only one training session was held, and only a small number of individuals  were trained. USDA officials we spoke to confirmed this, and stated that  not a lot of effort was made to train inspectors. USDA officials told us  that OSHA had proposed a week’s worth of training and that it would be  very difficult to pull inspectors from their line duties and send them to  training for that length of time. In their comments on a draft of this report,  USDA officials noted that in-plant inspectors routinely receive training on  topics such as wellness, awareness of infectious diseases, and worker  health and safety.
section_title: Evidence Suggests OSHA’s Programs Have a Positive Impact on Worker Safety and Health
paragraphs: Some positive outcomes have resulted from OSHA’s efforts directed at the  meat and poultry industry. For example, in 2003, OSHA inspected 193 meat  and poultry plants to determine their compliance with federal safety and  health standards. These inspections produced safety improvements in  several of the plants inspected, according to OSHA, trade association  officials, and some plant officials we interviewed. In addition, according to  OSHA and trade association officials, the widespread use of the agency’s  ergonomic guidelines for meatpacking plants has contributed to a decline  in worker illness and injury rates in the last decade.
OSHA’s partnerships have also, according to the agency, had positive  outcomes. For example, according to information on its Web site, as a  result of OSHA’s partnership with ConAgra Refrigerated Foods, many of  the company’s facilities have formed new safety and ergonomics  committees with both management and union participation. According to  OSHA, five of the company’s nine participating facilities experienced  significant decreases in workers’ compensation costs ranging from 42  percent to 93 percent (with an average reduction of 62 percent),  suggesting a reduction in the injury and illness rates for these five  participating facilities.
Another of OSHA’s partnerships, with meatpacking plants in Nebraska,  has shown some positive outcomes. According to officials from OSHA’s  Omaha Area Office and some plant officials who participate in the  partnership, the group has made progress toward the goal of making the  industry safer. In addition, according to the participants, the relationship  between OSHA and Nebraska’s meatpackers, which had been strained, if  not antagonistic, has improved significantly, and the group has made  tremendous progress in building cooperative, trusting relationships. These  relationships have developed not only between OSHA and the plants, but  also among the plant officials themselves. According to officials at OSHA’s  Omaha Area Office, over the 4-year existence of the partnership, the  members have realized a 23 percent reduction in injuries and illnesses  resulting in days away from work or restricted work activities. There has  also been a 39 percent reduction in total recordable injury and illness  cases, a total that includes cases resulting in days away from work, cases  resulting in restricted work, and cases requiring medical treatment. OSHA  officials told us that they consider these to be noteworthy improvements  over a relatively short period of time in an extremely hazardous industry.  Furthermore, the partnership has allowed OSHA to reach out directly to  meatpacking plants too small to meet the agency’s criteria for inspection  (those with fewer than 40 employees) and provide them with information  about improving safety and health at their plants.
OSHA’s memorandum of understanding with USDA has also resulted in  some positive outcomes. According to a high-ranking OSHA official, since  the revised memorandum was signed in 1994, USDA inspectors have made  31 referrals to OSHA, 26 of which resulted in an OSHA inspection. USDA  does not track this information and could not verify the number of  referrals made by its inspectors to OSHA. However, we were told by USDA  officials that the department’s inspectors rarely make referrals because  workplace hazards are not the focus of their inspections. In addition, we  were told that USDA inspectors are more likely to discuss observed  hazards with plant management before referring them to OSHA, since they  have established relationships with the plants and because the hazards  could affect them as well as plant employees. Finally, OSHA officials said  that because a referral may cause OSHA to inspect the plant, some USDA  inspectors may be reluctant to make such referrals because it could mean  that OSHA would include them in the inspection and cite them for  violations, such as not wearing their personal protective equipment.
Several meat and poultry plants have taken advantage of OSHA’s various  cooperative programs. Since 1996, 391 meat and poultry worksites have  received consultation services through OSHA’s On-Site Consultation  Program. In addition, OSHA has also recognized some meat and poultry  plants as having exemplary safety and health management systems,  although the relatively low numbers of participants from this industry  indicates the difficulty in meeting program requirements. As of September  30, 2004, only 8 of the 1,180 Voluntary Protection Programs worksites were  in the meat and poultry industry. Similarly, as of September 1, 2004, only 8  of the 844 worksites participating in OSHA’s Safety and Health  Achievement Recognition Program were in the meat industry, and no  poultry plants participated in the program.
