Workplace Safety and Health: Additional Data Needed to Address Continued Hazards in the Meat and Poultry Industry
Released: 2016-05-25T00:00:00

Letter

Background

According to March 2015 CPS data, an estimated 526,000 workers were employed in the animal slaughtering and processing industry. There were about 5,350 meat and poultry plants in the United States as of September 2015, of which around 1,100 were slaughter and processing plants, according to the USDA (see fig. 1). In 2014, more than 30 million beef cattle, 100 million hogs, 200 million turkeys, and 8 billion chickens were slaughtered in the United States, according to USDA’s National Agricultural Statistics Service data.

Meat and poultry plants are generally designed for an orderly flow from point of entry of the living animal to the finished food product. Typically, the animal is brought to the meat or poultry plant and taken to the kill floor area, where the slaughter occurs. Workers and machines behead and eviscerate the animal, among other things, after which it is chilled for several hours. FSIS inspectors ensure that the carcass meets federal food safety standards. Workers and machines next process the carcass and may break it into small portions that can be transported directly to supermarkets. Slaughter and processing of meat and poultry require workers to perform a high number of repetitive motions. Although plants have increased automation, much of the work is still done by hand through the use of saws, knives, and other tools (see fig. 2).

Workers may sustain many different types of injuries at meat and poultry plants (see fig. 3).

To carry out its responsibilities under the Occupational Safety and Health Act of 1970 (OSH Act), OSHA establishes workplace safety and health standards, conducts inspections, investigates complaints from workers and reports of fatalities and serious injuries at worksites, and provides training and outreach, among other activities. To supplement its enforcement efforts, OSHA offers cooperative programs to help employers prevent injuries, illnesses, and fatalities in the workplace. OSHA conducts inspections in response to imminent danger, fatalities, catastrophic events such as hospitalizations, and worker complaints, and also selects worksites for programmed inspections based on injury incidence rates, previous citation history, or random selection. OSHA is directly responsible for setting and enforcing these standards for private sector employers, including meat and poultry plants, in 29 states, the District of Columbia, and 4 U.S. territories. The remaining 21 states and 1 territory have assumed responsibility for workplace safety and health under an OSHA-approved state plan. These “state-plan states” adopt and enforce their own standards (which must be “at least as effective” in providing safe and healthful employment as the federal standards).

The OSH Act and OSHA’s regulations require covered employers to prepare and maintain records of certain injuries and illnesses sustained by their workers. Specifically, non-exempt employers are required to record information about every work-related death and each new work- related injury or illness that results in loss of consciousness, days away from work, restricted work or transfer to another job, or medical treatment beyond first aid. OSHA has established three different forms for employers to record injuries and illnesses: the Form 300 Log of Work- Related Injuries and Illnesses (log), the Form 301 Injury and Illness Incident Report (incident report), and the Form 300-A Summary of Work- Related Injuries and Illnesses. For each recordable injury or illness, the employer must record specified information on the log, including the worker’s name, job title, date of injury or illness, a brief description of the injury or illness, and, if applicable, the number of days the worker was away from work, assigned to restricted duties, or assigned to another job as a result of the injury or illness. Employers must also classify the injury or illness according to categories provided on the OSHA log. These categories include injury, skin disorder, respiratory condition, poisoning, hearing loss, and “all other illnesses.” In addition to the log, for each case employers must prepare an incident report, which includes descriptive information about the case, including details about the injury or illness, how it occurred, and the treatment provided. Finally, employers are also required to prepare a summary of all injuries and illnesses annually, which is to be posted at the workplace. Although these three forms are not routinely provided to OSHA, they must be kept for 5 years and provided upon request in certain circumstances, such as during an OSHA inspection or in response to BLS’s SOII. In addition, all covered employers, including those exempt from the routine recordkeeping requirements, must report all work-related fatalities to OSHA within 8 hours and all work-related in-patient hospitalizations, amputations, or losses of an eye within 24 hours.

With respect to federal employers, such as USDA, each federal agency is generally required to establish and maintain a comprehensive and effective occupational safety and health program that is consistent with OSHA’s standards. The mission of USDA’s Safety and Health Management Division is to develop department-wide policies and promote and assist the development of USDA safety programs. USDA’s FSIS occupational safety and health program has safety and health committees that may analyze injury and illness data to identify the cause of an injury and develop preventative measures, among other things. FSIS safety and health specialists investigate safety concerns of FSIS inspectors in meat and poultry plants.

BLS is responsible for collecting and distributing statistical information on issues related to labor, and one of the studies it conducts is the SOII. Employers’ OSHA logs are the main source of data for the annual SOII. In addition to collecting information on all recorded injuries and illnesses, the survey, which draws from a sample of about 230,000 employers, requests detailed case data from employers for injuries or illnesses that resulted in at least 1 day away from work. This detailed case data includes information on the type, or nature, of the injury or illness and the exposure, or event, that caused it. OSHA officials told us that they use these data to help them develop national and regional emphasis programs that focus on specific industries or worksite hazards, and to select high hazard workplaces to receive OSHA support and assistance.

Within the Department of Health and Human Services (HHS), CDC’s NIOSH is the federal agency that conducts occupational safety and health research and workplace evaluations, and makes recommendations to prevent worker injuries and illnesses. At the request of employees, employee representatives, or employers, NIOSH may conduct a health hazard evaluation at a work site, such as a poultry plant, to determine if health hazards—such as chemical exposure or ergonomic hazards—are present. NIOSH provides assistance and information by phone and in writing to the requester and may visit the workplace to assess exposure and employee health.

USDA, under the Federal Meat Inspection Act and the Poultry Products Inspection Act, is responsible for ensuring the safety and wholesomeness of meat and poultry products that enter interstate commerce. In 2013, over 3,700 USDA FSIS inspectors worked in meat and poultry plants to provide continuous inspection of each meat and poultry carcass and its parts. Among other regulations, USDA sets maximum line speeds for slaughter plants in order to allow FSIS inspectors sufficient time to perform proper inspection procedures.

Federal Data Show a Decline in Injuries and Illnesses, Yet Meat and Poultry Workers Continue to Face Hazardous Conditions

Federal Data Show a Decline in Injury and Illness Rates for Meat and Poultry Workers

Injury and illness rates of total recordable cases in the meat and poultry industry declined from an estimated 9.8 cases per 100 full-time workers in calendar year 2004 to 5.7 cases in 2013, according to BLS data (see fig. 4). The decline is comparable to all U.S. manufacturing, which dropped from an estimated 8.2 cases to 5 cases per 100 full-time workers. However, the rates in the meat and poultry industry remained higher than those of manufacturing from 2004 through 2013.

While injury and illness rates have declined in the meat and poultry industry, meat workers sustained a higher estimated rate of injuries and illnesses than poultry workers from calendar years 2004 through 2013, according to BLS data (see fig. 5). For example, in calendar year 2013 there were an estimated 7.8 cases per 100 full-time workers in meat slaughter and 5.4 cases for meat processing, compared to an estimated 4.5 cases for poultry slaughter and processing.

