Workplace Safety and Health: Safety in the Meat and Poultry Industry, While Improving, Could Be Further Strengthened

According to officials at OSHA, the agency already has the ability to analyze trends in rates for specific establishments. Establishments that report high rates of injuries and illnesses (i.e., a Days Away, Restricted, or Transferred (DART) rate of 7.0 or greater) are included in the data collection in consecutive years. OSHA has stated that it can therefore trend rates for that establishment on an annual basis. Collection of multiple years of data during one collection would be redundant and contrary to the requirements of the Paperwork Reduction Act (PRA). According to OSHA, establishments that do not report high DART rates are included in the OSHA Data Initiative (ODI) collection on a rotating basis, generally every second or third year. While this precludes OSHA from having a complete data set, it does not limit the agency's ability to trend data over time. If the establishment continues to operate, OSHA will have multiple years of data for that establishment. Given its current ability to trend and analyze multiple years of establishment level data, OSHA does not see the need to modify its data collection procedures as recommended by GAO. With regard to the collection of data on injuries and illnesses to workers that work at meat packing facilities but are employed by other companies, OSHA believes this recommendation would be contrary to the record developed in the 2001 revision of the injury and illness recordkeeping requirements (29 CFR Part 1904). While the concept may be feasible, OSHA made the decision not to adopt it based on the record developed through the rulemaking process. The January 19, 2001 Federal Register (pp. 5921-5923) discusses the "site log" concept and outline the agency's reasons for not adopting that proposed provision. OSHA stands by the rulemaking. Its 2003-2008 Strategic Management Plan directs OSHA to allocate its resources to specific industries with high injury, illness, and fatality rates or special population needs. According to OSHA, the meat packing industry is not identified in the agency's current Plan and, therefore, is not targeted for enforcement, outreach, or cooperative program emphasis. The agency continues to maintain the ability to analyze trends at specific establishments and also asserts that collection of injury and illness data of contract employees not under the day-to-day supervision of meat and poultry plant employers is contrary to the record developed in its last recordkeeping rulemaking. Requiring data from contractors would necessitate rulemaking which is not prioritized on OSHA's regulatory agenda at this time. It should be noted, however, that the new Administration is reviewing and re-examining OSHA's regulatory agenda, and the possibility of reconsidering site logs has not been entirely eliminated.

According to OSHA officials, cooperative program participation is voluntary - typically resulting from private and public sector interest to partner with the agency. OSHA cannot require a specific group or industry to participate in cooperative programs; typically, organizations or companies approach OSHA to partner. Based on the link to the Strategic Management Plan, potential for impact on reducing fatalities, injuries or illnesses, and available resources, OSHA makes a decision whether to form a cooperative relationship with the interested party. In the past decade, OSHA has entered into cooperative relationships with the meat packing industry due to the employers' and employees' belief in the value of implementing effective safety and health management systems and promoting a safety and health culture. A total of 22 meatpacking industry sites have attained VPP status. In addition, OSHA has formed three partnerships in the meatpacking industry. The most recent partnership is the Nebraska Animal Slaughtering and Processing Industry (NASPI) partnership, which started in June 2006, and was noted in our report. OSHA has no plan to expand the partnership to other parts of the country.

As of August 2007, the National Institute of Occupational Safety and Health (NIOSH) reported that it is exploring opportunities with the American Meat Institute to develop a collaborative research effort focused on reducing injuries in the meat industry, which could include a review of the speed of the production line. It is NIOSH's position, however, that the issue of line speed is not an independent factor directly contributing to injuries but is confounded by a multitude of other factors and cannot be examined in isolation in research focusing on prevention of injury outcomes. NIOSH noted that successful injury prevention research in the meat industry would require cooperative worksite access and industry participation, which is difficult to obtain.