section_title: Selection Criteria May Not Trigger Inspection of At- Risk Plants, and Data Collection Makes Assessing Effectiveness Difficult
paragraphs: While the criteria OSHA uses to select worksites for inspection focuses its  limited resources mainly on plants with relatively high injury and illness  rates, the agency does not consider trends in worksites’ injury and illness  rates over time. As a result, OSHA may not detect dramatic decreases in  these rates that could raise questions as to the accuracy of the figures.  This is of particular concern given the allegations of underreporting in the  industry and weaknesses in the data used to select plants for inspection.  OSHA does, however, select some worksites with low injury and illness  rates in an attempt to ascertain whether worksites with low rates are  underreporting injuries and illnesses. It also randomly selects some  worksites from high-hazard industries for record-keeping audits designed  to verify the injury and illness rates reported to OSHA. For both of these  efforts, however, OSHA selects few meat and poultry plants. Furthermore,  the data it collects on specific worksites—kept in multiple databases—are  not easily tracked, because OSHA does not assign a unique identifier to  each worksite. Therefore, it is difficult to assess the effectiveness of  OSHA’s efforts to improve safety and health.
subsections: section_title: Selection Criteria
paragraphs: The criteria OSHA uses to select meat and poultry plants for inspection  target worksites that report high injury and illness rates. However, OSHA’s  selection criteria do not allow it to detect anomalies in worksites’ reported  injury and illness rates, because the agency does not analyze data on  plants’ injury and illness rates over time. Although OSHA surveys meat and  poultry plants annually to obtain worksite-specific data on their injury and  illness rates and uses these data to select plants for inspection, it does not  review the data collected from previous years in order to examine changes  in their injury and illness rates. In addition, these data are incomplete,  because OSHA’s survey sample varies from year to year, and because  OSHA only asks employers for 1 year of injury and illness data. In 2002, we  reported the problem with OSHA collecting only 1 year’s worth of data,  concluding that this limited the agency’s ability to effectively identify  hazardous worksites for inspection. Area office officials we interviewed  for that report said that, in some cases, the 1-year rate was an outlier that  did not reflect general worksite operations.
The data on which OSHA bases it selections are also incomplete because,  when it surveys worksites in the meat and poultry industry, OSHA does  not ask employers to report injuries and illnesses incurred by contract  cleaning and sanitation workers who work at the plant. Because these  workers are not employees of the plant, their injuries and illnesses are  recorded by the companies for whom they work rather than on the plants’  injury and illness logs. As a result, OSHA does not consider all injuries  and illnesses in selecting meat and poultry plants for inspection. This is a  significant oversight because, according to OSHA officials, experts, and  researchers, these workers incur high rates of injury and illness and often  sustain more serious injuries than production workers. According to  information in OSHA’s inspections database, between 1998 and 2003, at  least 34 contract cleaning and sanitation workers employed in meat and  poultry plants sustained serious injuries or were killed. However, because  these injuries were recorded as occurring in another industry, none of the  injuries were reflected in the meat and poultry industry’s injury and illness  rates.
A large number of workers perform this work under contract for meat and  poultry plants; we interviewed three cleaning and sanitation companies  that employ more than 5,000 workers at 140 plants across the country.  One contract cleaning company representative reported that the biggest  risk factor affecting the safety of these workers was workers’ decisions to  take shortcuts, such as not properly performing lock-out/tag-out  procedures for machinery before cleaning it. Another representative said  he felt that the biggest risk factor was the difficulty in communicating how  hazardous the complex and intricate machinery is because of language or  cultural differences. OSHA inspects the cleaning and sanitation shift  during its inspections of meat and poultry plants, whether the workers are  employees of a contract company or the plant. However, plants whose  contract workers have high injury and illness rates may not be selected for  inspection because these injuries are not included in the data OSHA uses  to select meat and poultry plants for inspection.
Because there are allegations of underreporting in the meat and poultry  industry, OSHA attempts to counter such incidences by verifying the injury  and illness rates of worksites it inspects as part of its SST program. In  addition to reviewing employers’ logs during SST inspections, OSHA also  randomly selects for inspection 200 worksites each year that report low  injury and illness rates in high-hazard industries to ensure that these  worksites are not underreporting injuries and illnesses. In 2003, 5 of the  200 worksites selected were meatpacking plants; in 2004, 10 were  meatpacking plants. The sausage and other prepared meats industry and  the poultry industry did not have injury and illness rates that met the  criteria for this effort. Therefore, OSHA did not select any worksites in  these industries for inspection that reported low rates.