The highest rates of injuries that resulted in days away from work in 2013 fell under the category of traumatic injuries—defined by BLS as injuries occurring from a single event over the course of a work shift—and included sprains, strains, and tears (see table 1). BLS collects data for injuries and illnesses that resulted in days away from work in order to understand the types of injuries and illnesses occurring and the events leading to them. BLS reports these data per 10,000 full-time workers— versus the rate per 100 full-time workers that is used for all injuries and illnesses. We are unable to show rates for these types of injuries over the past 10 years because BLS’s changes to some injury classifications in 2011 prevent direct comparisons over time. (Additional information on injury and illness rate estimates is contained in appendix I.)

The events that led to injuries or illnesses that resulted in days away from work also varied (see table 2). In calendar year 2013, “overexertion and bodily reaction,” a term BLS uses to capture injuries and illnesses resulting from activities such as overexertion when lifting and repetitive motion, was cited most frequently as the event that led to an injury (estimated 40.1 per 10,000 full-time workers). This is consistent with the findings in our 2005 report that back sprains and strains among meat and poultry workers can be caused from lifting heavy objects or repetitive lifting of lighter objects.

Some injuries have resulted in fatalities. According to BLS fatality data, 151 meat and poultry workers sustained fatal injuries in calendar years 2004 through 2013. Over that time, transportation incidents were the most frequent cause of death. For example, in calendar years 2011 through 2013, 46 meat and poultry workers sustained fatal injuries and 19 of these fatalities were caused by transportation incidents, such as being struck by a vehicle. Other causes of fatalities included violence from a person or animal, contact with objects or equipment, and exposure to harmful substances or environments.

Meat and poultry workers experienced higher illness rates than other manufacturing workers (see fig. 6). In calendar year 2013, there were an estimated 159.3 cases per 10,000 full-time meat and poultry workers, compared to an estimated 35.9 cases for manufacturing overall. To better understand illness rates, OSHA classifies total recordable cases of illnesses into five categories, such as skin diseases and respiratory conditions, which BLS reports per 10,000 workers. In the meat and poultry industry, illnesses accounted for over one-fourth of all reported injury and illness cases in calendar year 2013. According to BLS’s website, working conditions can be difficult in the meat and poultry industry because workers are exposed to hazards that may lead to an injury or an illness. In 2013, BLS categorized the poultry industry (104.2 cases per 10,000) and part of the meat industry—animal (except poultry) slaughtering—(319.7 cases per 10,000) as high-rate industries for illnesses because these industries had the highest incidence rate of total illness cases, compared to other industries with at least 500 cases.

USDA data show that its inspectors experience injuries and illnesses similar to those experienced by other meat and poultry workers. According to USDA’s 2014 workers’ compensation claims data, falls, slips, and trips were the most frequent causes of injuries among meat and poultry inspectors. USDA inspectors at plants we visited told us injuries and illnesses among inspectors vary, depending on whether they work in a meat or poultry plant. Specifically, inspectors told us that compared to inspectors in poultry plants, inspectors in meat plants sustain more cuts or lacerations because they make several cuts during hog and cattle inspections, while poultry inspections generally do not require any cuts to animal carcasses. Additionally, they said inspectors in poultry plants sustain more repetitive motion injuries due to faster line speeds. Some inspectors experience respiratory ailment symptoms due to chlorine used in poultry plants, according to USDA inspectors.

Evaluations, Studies, and Stakeholder Views Indicate that Hazardous Work Conditions Persist

Since our findings in 2005 on meat and poultry workers facing hazardous work conditions, NIOSH health hazard evaluations and academic studies have found that meat and poultry workers continue to face the types of hazards we cited, including hazards associated with musculoskeletal disorders, chemical hazards, biological hazards from pathogens and animals, and traumatic injury hazards from machines and tools. NIOSH’s findings are generally supported by OSHA documents and academic literature we reviewed, as well as by statements from workers and worker advocacy groups. (See appendix II for more information on NIOSH’s findings the from eight health hazard evaluations in poultry plants we reviewed.) In addition, other factors, such as employer emphasis on safety, worker training, and line speeds, may affect hazards and the risk of injuries and illnesses, according to literature we reviewed and the workers and officials we interviewed from federal agencies, the meat and poultry industry, and worker advocacy groups.

Assessing hand activity and force used by

Reviewing lab testing conducted by other causes of eye and respiratory irritation After NIOSH completes an evaluation, the agency typically makes recommendations to the employer on how to reduce or eliminate identified hazards and prevent related injuries and illnesses. According to officials, NIOSH disseminates the results of its evaluations as broadly as possible to help make industry- wide improvements even though evaluations focus on individual plants. According to NIOSH’s 2014 annual report, NIOSH received 209 requests and completed 33 field investigation reports and 118 consultation letters.

Meat and poultry work continues to require forceful exertions, awkward postures, and repetitive motions for many job tasks, which can lead to injuries. In a 2015 health hazard evaluation of a poultry plant, NIOSH reported 59 percent of the 32 job tasks evaluated—from receiving to deboning—had average levels of hand activity and force above the American Conference of Governmental Industrial Hygienists threshold limit value, and carpal tunnel syndrome among workers likely resulted from repetitive motion and the forceful nature of these job tasks. Similarly, in a 2014 health hazard evaluation of a poultry plant, NIOSH found 41 percent of participants worked in jobs that had levels of hand activity and force above the American Conference of Governmental Industrial Hygienists threshold limit values. In a 2008 NIOSH health hazard evaluation of a turkey plant, NIOSH found that hanging and unloading racks of turkey franks (hot dogs) during processing increased the risk of musculoskeletal disorders due to awkward postures, repetitive motions, and heavy lifting. According to the evaluation, in raw and cooked production, workers hung and removed franks from racks on 50- inch metal rods weighing up to 38 pounds, and reported discomfort in their backs and shoulders. NIOSH’s recommendations included job redesign and job rotation from lifting to non-lifting tasks to alleviate these hazards. Workers we interviewed also said that the repetitive nature of meat and poultry work leads to injuries. For example, one meat worker with more than 20 years of experience told us he almost constantly experiences discomfort and pain in his hands and that he only gets relief when he is not working.

Chemical Hazards

Chemicals are a hazard in meat and poultry plants because they can create a harmful environment if they accumulate within an enclosed space. Findings from two NIOSH health hazard evaluations suggested that exposure to chlorine may be associated with self-reported symptoms of respiratory illness or eye irritation. In its 2012 evaluation, NIOSH found that employees in an exposed group were more likely to report certain work-related symptoms than employees in an unexposed group, including chest tightness; sneezing; blurry vision; and burning, itchy, or dry eyes. NIOSH also found that while chlorine levels met USDA requirements, chlorine-related by-products called chloramines were often implicated as a more likely cause of irritation. According to NIOSH, there is no valid air sampling method to consistently detect levels of this by-product in plants. Hazardous chemicals in meat and poultry plants also include ammonia, which is used as a refrigerant. For example, a state OSHA official told us process safety management related to ammonia handling is among the top three violations in the meat and poultry industry. An OSHA regional official said common injuries in the meat and poultry industry stem from chemicals such as chlorine and ammonia, among other things.

