By Brent I. Clark, James L. Curtis, and Craig B. Simonsen

Empty Hooks In A Meat Processing FactoryThe Occupational Safety & Health Administration recently issued its “Inspection Guidance for Poultry Slaughtering and Poultry Processing Establishments” (October 28, 2015).

OSHA explains in the Guidance that workers employed in the poultry industry may face many hazards, including high noise levels, dangerous equipment, musculoskeletal disorders, and hazardous chemicals. Poultry processing is highly mechanized, so walkways may be adjacent to conveyors. Processing meat uses a large amount of water that may splash on walkways and stairs. The addition of scraps of fatty skin from the poultry carcass can create slippery surfaces.

OSHA indicates that it believes that poultry workers suffer serious injury at a rate that is almost double private industry. Also, OSHA contends that “musculoskeletal disorders are of particular concern and continue to be common among workers in the poultry processing industry.”

In a multi-agency cooperation, the Guidance specifies that OSHA inspectors (CSHOs) should identify if the poultry processing plant has adopted the United States Department of Agriculture (USDA) New Poultry Inspection System (NPIS). Facilities that have adopted NPIS submit an annual attestation to the management member of the local Food Safety Inspection Service (FSIS) circuit safety committee, stating that it maintains a program to monitor and document any work-related conditions. The elements of this program include:

  1. Policies to encourage early reporting of symptoms of work-related injuries and illnesses;
  2. Notification to employees of the nature and early symptoms of occupational illnesses and injuries, in a manner and language that workers can understand, including by posting in a conspicuous place or places where notices to employees are customarily posted, a copy of the FSIS/OSHA poster encouraging reporting and describing reportable signs and symptoms;
  3. Monitoring on a regular and routine basis of injury and illness logs, as well as nurse or medical office logs, workers’ compensation data, and any other injury or illness information available; and
  4. A commitment to issuing FSIS notice, “Procedures for Notifying the Occupational Safety and Health Administration (OSHA).” The notice establishes a procedure for FSIS inspection personnel to notify OSHA directly of serious workplace hazards that may affect non-federal establishment personnel in meat and poultry products establishments and in egg product plants.

The Guidance reviews numerous alleged issues regarding musculoskeletal disorders and outlines potential means to reduce risk factors.

The Guidance includes a sample “alleged violation description” for potential ergonomics hazards with recommended abatement action and “additional methods of reducing the ergonomic hazards.” This section of the Guidance may be of particular interest to employers because it provides insight into the hazards OSHA believes exist (before they enter the work place) and now OSHA views abatement.

Note that the guidance directs that because “these hazards have been identified nationwide,” State Plans are expected to follow the guidance provided in this memorandum.

Employers in this industry sector need to be zealous to review and update their safety and training programs to encompass the issues covered in this Guidance.  You may be certain that the Agency’s inspectors will be looking for that too. The Guidance is also of interest to employers in other industries because it provides insight into OSHA’s focus on and approach to potential ergonomic hazards.