In a separate effort designed in part to combat underreporting of injuries  and illnesses, OSHA annually conducts a number of comprehensive  record-keeping audits intended to verify the accuracy of the data on  injuries and illnesses that employers submit to OSHA. However, the  selection criteria it uses allow the agency to audit the records of only a few  meat and poultry plants. While OSHA’s limited resources allow it to select  few worksites in any industry for a record-keeping audit, OSHA is not  doing enough to verify the accuracy of the data that meat and poultry  plants report, considering the dramatic decreases in this industry’s  reported injury and illness rates. Of the 250 worksites OSHA selected for  the audits of 2001 and 2002 data, only 3 each year were in the meat and  poultry industry.
While the criteria it uses to select worksites for inspection are rarely  altered, according to OSHA officials, in 2004, they adjusted the criteria  used to select the 200 worksites with low injury and illness rates for  inspection in order to focus on worksites with a large number of  employees. Previously, OSHA selected worksites in high-hazard industries  with a minimum of 40 employees for these inspections; currently, it selects  worksites with a minimum of 200 employees. This change will likely have  the effect of OSHA selecting even fewer meat and poultry plants that  report low injury and illness rates for inspection, because the majority of  plants have fewer than 200 employees. In addition, we were told by a high- ranking OSHA official that the agency is considering adjusting the criteria  further to double the number of worksites with low illness and injury rates  for inspection. However, according to OSHA officials, adjusting the  criteria further—for example, to enhance the agency’s focus on a  particular industry such as meat or poultry—would require additional  resources and a consideration of the effect on other industries.
section_title: Data Collection
paragraphs: OSHA’s data do not allow the agency to determine the impact of its  enforcement and cooperative programs on the meat and poultry industry.  To determine the impact of its efforts, OSHA could match the injury and  illness data it collects from employers to data on inspections and employer  participation in its cooperative programs. However, such matching, which  would allow the agency to better relate reductions in injury and illness  rates to its interventions, cannot be easily performed. The data it collects  on specific worksites—recorded in multiple databases—are not easily  tracked because OSHA does not assign a unique identifier to each  worksite. Without such an identifier that can be tracked across databases,  the agency is unable to easily consolidate all the information associated  with each worksite. Without the ability to compare this information across  databases, it is difficult to assess the success of its efforts.
We attempted to assess the impact of OSHA’s programs on the meat and  poultry industry by comparing worksite-specific data across its various  databases to determine an association between changes in a plant’s injury  and illness rates and the agency’s efforts. However, we encountered  problems because of the lack of a unique identifier for each worksite. To  match data on specific worksites without such an identifier, we relied on  other identifiers—such as the name of the company, address, or zip  code—to find the data associated with a company over time. However,  because of differences in how these identifiers appeared in each of  OSHA’s databases, we could not reliably track data for specific companies.  For example, from one year to the next, a company’s name may appear  differently in the various databases, or a match on address may not  produce a match for the company name. OSHA officials we spoke to  acknowledged the difficulties involved in this type of effort. In fact, they  recently encountered similar problems in their attempts to evaluate the  impact of the SST program in 2004 (see app. III for more information).  OSHA’s inability to assess the effectiveness of its efforts has been a  recurring finding.
In November 2002, we recommended that OSHA take steps to assess the  impact of its SST program on workplace injuries and illnesses. Similarly, in  March 2004, we reported that OSHA’s lack of comprehensive data on its  cooperative programs—such as their relative impact on worksites’ safety  and health—makes it difficult to fully assess the effectiveness of these  programs. OSHA agreed with our recommendation but pointed out that  the agency’s variety of strategies reach out to different types of industries,  employers, and workers, making it difficult and costly to compare their  relative effects.
section_title: Conclusions
paragraphs: The dangerous and repetitive nature of the work in the meat and poultry  industry results in a variety of injuries and illnesses to workers. Although  the efforts by government, employers, and advocacy groups have helped  improve worker safety and health in this industry, and according to BLS  the number and rate of injuries and illnesses have decreased substantially  over the last decade, additional improvements could be made. For  example, the criteria that OSHA uses to select plants for inspection, while  reasonable, do not incorporate consideration of dramatic or sudden  decreases in injury or illness rates in selecting plants for inspection. In  addition, because OSHA lacks complete data on the injuries and illnesses  of meat and poultry workers, particularly those employed by cleaning and  sanitation companies, plants in need of inspection may not be identified  and selected. Further, because OSHA does not track changes in individual  plants’ injury and illness rates, or have a method for comparing these rates  with data collected on inspections or plants’ participation in its  cooperative programs, it lacks a means of understanding the impact its  programs have on workers in this industry.