Peracetic acid, an antimicrobial agent used to kill bacteria on poultry carcasses, may be harmful to workers. In November 2011 and January 2012, OSHA inspected a poultry plant after the death of a USDA inspector who worked there, including conducting chemical sampling at the plant. A regional OSHA official told us that OSHA suspected chemical exposure as the cause of death for the USDA inspector. According to OSHA and USDA officials, OSHA was unable to attribute the cause of death to any work-related conditions. In a June 2014 USDA letter to OSHA, USDA stated that it conducted additional air sampling at the poultry plant and did not detect any antimicrobial chemicals. However, according to an OSHA 2014 news release, OSHA cited the plant for, among other violations, failure to provide employees with information and training about the hazards of products that contain peracetic acid and bleach, as required by OSHA’s hazard communication standard. This citation was upheld by the Occupational Safety and Health Review Commission. The administrative law judge who upheld the hazard communication citation noted that employees told the OSHA compliance officer they had experienced respiratory ailment symptoms and rashes consistent with the exposure symptoms described in the chemical manufacturer’s safety data sheets, but the employer failed to train workers on chemical hazards, according to OSHA.

Biological Hazards— Pathogens and Animals

Meat and poultry workers continue to be exposed to biological hazards associated with handling live animals, including contact with feces, blood, and bacteria, which can increase their risk for many diseases, according to a NIOSH evaluation and investigations we reviewed. In a 2012 health hazard evaluation, NIOSH investigated exposure to the pathogen Campylobacter in a poultry plant and found gastrointestinal illness appeared to be common, yet underreported, based on interviews with workers. In the live hang area at poultry plants, workers lift live poultry from the supply conveyer belt and hang the birds by their feet from a shackle conveyor belt. In doing so, workers can be covered with poultry feces and dust that can carry pathogens and other diseases, according to OSHA. NIOSH observed that the 20 air vents above the heads of the live hang area employees could spread contamination, and it advised the plant to modify the supply vents. NIOSH also observed inconsistent hand hygiene and use of personal protective equipment in the area and recommended the plant provide training to all employees. In response, the plant instituted a monthly safety training meeting; offered computerized training in English and Spanish, including a competency test; and provided required personal protective equipment at no cost to employees, including smocks and safety glasses, as well as optional respirators and face shields in the live hang area. According to NIOSH, the number of plant employees with confirmed cases of Campylobacter infection dropped from 21 in 2011 to 6 in 2013 once these preventative measures were implemented.

In 2007, NIOSH assisted CDC and the Indiana, Minnesota, and Nebraska departments of health in their investigations of a progressive neurological disorder among workers in three hog slaughter plants, and in 2008 NIOSH conducted a health hazard evaluation at the hog slaughter plant in Minnesota. These plants had replaced saws with compressed air devices to reduce the risk of amputation, but the devices increased brain tissue splatter, causing a neurological disorder in several workers when they inhaled the animal matter, according to state officials. According to state and NIOSH investigators, workers at two of the plants also said line speed was a factor because the faster speeds meant they were unable to place the skulls completely on the device before triggering the compressed air, causing greater splatter. According to state officials, no new cases emerged after the three plants discontinued use of compressed air devices and the brain removal job task.

Traumatic Injury Hazards— Machines and Tools

Dangerous machines and tools remain a hazard within the meat and poultry industry, according to OSHA officials, workers we interviewed, and an academic study we reviewed. According to OSHA, moving machine parts can cause severe workplace injuries, such as crushed fingers or hands, amputations, burns, or blindness. OSHA officials we spoke with cited a lack of machine guarding—safety features on manufacturing equipment to prevent contact with the body or to control hazards from the machine—as a top safety violation at meat and poultry plants. Workers we spoke with experienced injuries from this hazard. For example, one meat worker showed us his scarred hand and said it had been caught in a machine, which crushed his finger and removed skin, necessitating a skin graft. Another worker’s apron was caught in a machine, which pulled her arm in before the machine could be turned off. As a result, she told us she can no longer work or perform daily activities with that arm. In addition to machinery, meat and poultry workers frequently use tools such as sharp knives, hooks, and saws. An academic study we reviewed examining the incidence of injuries, lacerations, and infections among poultry and pork processing workers employed by 10 companies found sharp tools were most frequently reported as sources of lacerations. A former meat worker we interviewed said he was injured twice by a neighboring worker’s hook when the other worker moved too close to him while trying to perform his task (see fig. 7).

Additional Factors May Affect Hazardous Conditions

Emphasis on worker safety, training, and line speeds may affect the risk of injuries and illnesses in the meat and poultry industry, but the underlying conditions remain, according to literature we reviewed, NIOSH health hazard evaluations, and interviews with federal officials, workers, and representatives of worker advocacy and industry groups.

Emphasis on worker safety: Emphasis placed on worker safety is a factor affecting workplace hazards, according to workers we interviewed and representatives from worker advocacy and industry groups. Some workers told us plants do not emphasize safety even when workers complain about hazardous conditions, but workers from two plants we visited said their company has a strong emphasis on worker safety. In at least half of the NIOSH health hazard evaluations we reviewed, NIOSH recommended or encouraged implementing worker safety programs or OSHA’s safety guidelines to help resolve identified hazards. Industry officials and a worker advocacy group told us plants should emphasize safety because it is in their best interest. Representatives from a worker advocacy group and industry officials told us that larger employers in the meat and poultry industry tend to have better worker safety practices than smaller ones. Representatives of meat and poultry industry associations also highlighted the implementation of worker safety programs in some plants over the last 20 years. In one study we reviewed, the authors suggested that workplace safety practices—such as the importance of safety to management, worker training, and proper use of safety equipment—can be modified to improve hazardous conditions in poultry plants.

Training: Worker training is critical to mitigating hazards and ensuring safety in the meat and poultry industry, but it remains a challenge, according to industry officials and workers with whom we spoke. In at least half of the NIOSH health hazard evaluations we reviewed, NIOSH recommended implementing proper training of workers.

However, industry officials said providing proper training can be a challenge because of different languages spoken by workers. For example, staff at two plants we visited said there are at least 20 languages spoken in their plants. At most of the plants we visited, managers told us that workers receive training during orientation and additional training may include annual training and working side-by- side with an experienced worker on the production line. Workers told us new hires receive video training on hazards and personal protective equipment, and acknowledge receipt of this training by signing an attestation document. Some meat and poultry workers told us the training is not always adequate. A hog plant worker said supplementary training should be provided on the job and at slower line speeds to ensure workers know how to do their jobs properly. One study we reviewed found that when workers in Nebraska and Iowa hog plants used an alternative method to accomplish a task, such as using different equipment, or performed a task in a different location within the plant, it was associated with increased risk of lacerations. The authors recommended expanded training and evaluation of tool sharpening procedures.

