Sunday, January 30, 2005

Stronger Inspection and Monitoring by OSHA Recommended In Meatpacking Plants

Following on last week's Human Rights Watch report concerning the hazardous working conditions in meatpacking and poultry processing plants, the Government Accountability Office (GAO) has released a report confirming those conditions and has recommended that OSHA improve its inspection programs and monitoring of conditions in these plants.

The GAO report describes what has become a familiar litany of hazardous conditions in these workplaces:

The type of work performed and the plant environment expose workers to many hazards. The work is physically demanding, repetitive, and often requiresworking in extreme temperatures—such as in refrigeration units that range frombelow zero to 40 degrees Fahrenheit—and plants often have high turnover rates.Workers often stand for long periods of time on production lines that move veryquickly, wielding knives or other cutting instruments used to trim or remove portions of the carcasses. Conditions at the plant can also be loud, wet, dark, and slippery. Workers responsible for cleaning the plant must use strong chemicals and hot pressurized water to clean inside and around dangerous machinery, and may experience impaired visibility because of steam.

Meat and poultry workers sustain a range of injuries, including cuts, burns, and repetitive stress injuries, and while, according to BLS, injuries and illnesses in the meat and poultry industry declined from 29.5 injuries and illnesses per 100 full-time workers in 1992 to 14.7 in 2001, the rate was among the highest of any industry. Similarly, though not comparable with these data because of recent changes in OSHA’s record-keeping requirements, statistics for 2002 indicate that injury and illness rates in the meat and poultry industry remain high in relation to those of other industries.


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.

Some of the report's descriptions of workplace injuries and fatalities are quite graphic:

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.

Forty-two percent of workers in the plants are Hispanic (up from 25% in 1994) and 26% are foreign born non-citizens. One agency official estimated that up to 25 percent of workers in meatpacking plants in Nebraska and Iowa were "illegal aliens" [sic].

Aside from its general observations about the hazards of life in meatpacking plant, the report raises a number of important issues concerning the accuracy of employer injury and illness records that need to be addressed by OSHA, not just in this industry, but others as well.
Because of the many hazards inherent in meat and poultry plants and the type of work performed, the dramatic decline in the industry’s injury and illness rates has raised a question about the validity of the data on which these rates are based. Several factors can affect the rates of injury and illness, such as an emphasis on safety by employers or employees, the amount and quality of training, employee turnover rates, and the speed of the production line.
The main problem addressed by this report are the holes in OSHA's targeting system, known as the Site Specific Targeting (SST) program. As OSHA can't visit every workplace every year, the idea behind SST is to target the most dangerous workplaces. Under SST, OSHA attempts to target companies for inspection based on the relative hazard of the industry in belongs to, and the company's specific injury and illnesses statistics. All of these injury and illness statistics are self-reported by the employer. There are several problems with this system that have been well known inside and outside of OSHA, but are nicely documented in this report.

  1. The employer is only required to report injuries, illnesses and fatalities for employees who work for that specific employer. The problem is that meatpacking and poultry processing plants (like other parts of American industry) are increasingly contracting out the jobs of workers who clean the plants, one of the most dangerous jobs in the factories.
    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.
  2. The second major problem identified by the report is that OSHA doesn't keep track of trends in individual companies, so that the agency is not able to evaluate the accuracy of reports from companies that show dramatic declines in injury and illness numbers from one year to the next. As mentioned in a recent article on injuries and fatalities in the steel industry, there is suspicion that because low injury and illness rates significantly reduce the likelihood of an inspection, companies have an incentive to underreport injuries and illnesses. In addition, although OSHA audits recordkeeping accuracy at a number of worksites every year, few of these are at meatpacking or poultry plants.

  3. OSHA does not assign a unique identifier to each site it inspects or audits, making it difficult for the agency to monitor trends or the reasons for improvements in any individual company. OSHA is unable, for example, to match the injury and illness data it collects from employers to data on inspections and employer participation in its cooperative programs.

    In a March 2004 report, GAO criticized OSHA for its lack of comprehensive data on its cooperative programs — such as their relative impact on worksites’ safety and health —which makes it difficult to fully assess the effectiveness of these programs, despite the substantial amount of resources that OSHA devotes to these program.

GAO makes a number of recommendations to OSHA, including looking more closely at sites that report significant decreases in injury and illness numbers, requiring companies to report multiple years of data, as well as injury and illness data on employees who work cleaning and sanitation contractors, and giving plants unique identifiers to enable OSHA to better evaluate the effectiveness of enforcement and cooperative programs. The GAO also recommended that the National Institute for Occupational Safety and Health (NIOSH) perform a study on the effect of line speed on the health and safety of workers in meatpacking and poultry processing companies.

Responding to Industry

The report provides an interesting and timely answer to the American Meat Institute's (AMI)response to the Human Right Watch Report.

Human Rights Watch accused the meatpacking industry of under-reporting injuries. AMI responded that "The Occupational Safety and Health Administration (OSHA) closely and regularly monitors the record keeping of employers to ensure that injuries are reported." The GAO, however, criticizes OSHA because in 2003, only 5 of the 200 worksites selected for OSHA recordkeeping audits were meatpacking plants; in 2004, 10 were meatpacking plants. GAO concludes that "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."

AMI also criticizes the Human Right Watch report for claiming that workers are forced to work at “unprecedented volume and pace.” Not so, says AMI:

Line speeds, which are monitored by USDA’s Food Safety and Inspection Service, have not changed appreciably in 15 years, and are engineered to ensure that the amount of work reaching an employee is appropriate and safe.
Actually, notes the GAO:

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.
Also of interest is the report's description of problems that unions are having in the industry, especially in light of the AMI's contention that "Many workers have decided to remain non-union because they see little value in union membership."

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.

UPDATE: Senator Edward M. Kennedy (D-MA), who requested the GAO report, made the following statement:
“The failure to obtain needed information about these injuries is inexcusable and shows the weakness of the Bush Administration’s casual approach to worker safety. OSHA should track this data carefully, restore reporting of ergonomics-related injuries, and increase the number of inspections in this dangerous industry.

“We also need action by other agencies. I commend HHS for acknowledging the need to study line speed injuries and I urge it to begin this project immediately. OSHA and USDA should provide needed training to USDA inspectors, who are frequently in these plants. We should use their expertise to strengthen both worker safety and consumer safety.”