OSHA also lacks some of the information needed to participate more fully  in improving worker safety and health. For example, until the effects of  line speed are studied from a worker safety and health perspective to  better understand its effect on injury and illness rates, it will be difficult  for OSHA to provide meaningful input with regard to the process of  regulating the speed of the production line. In addition, OSHA has been  slow in expanding its successful efforts. Because its most successful  program aimed at improving safety and health has not been replicated in  other areas of the country, OSHA is not allowing workers in its other  jurisdictions to realize the benefits, such as the potential for a reduced  number of injuries and illnesses, of this program. Finally, the  memorandum of understanding between USDA and OSHA is not being  utilized to the full extent possible. The efforts called for by the  memorandum of understanding to reinforce and supplement the training  of USDA inspectors so they are able to recognize and refer serious  workplace hazards in meat and poultry plants have lapsed.
section_title: Recommendations for Executive Action
paragraphs: In order to strengthen the agency’s efforts to improve safety and health of  workers at meat and poultry plants, the Secretary of Labor should direct  the Assistant Secretary for Occupational Safety and Health to consider    adjusting OSHA’s criteria for selecting worksites for SST inspections and  for record-keeping audits to consider worksites that have had large  reductions in their injury and illness rates over time; requiring worksites that are surveyed by OSHA to obtain worksite-specific  data on injuries and illnesses to include (1) multiple years of data, so that  trends in their rates may be analyzed and (2) data on injuries and illnesses  to workers employed by cleaning and sanitation companies that provide  workers to the plant under contract so that these data can be included in  the rates OSHA uses to select plants for inspection;  requiring that a common identifier for each plant be used in all of its  enforcement and cooperative program databases so that these different  data sets can be more easily compared in an effort to measure the agency’s  impact on worker safety and health; and   expanding successful partnerships, such as the Omaha Area Office’s  partnership with meatpacking plants in Nebraska to other area offices  with high concentrations of meat and poultry plants.
The Secretary of Labor should direct the Assistant Secretary for  Occupational Safety and Health and the Secretary of Agriculture should  direct the Acting Administrator of the Food Safety and Inspection Service  to  revisit and update their memorandum of understanding to ensure that  USDA inspectors receive training in recognizing and referring workplace  hazards and that the agreement remains current.
In addition, the Secretary of Health and Human Services should    direct the Director of the Centers for Disease Control and Prevention to  have NIOSH conduct a study of the effect of the speed of the production  line on workers in the meat and poultry industry, a study that would also  include other job-specific features that interact with line speed to increase  the risk of injuries and illnesses to these workers.
section_title: Agency Comments
paragraphs: OSHA, USDA, HHS, and BLS provided us with written comments on a  draft of this report, which are reproduced in appendixes IV, V, VI, and VII,  respectively. The agencies generally agreed with all of the  recommendations that applied to them.
OSHA noted that it has solicited public comments on its SST program and  will consider our suggestion to expand its selection criteria for SST  inspections. The agency also commented that it will cooperate with USDA  to encourage the revitalization of USDA inspector training and will work  with NIOSH and others to investigate the relationship between line speed  and the risk of injury. Finally, OSHA pointed out that some of the  remaining recommendations, such as expanding its data collection efforts,  could have significant impact on the agency’s resources and that it would  consider these recommendations in conjunction with decisions on how  best to allocate the resources it has available.
USDA noted that, because its in-plant employees are a federal presence in  meat and poultry plants, they can help detect and report serious  workplace hazards to OSHA. The agency also noted its responsibility to  enforce the Humane Methods of Slaughter Act, emphasizing that, if in- plant inspectors witness egregious violations of the act—such as hoisted  animals struggling or thrashing—they have the authority to take  immediate enforcement action against such firms including stopping the  production line. USDA commented that compliance with the act indirectly  improves workplace safety.
HHS agreed that there is a need to study the relationship between line  speed and musculoskeletal disorders and other injuries in the meat  industry, and stated that it would direct NIOSH to conduct such a study.  The agency noted, however, the difficulty its staff have had in the past in  gaining access to meatpacking plants to conduct research. HHS also  commented on the resource commitment that would likely be involved for  such a large and detailed, but necessary, study.
BLS noted that, although it conducted a major redesign of its annual  survey of occupational injuries and illnesses in 1992, (in part because of  concerns about the completeness of employer reporting,) there is still  some concern about underreporting of injuries and illnesses among users  of the data. The agency also noted several technical corrections to the  report, as did OSHA, USDA, and HHS, which we incorporated as  appropriate.