Line speed: High line speeds resulting from increased automation and other factors may exacerbate hazards, according to plant workers and worker advocacy groups. In 2013, 15 stakeholder groups petitioned OSHA and USDA, asking OSHA to establish a “work-speed” workplace safety and health standard—a regulation that would set the number of animals or products processed per minute on a production line in relation to staffing levels—to protect workers in the meat and poultry industry. The petition also requested that USDA and OSHA ensure that worker safety be protected in any rulemaking related to line and work speeds in this industry. USDA acknowledged receipt of the petition in 2013 and officials told us the agency made several changes to the poultry inspection final rule that addressed some of the issues in the petition, namely not increasing the maximum evisceration line speed in young chicken plants. In 2015, OSHA denied the petition and cited limited resources as its reason for not conducting a comprehensive analysis and rulemaking. Plant workers told us that meat and poultry plants are primarily concerned with production, and employers do not want the line to slow down even when the plant is understaffed. Industry officials we met with disagreed. According to representatives of a meat industry trade association, staffing is typically increased when line speed increases, and it is important to staff the line so that plant workers and USDA inspectors can accomplish all work tasks effectively. According to NIOSH officials, increasing line speed and workers may increase the risk of “neighbor cuts” due to workers’ close proximity. OSHA and NIOSH officials told us line speed—in conjunction with hand activity, forceful exertions, awkward postures, cold temperatures, and other factors such as rotation participation and pattern—affects the risk of both musculoskeletal disorders and injuries among workers. NIOSH examined the effect of increased evisceration line speed on worker safety at one plant in a 2014 health hazard evaluation, but the agency could not draw conclusions about its impact. Specifically, NIOSH stated in a 2014 letter to USDA that it could not draw conclusions on line speed and safety because the amount of time between the first and second visits (10 months) was not sufficient for a change in workers’ health to appear and the manner in which the plant modified the production lines resulted in no change in exposure to risk factors for musculoskeletal disorders for any individual worker, among other things. NIOSH stated that the plant’s consolidated evisceration lines resulted in a reduction of the number of birds processed because the plant combined two separate lines at 90 birds per minute into one line operating at approximately 170 birds per minute. In a 2015 health hazard evaluation, NIOSH found hand activity and force above recommended levels, as noted above, and after the evaluation the plant automated several jobs; however, the agency concluded that musculoskeletal disorder risks remain for many workers.

DOL Faces Challenges Gathering Data on Injury and Illness Rates Because of Industry Characteristics and Inadequate Data Collection

Meat and Poultry Worker Vulnerability and Employer Practices May Contribute to Underreporting of Injuries and Illnesses

Workers and employers may underreport injuries and illnesses in the meat and poultry industry because of worker concerns over potential loss of employment, and employer concerns over potential costs associated with injuries and illnesses, according to federal officials, worker advocacy groups, and studies. As a result, the injury and illness rates discussed in the previous section may not reflect complete data. In 2009, we reported on concerns about underreporting across all industries, including discrepancies between BLS’s annual survey used to calculate injury and illness rates and other data such as medical records. Due to concerns about reporting and also in response to findings and recommendations from our work in 2005 and 2009, OSHA undertook its Injury and Illness Recordkeeping National Emphasis Program. For this program, OSHA inspected recordkeeping and reporting accuracy in a nongeneralizable sample of over 300 establishments, primarily in industries with high average rates of injuries and illnesses. A 2013 analysis of data from this program indicates that OSHA identified reporting errors at establishments it inspected, but the prevalence of underreporting cannot be determined based on these data. While OSHA and BLS recognize that underreporting exists, the extent is unknown.

Underreporting continues to occur in the meat and poultry industry, according to worker advocacy groups and selected OSHA hazard alert letters we reviewed. Some meat and poultry workers may be less likely to report injuries and illnesses because of their vulnerable status as undocumented or foreign-born workers, according to federal officials and representatives of worker advocacy groups we interviewed. About 28.7 percent of meat and poultry workers were foreign-born noncitizens in 2015 compared to about 9.5 percent of all manufacturing workers, according to CPS data. The meat and poultry industry has been a starting point for new immigrants, as many jobs require little formal education or prior experience, according to a meat industry trade association. According to an OSHA official, worker advocacy groups, and plant managers at one plant we visited, some employers in the meat and poultry industry recruit refugees—in part, to replace undocumented workers—and some companies hire prison labor. Further, according to data from BLS, the meat and poultry industry had an hourly mean wage of $12.50 per hour in 2014 and an annual mean wage of $26,010. While above the federal minimum wage of $7.25 per hour, these wages are just above the 2014 federal poverty guidelines for a family of four. Workers who face economic pressures or have a tenuous immigration status may fear job loss or deportation if they report or seek treatment for work- related injuries and illnesses, according to federal officials and worker advocacy groups. For example, a community-based doctor told us that soon after he approved some injured meat workers’ work restriction requests, they returned and asked him to send a note to their workplace to end their work restriction because their employer had threatened to fire them if they could not do their jobs. Language barriers can also make it difficult for some of these workers to communicate about and report injuries, according to a worker advocacy group. In addition, NIOSH officials told us that in some cultures someone who reports an injury or illness is considered weak.

Some meat and poultry industry employers may not record worker injuries and illnesses because of certain disincentives, according to federal officials and representatives of worker advocacy groups we interviewed. We previously found that generally, employers may not record workers’ injuries and illnesses because of disincentives such as fear of increasing their workers’ compensation costs or jeopardizing their chances of being awarded contracts for new work. Federal officials and representatives of worker advocacy groups we interviewed told us that some employers in the meat and poultry industry may underreport workplace injuries to keep workers’ compensation insurance premiums low. In addition, some employers may underreport to avoid triggering OSHA inspections or promote the image of a safe workplace, according to a worker advocacy group and managers at one plant we visited. At one meat plant we visited, workers recalled incidents in which supervisors told injured workers they were not hurt and to go back to work rather than report their injury. NIOSH officials and a worker advocacy group attribute some underreporting in the meat and poultry industry to lack of paid sick leave, which may cause injured or ill workers to stay on the job so they can get paid. For example, some poultry plants use point systems to track sick days and may penalize workers for taking too many, according to worker advocacy groups. A former meat worker who was injured on the job told us he was suspended for three days after taking time off from work to recover and was later terminated. Workers and representatives of worker advocacy groups told us these systems discourage workers from reporting their injuries and illnesses. OSHA officials also expressed concerns that employer-sponsored safety programs with incentives— such as those that offer rewards for no injuries over time—may pressure meat and poultry workers to not report work-related injuries and illnesses.

Plant health units, which provide certain types of medical assistance to workers with injuries and illnesses at some plants, may also discourage reporting of injuries and illnesses, according to OSHA and worker advocacy groups. In an effort to maintain a clean safety record and avoid recording injuries in their OSHA logs, some plant health units may repeatedly offer first aid treatments—for example, compresses and over- the-counter painkillers and ointments—rather than refer workers to a doctor, according to two OSHA hazard alert letters, worker advocacy groups, and workers we interviewed. We were told about multiple incidents in which meat and poultry workers were punished for visiting the health unit too often or ignored by heath unit staff when they sought further medical care. For example: In 2014, OSHA sent a hazard alert letter to a poultry plant, recommending that the plant voluntarily take steps to improve its medical management practices. In the letter, OSHA identified practices that were contrary to good medical practice for managing work-related MSDs, including prolonged treatment by nursing station staff without referral to a physician. The letter included one example in which a worker made over 90 visits to the nursing station before referral to a physician.

In 2015, OSHA sent a hazard alert letter to another poultry plant, also recommending voluntary improvements to the plant’s medical management practices. The letter noted that based on OSHA’s investigation, it appeared that the plant used its first aid station to prevent injuries from appearing on the plant’s OSHA log, such as by not referring workers to a physician for evaluation or treatment when appropriate.

One worker told us that after he fell off a platform, the health unit provided ice and denied his request to be referred to a physician for x- rays. When he received an x-ray several days later, it confirmed that he had a fracture.

A representative of a worker advocacy group told us about an incident in which a nurse gave a worker with an injured wrist some cream and sent him home. The worker sought medical treatment on his own, which confirmed that he had a fractured wrist.

Meat and poultry industry representatives said underreporting is not a major issue, although some employers may not understand all of the reporting requirements. A meat industry trade association we interviewed noted that they organize seminars on reporting requirements and encourage employers to record all incidents in order to document improvement and avoid OSHA citations. Industry group representatives also stated that the decline in injury and illness rates discussed above is due in part to increased automation and industry efforts to enhance plant safety. OSHA officials concurred that increased automation in the industry has positively affected safety in limited areas of meat and poultry plants.

DOL Lacks Information That Could Help It Address Meat and Poultry Workers’ Musculoskeletal Disorders

DOL lacks key information about MSDs in the meat and poultry industry because of the way it gathers information on these conditions. It is particularly challenging to gather data on MSDs because the gradual nature of these injuries makes it harder for workers to recognize and report them, according to experts and worker advocacy groups. As discussed earlier, existing federal data and health hazard evaluations suggest that MSDs in the meat and poultry industry are common and can be disabling. In 2013, the incidence rate of MSDs that resulted in at least 1 day away from work was an estimated 39.2 cases per 10,000 workers in the meat and poultry industry overall and 25.2 cases per 10,000 workers in the poultry industry, according to BLS’s SOII. The 2013 incidence of carpal tunnel syndrome—an MSD—for cases that resulted in days away from work in the meat and poultry industry was an estimated 4.1 cases per 10,000, compared to 2.1 cases per 10,000 for manufacturing overall. A 2015 health hazard evaluation of a poultry plant by NIOSH found that over one-third of the workers who participated in the study had evidence of carpal tunnel syndrome. A 2014 NIOSH health hazard evaluation of poultry plant workers found that over two- thirds of workers interviewed reported experiencing pain, burning, numbness, or tingling in their hands over the preceding 12 months and that over half reported pain, aching, or stiffness in their backs during the same timeframe (see fig. 8).

OSHA and worker advocacy groups have also documented the debilitating effects of MSDs. OSHA reports, for example, that MSDs can be painful and disabling, and may cause permanent damage to musculoskeletal tissues.

Despite these concerns, DOL lacks information about MSDs in the meat and poultry industry because of how the data are collected. Specifically, BLS’s annual SOII only collects injury and illness details—such as the type of injury or illness—on cases that result in workers having to take days off from work. For example, the survey does not collect detailed information on MSDs that resulted in a worker being placed on work restriction, transferred to a different job, or continuing in the same job after medical treatment, making it more difficult to identify and track these MSDs. From 2011 to 2013, BLS conducted a pilot study, for which the SOII was modified to collect data for six selected industries (including food manufacturing) on the case circumstances and worker characteristics for cases where the worker was placed on work restriction or transferred to a different job. This pilot study found many of the MSDs occurring in the food manufacturing industry—which includes the meat and poultry industry—result in the worker being transferred to other jobs or restricted from activity in a current job without days away from work. For each calendar year from 2011 through 2013, the BLS study found that far more MSD cases in the food manufacturing industry resulted in job transfer or restricted work than in days away from work. For example, in 2013, the most recent data available, there were about 13,000 cases with job transfer or restricted work in this industry, compared to about 6,000 with days away from work.

The OSHA log, which employers use to respond to BLS’s SOII, also does not specifically classify recorded injuries or illnesses as MSDs. For each injury or illness recorded on the log, OSHA requires employers to check off a column indicating whether it is an injury or one of four specified types of illnesses: skin disorder, hearing loss, poisoning, or respiratory condition. Otherwise, the employer is to check “all other illnesses” (see fig. 9). However, the OSHA log does not include a place where employers can check off whether a recorded injury or illness is an MSD. Such information would only be included in the incident report, which is maintained by the employer and generally not sent to OSHA or BLS. Attempting to compile MSD data using individual incident reports would be difficult.

A former OSHA official said the agency added these columns to the log because OSHA determined that tracking these particular conditions was important to overseeing worker safety and health. Having these columns enables OSHA to more easily distinguish specific illnesses and conditions from other recorded cases.

Before 2001 the OSHA log included a column for “repeated trauma” cases, which included some, but not all, MSDs, as well as some non- MSD cases such as hearing loss. OSHA revised its recordkeeping regulations in 2001 and replaced this column with two, one column for MSDs and another for hearing loss. However, the MSD column never went into effect, and in 2003, the agency deleted the MSD column after determining the column was not necessary or supported by the record. Some public commenters had also expressed concern that the column was not necessary, did not clearly define MSDs, and imposed a paperwork burden. Because the column was deleted, the current OSHA log does not specifically classify MSDs, although MSDs must be recorded as injuries or illnesses on the log if they meet the criteria in OSHA’s recordkeeping regulations. In 2010, OSHA again proposed a rule that would have required employers to check off in a separate column on the OSHA log whether an already-recorded injury or illness was an MSD, stating that information generated from the column would improve the accuracy and completeness of national occupational injury and illness statistics, provide valuable industry-specific information to assist the agency in its activities, inform workers and employers, and would not be cost-prohibitive. However, the Department of Labor Appropriations Act, 2012 prohibited any funds from being used for the MSD column proposed rule. The prohibition was extended by the 2013 appropriations act, but was not included in subsequent appropriations. Since then, OSHA has not attempted to add an MSD column to the OSHA logs.

OSHA officials told us that it is vital to have accurate data on MSDs in the meat and poultry industry, and OSHA stated in its 2010 proposed rule to add a column to track MSDs that data from the column would assist the agency in targeting its inspections, outreach, guidance, and enforcement, among other things. BLS officials told us it would be a significant improvement if there were data that would quantify the extent of MSDs, as current data collection methods fall short. Although they stated they did not see a need for a column, representatives of trade associations for the meat and poultry industry we interviewed agreed that tracking MSDs at the plant level helps employers prevent and respond to these injuries. More MSD data would be helpful to OSHA and researchers, and a column on the OSHA injury log dedicated to MSDs could also make it simpler for employers to calculate their MSD rates, according to representatives of worker advocacy groups. Currently, employers must examine numerous entries in their OSHA injury log to calculate these rates. According to CDC, the first step in addressing health issues such as injuries is obtaining a full understanding of the extent of the problem. Federal internal control standards also call for accurate and timely recording to accomplish agency objectives. Without improving data on MSDs, BLS’s statistics on these conditions will remain limited and OSHA’s efforts to oversee employers and ensure workplace safety and health will continue to be hindered.

DOL Lacks Information on Injury and Illness Rates of Meat and Poultry Sanitation Workers

DOL does not know the extent to which injuries and illnesses occur among meat and poultry sanitation workers—who may be employed directly by a plant or work for a separate contract sanitation company— because of how data on these workers are collected. Although they labor in the same plants and under working conditions that can be as hazardous as those of production workers, in 2005 we found sanitation workers employed by contract sanitation companies were not classified by BLS in the SOII as working in the meat and poultry industry. We concluded that OSHA, as a result, was not considering all injuries and illnesses at a plant when selecting plants to be inspected because some worker injuries and illnesses were not included in OSHA logs at those sites. We recommended that DOL require certain plants to provide OSHA with worksite-specific data of injuries and illnesses of workers employed by contract cleaning and sanitation companies so these data could be included in the rates OSHA uses to select plants for inspection. DOL did not implement this recommendation, citing a decision it had already made against requiring employers in the construction industry to collect contract worker data because of the burden to that industry, among other things.