As arranged with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days after the  date of this report. At that time, we will send copies of this report to the  Secretary of Labor, the Assistant Secretary of Labor for Occupational  Safety and Health, the Secretary of Agriculture, the Acting Administrator  of the Food Safety and Inspection Service, the Secretary of Health and  Human Services, and the Director of the Centers for Disease Control and  Prevention. We will also make copies available to others upon request. In  addition, the report will be available at no charge on GAO’s Web site at  http://www.gao.gov.
Please contact me or Revae Moran on (202) 512-7215 if you or your staff  have any questions about this report. Other contacts and staff  acknowledgments are listed in appendix VIII.
section_title: Appendix I: Scope and Methodology
paragraphs: For this report, we attempted to (1) describe the characteristics of  workers in meat and poultry slaughter and processing plants and the  conditions in which they work; (2) identify the types of injuries and  illnesses workers in meat and poultry slaughter and processing plants  incur, how the injury and illness rates have changed over the past decade,  and the factors that may have affected these rates; and (3) determine what  is known about the effectiveness of the Occupational Safety and Health  Administration’s (OSHA) efforts to improve safety and health at meat and  poultry slaughter and processing plants. To address these objectives we    obtained and analyzed relevant data from the Bureau of Labor Statistics  (BLS) on worker demographics and workplace injuries, illnesses, and  fatalities; OSHA’s inspection database; the data OSHA uses to target  specific worksites for inspection; and information on plants that  participate in OSHA’s cooperative programs;   conducted a survey of meat and poultry plants to obtain data on their  workers, factors that affect their injury and illness rates, plants’ efforts to  improve safety and health, and plants’ interactions with OSHA; interviewed officials from OSHA and other federal agencies, such as the  U.S. Department of Agriculture (USDA) and the Centers for Disease  Control and Prevention’s National Institute for Occupational Safety and  Health (NIOSH) within the Department of Health and Human Services  (HHS), as well as individuals from contract cleaning and sanitation  companies, unions, advocacy groups and key trade associations; and   visited six meat and poultry plants.
subsections: section_title: Reliability of USDA’s, BLS’s, and OSHA’s Data
paragraphs: To determine the number, location, and regional distribution of plants, we  examined USDA’s Food Safety and Inspection Service’s Performance  Based Inspection System database. This management system integrates  weekly schedules of inspection tasks; documents inspection findings  including deviations, deficiencies, and corrective actions; and provides a  database for the automatic data-processing support system.
To describe the characteristics of workers employed in the meat and  poultry slaughter and processing industries, we obtained demographic  estimates for meat and poultry workers and for the manufacturing  industry as a whole from BLS’s Current Population Survey (CPS) March  supplement for 2004 and 1995. The CPS is a monthly survey of households  conducted by the U.S. Census Bureau for BLS. The CPS, a sample of  60,000 households, provides a comprehensive body of information on the  employment and unemployment experience of the nation’s population,  classified by age, sex, race, and a variety of other characteristics.
Because the CPS estimates are based on probability samples, they are  subject to sampling error. Slightly different estimates could result from  different samples. We express our confidence in the precision of our  particular sample’s results as a 95 percent confidence interval. This is the  interval that would contain the actual population value for 95 percent of  the samples we could have drawn. As a result, we are 95 percent confident  that each of the confidence intervals in this report will include the true  values in the study population.
For the CPS estimates in this report, we estimated sampling error and  produced confidence intervals using the methods provided in the technical  documentation for the 2004 and 1995 March supplements. All CPS  percentage estimates contained in this report have 95 percent confidence  intervals within plus or minus 8 percentage points of the estimate itself. All  other CPS estimates contained in this report have 95 percent confidence  intervals within plus or minus 14 percent of the estimate itself, unless  otherwise noted.
We also reviewed data on injuries and illnesses, collected and published  by BLS through its Survey of Occupational Injuries and Illnesses, for  calendar years 1992 to 2002, as they related to workers in the meat and  poultry industry. BLS’s Survey of Occupational Injuries and Illnesses  provides estimates of the number and frequency (incidence rates) of  workplace injuries and illnesses based on logs kept by private industry  employers during the year. Survey estimates are based on a scientifically  selected sample of worksites, some of which represent only themselves  but most of which also represent other employers of like industry and  workforce size that were not chosen in a given survey year. Besides  providing injury and illness counts, survey respondents also are asked to  provide additional information for a subset of the most serious nonfatal  cases logged, namely, those that involved at least 1 day away from work,  beyond the day of injury or onset of illness. Employers answer several  questions about these cases, including the demographics of the worker  disabled, the nature of the disabling condition, and the event and source  producing that condition. BLS calculates relative standard errors for all  estimates it tabulates (see BLS's Web site for more information).  These  relative standard errors were used to develop 95 percent confidence  intervals for each estimate. In this report, all estimates of incidence rates  have 95 percent confidence intervals of within plus or minus 14 percent of  the estimated incidence rate. For example, the estimated rate for  tendonitis in 1992 was 23.6 cases per 10,000 full-time meat and poultry  workers. Since 14 percent of 23.6 is 3.3, the confidence interval for this  interval is within 20.3 to 26.9 cases per 10,000 full-time workers.
We also reviewed data on fatalities, collected and published by BLS  through its Census of Fatal Occupational Injuries for calendar years 1992  to 2003 as they related to workers in the meat and poultry industry. BLS’s  Census of Fatal Occupational Injuries is a federal-state cooperative  program that has been implemented in all 50 states and the District of  Columbia since 1992. To compile fatality counts that are as complete as  possible, the census uses multiple sources to identify, verify, and profile  fatal worker injuries. Information about each workplace fatality— occupation and other worker characteristics, equipment involved, and  circumstances of the event—is obtained by cross-referencing the source  records, such as death certificates, workers’ compensation reports, and  federal and state agency administrative reports. To ensure that fatalities  are work-related, cases are substantiated with two or more independent  source documents or a source document and a follow-up questionnaire.  Data compiled by the program are issued annually for the preceding  calendar year. We report the 2003 data in a footnote because the data are  not comparable with data from previous years. According to BLS, the new  industry and occupational classifications the agency is required to use  may, in some instances, have different definitions than the classification  system used previously.
To analyze the extent to which OSHA interacts with meat and poultry  plants through its enforcement programs, we analyzed inspections data for  fiscal years 1996 to 2004 from OSHA’s Integrated Management Information  System and worksite-specific injury and illness data collected by OSHA.  We assessed the completeness of these data by reviewing OSHA’s  documentation on how the data were collected and performed electronic  tests to look for outliers, missing values, and duplicate records. On the  basis of these reviews and tests, we found the data sufficiently reliable for  our purposes. In addition, for OSHA’s inspections data, we obtained and  reviewed documentation of internal controls.
We analyzed the data that OSHA uses to target specific worksites for  inspection through its SST program. These data are collected by OSHA  through its annual Data Initiative, which is a nationwide collection of  worksite-specific injury and illness data from approximately 80,000  worksites. OSHA collects data from worksites by using the OSHA Work- Related Injury and Illness Data Collection Form.
To report on the extent that meat and poultry plants participate in OSHA’s  various cooperative programs, we analyzed OSHA’s consultation database,  its lists of Voluntary Protection Programs and Safety and Health  Achievement Recognition Program sites, and its lists of current alliances  and strategic partnerships.
We interviewed USDA, OSHA, and BLS officials to establish the reliability  of the data. We found the data to be sufficiently reliable for our purposes.
section_title: Analysis of BLS’s CPS and Injury and Illness Data
paragraphs: We explored, for this report, different ways in which the CPS and BLS’s  injury and illness data could be used to track changes in injury and illness  rates for various groups of workers and discovered several limitations. For  example, we analyzed CPS data on worker demographics by industry and  data on injuries and illnesses sustained by workers. Using the two data  sets, we attempted to determine whether workers in certain demographic  groups—such as males and females, whites and minorities, and younger  and older employees—were sustaining more injuries or illnesses now than  would be expected, taking into account the number of individuals in these  demographic groups. We also attempted to estimate differences in injury  rates, or in the likelihood of being injured, between certain worker  demographics, such as gender, race, and age. However, a large percentage  of cases in the meat and poultry industry that were reported to BLS— 24 percent in 2002—lacked data on the race of the injured worker since  race is not a required reporting item. Because of this lack of data, it was  not possible to determine whether workers of a certain race were  disproportionately injured.
First, BLS’s data on injuries and illnesses cannot be used by themselves to  estimate injury rates or the likelihood of being injured, since those data  include only information on workers who were injured, but not on  workers who were not injured. While BLS’s injury and illness data could  be used to estimate the numbers of workers in the meat products industry  at risk of being injured, overall and in each of the subgroups of interest to  us, its injury and illness data do not provide demographic information  (e.g., data on race, sex, or age) on all workers who were injured, but only  those workers whose injuries were serious enough to have resulted in the  workers requiring time off from work. While we might have merged  information from BLS’s injury and illness data and information from the  CPS in order to estimate rates of injuries requiring time off, and  differences in those rates across subgroups, that task was complicated by  the fact that there was considerable information missing on race, which  was one of the factors of greatest interest to us. Because BLS does not  require the various states and industries surveyed to disclose the race of  employees injured, some choose not to, and ultimately race is unknown  for roughly one in every four persons injured.