DOL has not taken action to improve data on sanitation workers, despite continued concerns expressed by OSHA about how sanitation work by both plant employees and contracted workers is one of the most hazardous occupations in the industry. Many sanitation workers work overnight during a plant’s “third shift” and are responsible for cleaning floors, machinery, and all product contact surfaces throughout the plant to comply with USDA requirements. Workplace hazards for sanitation workers employed directly by plants and those employed by contract sanitation companies include potential exposure to electrical, mechanical, hydraulic, and other sources of energy and potentially harmful chemicals. In 2013, for example, a 41-year-old sanitation worker was killed when he fell into an industrial blender at a meat plant, according to a fatality investigation report by the Oregon Fatality Assessment and Control Evaluation program of the Oregon Institute of Occupational Health Sciences. In 2015, according to an OSHA citation, a sanitation worker at a poultry plant lost two of his fingertips when a machine he was cleaning was mistakenly turned on. Two weeks later at the same plant, according to the same citation, a 17-year-old sanitation worker lost part of his leg when he was caught in a machine that lacked safety mechanisms.

Another challenge in tracking injury and illness rates among sanitation workers is that even for those workers directly employed by meat and poultry plants (as opposed to those working for a contractor), the plants use different occupational titles for these workers on their OSHA logs. Employers record the injured workers’ job titles on their OSHA log, then, in its SOII, BLS codes these data using a standardized system. BLS officials told us that under this system these workers’ occupations may be listed as “janitors and cleaners,” “cleaners of vehicles or equipment,” or other occupational categories such as “production workers-all other” or “food processing workers-all other.” As a result of using these various occupational titles, which may cover regular production workers as well, DOL is not able to determine which injuries and illnesses pertain to meat and poultry sanitation workers.

According to BLS, it also may not be possible to gather separate injury and illness data on those meat and poultry sanitation workers who are employed by contract sanitation companies. Under OSHA’s recordkeeping requirements, either the contract sanitation company or the plant may be required to track these workers’ injuries, depending on which entity is providing day-to-day supervision. As a result, injury and illness data for these workers in BLS’s SOII may be coded according to their employer’s industry—janitorial services, for example—and would therefore not be captured in injury and illness rates for the meat and poultry industry. Officials at four of the six plants we visited told us that the contract sanitation company they work with maintains the injury log for these workers. Officials at one contract sanitation company told us that both they and the plants with which they contract keep OSHA logs, and that the data the company sends to BLS from its OSHA log are coded under the “janitorial services” industry. BLS officials told us that it may not be possible to require contract sanitation companies to identify the industry of the companies they contract with because many of these companies provide services to a wide variety of businesses.

As a result of how DOL gathers information on meat and poultry sanitation workers’ injuries and illnesses, OSHA has little data to work with when determining how to oversee these workers’ safety and health. Federal internal control standards call for agencies to track data to help them make decisions and meet their goals. According to OSHA, inaccurate data can lead to misleading conclusions regarding incidence, trends, causation, and effectiveness of abatement strategies. Because of limitations in the BLS data on injuries and illnesses of workers in meat and poultry plants, OSHA cannot fully assess the extent to which it is fulfilling its worker safety mission or successfully carrying out its enforcement and other activities. In addition, the agency may not be doing all it can to ensure sanitation workers are protected from workplace hazards.

Several new developments may make it easier for OSHA to obtain more data on sanitation workers at meat and poultry plants. As of January 2015, employers covered by federal OSHA are required to report all work- related in-patient hospitalizations, amputations, and losses of an eye directly to OSHA within 24 hours. Previously, OSHA received more limited information on amputations and hospitalizations through direct employer reports. Reports on such cases involving meat and poultry sanitation workers may provide OSHA with additional details on injuries to this population. In addition, in October 2015, OSHA initiated two regional emphasis programs for the poultry industry in the southern United States. These programs—along with an ongoing regional emphasis program on poultry industry sanitation workers in the same region—mean OSHA will conduct more poultry plant inspections and gather more data on risks to sanitation and other workers, a former OSHA official told us.

OSHA may also be able to work with NIOSH to gather information about sanitation worker injuries and illnesses. NIOSH officials told us that they recently were able to conduct studies in other industries because OSHA had negotiated their access after issuing citations. OSHA officials agreed that NIOSH reports could be useful to their inspections. NIOSH’s last health hazard evaluation of meat and poultry sanitation workers was conducted in 2002. At that time, NIOSH examined the use of sanitizing agents, such as bleach, in a meat processing plant, and analyzed their connection to respiratory disorders among five sanitation workers in that plant. All five sanitation workers reported symptoms consistent with known irritant effects of bleach, such as throat irritation and burning or stinging eyes, and the symptoms disappeared when the use of bleach was discontinued. Since then, NIOSH has not conducted any additional health hazard evaluations on meat and poultry sanitation workers, since they must rely on plant management, workers, or worker representatives to request a health hazard evaluation. However, NIOSH can also self- initiate studies on occupational safety and health issues and may conduct studies in response to requests from federal, state, or local agencies. In the absence of additional studies on meat and poultry sanitation workers, both OSHA and NIOSH may be missing an opportunity to learn more about the nature and extent of sanitation worker injuries and illnesses.

Conclusions

While overall injury and illness rates have decreased since our last report, meat and poultry workers continue to face worksite hazards that put them at risk of severe and lasting injury. Obtaining complete information about injuries and illnesses in the meat and poultry industry continues to be a challenge that affects DOL’s ability to calculate accurate rates and ensure safe and healthy workplaces. Recent OSHA inspections suggest that more injuries occur than are reported, although the extent of underreporting is not known, and vulnerable workers such as immigrants and noncitizens may fear for their livelihoods and feel pressured not to report injuries. Our findings raise questions about whether the federal government is doing all it can to ensure it collects the data it needs to support worker protection and workplace safety. Strengthening DOL’s data collection on worker injuries and illnesses is the first step towards achieving that goal. Collecting accurate and complete data on MSDs is particularly important, because these disorders are common among this workforce and can be severe and debilitating. However, OSHA does not have a cost-effective method for distinguishing MSDs from other recorded cases, hindering OSHA’s efforts to ensure workplace safety and health. In addition, OSHA and BLS continue to face challenges determining the rates of injury and illness among meat and poultry sanitation workers. Until DOL is able to gather more complete data on sanitation workers in these plants, it does not have an accurate picture of total injuries and illnesses in the meat and poultry industry, and it cannot know how to best protect these sanitation workers. New developments provide an opportunity for DOL to learn more about the injuries and illnesses suffered by these workers and to develop ways to better track them. NIOSH, the federal agency responsible for researching workplace safety and health, may be well-placed to conduct an in-depth study on the injuries and illnesses experienced by this population.

Recommendations for Executive Action

We are making the following three recommendations: To strengthen DOL’s efforts to ensure employers protect the safety and health of workers at meat and poultry plants, the Secretary of Labor should direct the Assistant Secretary for Occupational Safety and Health, working together with the Commissioner of Labor Statistics as appropriate, to develop and implement a cost-effective method for gathering more complete data on MSDs.