In addition, we could have estimated differences in the rates of injury and  illness requiring time off across sex and age categories. However, the lack  of detailed information in the CPS on the types of jobs held by workers  employed in the meat products industry would not have made it possible  for us to determine whether differences in injury and illness rates across  age and sex categories was a result of differences in these demographic  characteristics or the result of women and older employees having  different types of jobs than men and younger workers.
section_title: Survey of Meat and Poultry Plants
paragraphs: To obtain information about safety and health and the characteristics of  their workforce, we administered a survey to a sample of meat and poultry  plants. Our survey population consisted of plants represented in OSHA’s  worksite-specific injury and illness database for years 1999 to 2002. This  database contains annual information on occupational injuries and  illnesses at the worksite (plant) level. The data on worksites, operating in  what are considered high-hazard industries, have been collected since  1995. Since the data for approximately one-third of all existing plants  above a certain size are updated in the database in any particular year, we  included in our sample, all plants included in the database during the most  recently available 4-year period (1999 to 2002). The specific industries on  which we focused were meat and poultry plants in Standard Industrial  Classification code 201—the meat products industry—including those in  meatpacking plants, code 2011; the sausages and other prepared meat  products industry, code 2013; and the poultry slaughtering and processing  industry, code 2015.
subsections: section_title: Sample Design
paragraphs: Our survey sample included all plants from the database with more than  1,250 employees. The remaining plants were stratified by industry, using  the three Standard Industrial Classification codes for each of the three  industries that encompass the meat products industry. We drew a random  sample from each of these three industries.
From our total sample of 420 plants, 24 were eliminated for various  reasons, including the fact that the plant had gone out of business, the  plant was not a meat or poultry plant, or the plant was duplicated  elsewhere in our sample.
section_title: Survey Administration and Response Rates
paragraphs: To develop our questionnaire, we consulted with officials at the American  Meat Institute and the United Food and Commercial Workers union, and  experts at GAO. We pretested a draft of the questionnaire with six  companies in the meat products industry. We mailed the questionnaire,  addressed to the plant safety director (or other appropriate management  personnel), requesting information on the demographic characteristics of  the plant’s workforce, the working conditions of the plant, the safety  training and related efforts undertaken within the plant, and the plant’s  interaction with (and respondent’s opinions on) OSHA. The survey was  conducted between July 2004 and September 2004.
The overall response rate of 23 percent compromises our ability to  generalize the findings across the population of plants and to present  statistically valid results. While the sample was designed to draw  inferences from the study population, we did not produce estimates of the  population of meat producers based on our sample results. We arrived at  this decision both because the response rate was low and because it is  likely that certain key characteristics of respondents differ from those of  nonrespondents. For example, since two major companies refused to  participate, our responses did not include the responses of any plants from  these companies; the experiences of our respondents may differ from  those of plants from these companies. Table 3 summarizes the sample  sizes by industry, their disposition, and our response rates.
Because of our low response rate, we did not use the data obtained from  the survey to draw conclusions about the meat and poultry industry.  Instead, we used the responses to illustrate some of the information  provided from other sources in our report, such as opinions about OSHA  as a factor in the safety and health of workers. We also used the data to  provide examples about the range of responses we found. For example,  we reported that one plant had an employee turnover rate that could reach  200 percent from data obtained from our survey.
section_title: Interviews with OSHA Area Offices
paragraphs: To describe the variety and extent of OSHA efforts within the meat and  poultry industry, we interviewed officials from four OSHA regional offices.  We selected these regional offices based on information from OSHA’s  inspections database, which contains data on inspections and fines levied  by OSHA. We examined the inspections data to determine the regional  offices that had conducted the highest number of inspections from  January 2003 to July 2004 for plants in Standard Industrial Classification  codes 2011, 2013, and 2015. From these interviews, we obtained  information about their activities in the meat and poultry industry within  their respective regions, including any regional and local emphasis  programs, their perspectives on factors affecting the safety and health of  workers in this industry, and coordination efforts between their offices  and USDA.