To develop a better understanding of meat and poultry sanitation workers’ injuries and illnesses:

The Secretary of Labor should direct the Assistant Secretary for Occupational Safety and Health and the Commissioner of Labor Statistics to study how they could regularly gather data on injury and illness rates among sanitation workers in the meat and poultry industry.

The Secretary of Health and Human Services should direct the Director of the Centers for Disease Control and Prevention to have NIOSH conduct a study of the injuries and illnesses these workers experience, including their causes and how they are reported. Given the challenges to gaining access to this population, NIOSH may want to coordinate with OSHA to develop ways to initiate this study.

Agency Comments and Our Evaluation

We provided a draft of this report to the Secretary of Labor, the Secretary of Agriculture, and the Secretary of Health and Human Services for their review and comment. DOL and HHS provided comments, reproduced in appendixes IV and V, respectively. DOL generally agreed with our recommendations and stated that their implementation would make a difference in working conditions in the meat and poultry industry. DOL also noted that it may not be easy to implement our recommendations due to resource constraints. We are pleased that DOL agreed with our recommendations.

HHS concurred with our recommendation to have NIOSH conduct a study of the injuries and illnesses of sanitation workers in the meat and poultry industry. HHS noted the previous difficulties NIOSH has had gaining access to these workplaces and the potential resource commitment involved in conducting such a study. In the report we acknowledged the access challenge and noted that OSHA has negotiated access for NIOSH in other industries, which is why we suggested in the recommendation that NIOSH may want to coordinate with OSHA.

USDA generally agreed with our findings and recommendations, and provided technical comments, which we incorporated as appropriate.

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If you or your staff have any questions about this report, please contact us at (202) 512-7215 or brownbarnesc@gao.gov or at (202) 512-3841 or morriss@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix VI.

Appendix I: Scope and Methodology

This report (1) describes what is known about injuries, illnesses, and hazards in the meat and poultry industry since we last reported, and (2) examines what, if any, challenges the Department of Labor (DOL) faces in gathering data on injury and illness rates in this industry.

To describe what is known about injuries, illnesses, and hazards in the meat and poultry industry since we last reported, we analyzed and reported survey data from DOL’s Bureau of Labor Statistics’ (BLS) Survey of Occupational Injuries and Illnesses (SOII) for calendar years 2004 through 2013 (the most recent year for which data were available). The SOII provides estimates of the number and frequency (incidence rates) of workplace injuries and illnesses by industry and also by detailed case circumstances, such as injury type and event, and worker characteristics for cases that result in days away from work, based on data from logs kept by employers (survey respondents)—private industry and state and local governments. Survey respondents provide counts for all recordable injuries and illnesses under Occupational Safety and Health Administration (OSHA) recordkeeping regulations. Survey respondents also provide additional information for a subset of cases, specifically those that involved at least 1 day away from work. In 2011, the BLS Occupational Injury and Illness Classification System and definitions of some injuries changed, thereby preventing direct comparison of case characteristics over time. We report estimates of detailed case characteristics from various injuries and illnesses, such as carpal tunnel syndrome, that resulted in days away from work in the most recent calendar year available, 2013.

To report SOII data from the meat and poultry industry (using North American Industry Classification System (NAICS) code 31161 for the animal slaughtering and processing industry) and manufacturing overall (NAICS codes 31-33), BLS provided estimates of each industry’s injury and illness incidence rates and their associated relative standard errors. All estimates produced from the analysis of the SOII data are subject to sampling errors. We express our confidence in the precision of the results as a 95 percent confidence interval. This is the interval that would contain the actual population value for 95 percent of the samples the respective agency could have drawn. For estimates derived from BLS’s SOII data, we used the agency-provided relative standard errors to estimate the associated confidence intervals. All estimates we report have the associated 95 percent confidence interval provided.

We also reviewed BLS’s Census of Fatal Occupational Injuries (CFOI) data for calendar years 2004 through 2013, the most recently available data, to better understand the number of fatalities and their circumstances, including causes in the meat and poultry industry. The CFOI is a federal-state cooperative program that has been implemented in all 50 states and the District of Columbia since 1992. According to BLS, the CFOI program uses diverse state, federal, and independent data sources to identify, verify, and describe fatal work injuries to ensure counts are as complete and accurate as possible. CFOI compiles a count of all fatal work injuries occurring in the United States during the calendar year. Fatal injury counts exclude illness-related deaths unless precipitated by an injury event. As previously stated, in 2011 the classification systems and definitions of some data elements changed, and this change may not allow comparing CFOI data within specific fatality categories to previous years. Therefore, we reported total fatalities over a 10-year period rather than annual totals within each major fatality category.

To assess the reliability of BLS SOII and CFOI data, we reviewed documents related to the data sources, such as BLS’s Handbook of Methods, and we interviewed agency officials knowledgeable about these data. We found that SOII and CFOI data were sufficiently reliable for our purposes in generally reporting estimated incidence rates of injuries and illnesses in the meat and poultry industry and manufacturing overall, describing injuries and illnesses, and reporting total fatalities in the meat and poultry industry.

We also obtained and reviewed fiscal year 2014 workers’ compensation data from USDA’s Food Safety and Inspection Service (FSIS) to describe the injuries, illnesses, and hazards experienced by inspectors in meat and poultry plants. USDA’s workers’ compensation data includes injuries and illnesses from workers who filed a workers’ compensation form. A limitation of this data source is that workers’ compensation data likely undercounts injuries and illnesses. To assess the data’s reliability, we interviewed agency officials, reviewed documentation on FSIS’s workers’ compensation program, and checked the data for discrepancies. We found the data were sufficiently reliable for our purposes.

We reviewed literature from peer-reviewed journals, Centers for Disease Control and Prevention’s (CDC) National Institute for Occupational Safety and Health (NIOSH) health hazard evaluations, and OSHA guidance documents on factors that affected injury and illness rates and hazards in the meat and poultry industry since we last reported.

We conducted a literature search for studies that examined factors affecting injury and illness rates, as well as hazards in the meat and poultry industry. Based on our literature review, we reported information from four peer-reviewed studies. To identify studies from peer-reviewed journals, we conducted searches of various databases, such as Web of Science, Scopus, and ProQuest and requested suggestions from officials we interviewed. We further limited our review to studies on meat and poultry workers only; therefore, we excluded any studies that made comparisons between workers in the meat and poultry industry and other industries. From this review, we identified 19 studies that appeared in peer-reviewed journals between 2005 and 2015. Of the 19 studies, we excluded two studies that summarized findings from two NIOSH health hazard evaluations that we had previously obtained and reviewed. We noted that 8 of the 17 studies relied on a community-based approach to obtain participants rather than recruiting them directly from plants. These studies focused exclusively on a subset of the worker population within the meat and poultry industry, namely women and Hispanic or Latino poultry workers in North Carolina. We included observations from 1 of the 8 studies, which focused on Hispanic poultry workers, but we noted study limitations in the report. We included findings from 3 of the other 9 studies: (1) a study on a neurological disorder experienced by workers in three hog plants that illustrated hazards related to animals, (2) a study on lacerations in meatpacking describing hazards related to machines and tools, and (3) a study on laceration injuries experienced by meat and poultry workers employed by 10 companies representing 22 poultry plants and 8 pork plants to illustrate factors that may affect injury and illness rates in the meat and poultry industry.

We identified and reviewed eight NIOSH health hazard evaluations published from 2007 to 2015 that describe various hazards in poultry plants, as well as factors that may affect injury and illness rates in this industry. NIOSH officials told us the agency has not conducted similar evaluations in meat plants to those it conducted in poultry plants because the agency has not received any requests to do so. Findings from NIOSH evaluations we reviewed are not generalizable to illustrate hazards in all poultry processing plants in the United States.

We reviewed OSHA guidance documents on hazards in meat and poultry plants, including OSHA’s e-Tool for poultry processing which details workplace hazards by job task in the poultry industry.

To examine the challenges DOL may face in gathering data on injury and illness rates in this industry, we reviewed relevant federal laws and regulations, as well as OSHA documentation. We also reported BLS data and reviewed documentation on musculoskeletal disorders (MSD), including a pilot study on cases involving job transfer and work restriction from data collected from 2011 through 2013. We obtained and analyzed data on worker demographics from the Current Population Survey (CPS), jointly sponsored by BLS and the Census Bureau, from March 2015, the most recent data available. We assessed the reliability of CPS data by reviewing documentation, interviewing knowledgeable agency officials, and performing electronic data testing, and determined the data were sufficiently reliable for our purposes. Because the CPS estimates are based on probability samples, they are subject to sampling error. For the CPS estimates in this report, we estimated sampling error and produced confidence intervals using the methods provided in the technical documentation of CPS’s March 2015 supplement. To report wages of meat and poultry workers, we used estimates of average annual and monthly wages for slaughterers and meat packers (Standard Occupational Classification code 513023) in the animal slaughtering and processing industry (NAICS 31161) and their associated relative-standard errors from BLS’s Occupational Employment Statistics (OES) survey data from May 2014. We used the relative-standard errors to calculate 95 percent confidence intervals for estimates derived from BLS’s OES survey data. We found the BLS and CPS data were sufficiently reliable for our purposes. We interviewed OSHA officials—including officials from all 10 regional OSHA offices—and FSIS and NIOSH officials. We also interviewed Georgia Tech Research Institute staff who conducted research on sanitation workers in the poultry industry to learn about hazards faced by sanitation workers in the meat and poultry industry. Moreover, to describe challenges in gathering data on sanitation workers, we reviewed a 2002 NIOSH evaluation on sanitation workers and interviewed one sanitation company that provides cleaning services in the meat and poultry industry. Of the two other sanitation companies we approached, one declined to meet with us and other company did not respond to our request.

To respond to both objectives, we interviewed representatives from stakeholder groups and visited several meat and poultry plants. We identified and interviewed 13 stakeholder groups (unions, worker advocacy groups, and industry trade organizations) with sufficient knowledge about worker safety in the meat and poultry industry, in part based on previous work as well as referrals from other stakeholder groups. We also reviewed information obtained from these groups. These stakeholder groups were the American Federation of Government Employees/National Joint Council of Food Inspection Locals, the Government Accountability Project, Legal Aid of North Carolina, the National Chicken Council, the National Council for Occupational Safety and Health, the National Turkey Federation, Nebraska Appleseed, the North American Meat Institute, Oxfam America, the Southern Poverty Law Center, Student Action with Farmworkers, the United Food and Commercial Workers International Union, and the U.S. Poultry and Egg Association. We attended a meat industry conference on worker safety, as well as a worker safety conference organized by the National Council for Occupational Safety and Health. Finally, we visited six meat and poultry plants—selected to cover a mix of species (chicken, turkey, hog, and cattle) and states (Missouri, Nebraska, North Carolina, and Virginia), as well as union and non-union plants and two plants that were part of the FSIS pilot project—where we met with plant management, USDA’s FSIS management and inspectors, and plant safety and health staff. We also met with current and former workers, who were selected either by unions, worker advocacy groups, or plant managers. The information gathered in these interviews is not generalizable to all plants or workers. To assess DOL’s efforts based on the information gathered in interviews and site visits, we used federal internal control standards that call for agencies to track data and to undertake accurate and timely recording to accomplish agency objectives.

We conducted this performance audit from December 2014 to April 2016 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Summary of Selected Health Hazard Evaluations in the Poultry Industry Conducted by the National Institute for Occupational Safety and Health, 2007-2015

The National Institute for Occupational Safety and Health (NIOSH) conducted eight health hazard evaluations published from 2007 to 2015 that describe various hazards in poultry plants. Table 3 presents a summary of selected findings and recommendations from these health hazard evaluations. Selected findings on hazards are not generalizable to all poultry processing plants in the United States. This table is not intended to be a complete list of NIOSH’s findings and recommendations; for more complete information, refer directly to the cited NIOSH health hazard evaluation.

Appendix III: OSHA’s Form 300—Log of Work-Related Injuries and Illnesses

Appendix IV: Comments from the Department of Labor

Appendix V: Comments from the Department of Health and Human Services

Appendix VI: GAO Contacts and Staff Acknowledgments

GAO Contacts

Staff Acknowledgments

In addition to the contacts named above, Blake Ainsworth, (Assistant Director), Mary Denigan-Macauley (Assistant Director), Eve Weisberg (Analyst-in-Charge), Nkenge Gibson (Analyst-in-Charge), Leah English, Monika Gomez, Susan Aschoff, James Bennett, Sarah Cornetto, and Lorraine Ettaro made significant contributions to this report.

Also contributing to this report were Diann Baker, Carl Barden, Carol Bray, Angela Clowers, Marcia Crosse, Grant Mallie, Sheila McCoy, John Mingus, and Michelle Sager.

Related GAO Products

Food Safety: USDA Needs to Strengthen Its Approach to Protecting Human Health from Pathogens in Poultry Products. GAO-14-744. Washington, D.C.: September 30, 2014.

Food Safety: More Disclosure and Data Needed to Clarify Impact of Changes to Poultry and Hog Inspections. GAO-13-775. Washington, D.C.: August 22, 2013.

Workplace Safety and Health: OSHA Can Better Respond to State-Run Programs Facing Challenges. GAO-13-320. Washington, D.C.: April 16, 2013.

Workplace Safety and Health: Further Steps by OSHA Would Enhance Monitoring of Enforcement and Effectiveness. GAO-13-61. Washington, D.C.: January 24, 2013.

Workplace Safety and Health: Multiple Challenges Lengthen OSHA’s Standard Setting. GAO-12-330. Washington, D.C.: April 2, 2012.

Workplace Safety and Health: Enhancing OSHA’s Records Audit Process Could Improve the Accuracy of Worker Injury and Illness Data. GAO-10-10. Washington, D.C.: October 15, 2009.

Workplace Safety and Health: Safety in the Meat and Poultry Industry, While Improving, Could Be Further Strengthened. GAO-05-96. Washington, D.C.: January 12, 2005.

Food Safety: Weaknesses in Meat and Poultry Inspection Pilot Should Be Addressed Before Implementation. GAO-02-59. Washington, D.C.: December 17, 2001.

Community Development: Changes in Nebraska’s and Iowa’s Counties with Large Meatpacking Plant Workforces. GAO/RCED-98-62. Washington, D.C.: February 27, 1998.