section_title: Visits to Meat and Poultry Plants
paragraphs: During the course of this review, we visited six meat and poultry plants. Of  the six plants, we visited four (two beef, one pork, and one poultry  slaughter and processing plant) to obtain a better understanding of the  work performed by workers in meat and poultry plants and the conditions  in which they work. During these visits, we toured the plants and spoke to  plant officials about worker demographics, plant operations, injury and  illness history, and their experiences with and opinions of OSHA. Three of  these four plants were selected because they were located in an area of  the country where meat production is high; the other was close to our  headquarters office. We visited two additional plants for the purpose of  pretesting our survey instrument; we did not tour these two plants.
section_title: Appendix II: Interviews with Cleaning and Sanitation Companies
paragraphs: We interviewed three cleaning and sanitation companies that provided  contracted services to meat and poultry plants. In total, these three  companies employed over 5,000 non-union workers and operated in 140  different plants across the country. One company representative told us  the company had contracts to operate in plants owned by some of the  largest companies in the meat and poultry industry.
In general, all three cleaning and sanitation companies employed workers  who tended to be young and Hispanic. The companies supplied small  plants with crews as small as 1 or 2 employees and large plants with crews  as large as 150 employees. According to representatives from these  companies, cleanup shifts at plants can range from only 2.5 hours to 12  hours, but typically shifts lasted less than 8 hours. While the majority of  time is spent cleaning the slaughter and process areas, at many plants the  crews are responsible for also cleaning bathrooms and office space. At the  end of the cleanup shift each day, the slaughter and process areas must  pass a USDA inspection in order for the plant to restart its operations. All  three companies’ representatives reported that if the plant is not cleaned  within the time allotted for USDA inspection, they must pay some type of  monetary penalty to the plant.
The companies reported providing their workers with all safety and health  training. In addition, the companies employed safety auditors who travel  to various plants to examine safety issues. These examinations may  include interviewing contract workers to see if they are aware of certain  safety regulations or procedures, such as “lock-out/tag-out” procedures,  the issue cited as most important by the companies.
With regard to the incidence of repetitive motion injuries, one company  representative stated that these types of injuries among their workers are  limited because sanitation workers perform tasks that are different from  those performed by plant workers in that they are constantly moving  around and not performing repetitive tasks. He said, however, that  conditions such as working at night, sweating from the steam, freezing  from the cold, and being wet all the time contribute to the high turnover  for his employees.
section_title: Appendix III: OSHA’s Study on Its Impact Using Establishment-Specific Targeting of Interventions
paragraphs: In November 2002, we recommended that OSHA take steps to assess the  impact of its SST program on workplace injuries and illnesses. OSHA has  since conducted its first major evaluation of the effectiveness of the SST  program and, in 2004, issued a report detailing the results of its  evaluation. The report states that worksites experienced statistically  significant cumulative 3-year reductions in the number of injuries and  illnesses as a result of OSHA’s efforts. However, while these results  indicate positive outcomes, the study did not attempt to isolate the impact  of OSHA’s efforts from other factors—such as employers’ own safety  programs—that may have as much or more of an influence on injuries and  illnesses. In fact, several employers who responded to our survey stated  that the reduction in their injury and illness rates could be attributed to  other factors that they claimed worked in addition to, or in place of,  OSHA’s efforts, and that these other factors were as important in achieving  safety and health improvements.
In performing this evaluation of its SST program, OSHA encountered  difficulties in identifying worksites across databases and dealing with the  incompleteness of certain data fields. While not invalidating the  conclusions in its report, the difficulties OSHA encountered suggest that  the data collection for its worksite-specific injury and illness database  could be improved. In particular, OSHA did not consistently assign a  unique identifier to each plant, which made it difficult to compare  information across databases. This issue, combined with a lack of  information in the 2004 report concerning how the model was developed  and tested, points to a need to use caution in interpreting the report’s  results.
section_title: Appendix IV: Comments from the Occupational Safety and Health Administration
section_title: Appendix V: Comments from the U.S. Department of Agriculture
section_title: Appendix VI: Comments from the U.S. Department of Health and Human Services
section_title: Appendix VII: Comments from the Bureau of Labor Statistics
section_title: Appendix VIII: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: David G. Ehrlich and Friendly M. Vang-Johnson made significant  contributions to this report throughout the review. In addition,   Luann M. Moy helped develop our data collection instrument and our  overall design and methodology; Margaret L. Armen and   Richard P. Burkard provided legal support; Avrum I. Ashery,   Jennifer R. Popovic, and Melba Edwards designed our graphics;   Paula J. Bonin, Mark F. Ramage, Douglas M. Sloane, and Beverly A. Ross  provided technical assistance; and Corinna A. Nicolaou assisted in report  and message development.