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Charles N. Jeffress
National Turkey Federation/
National Broiler Council
Safety and Health Committee
Washington, D.C.
September 17, 1998
- I am delighted to be here addressing safety and health professionals in the poultry
industry. In part, that's because North Carolina is home to so much of your industry that I
have some familiarity with your processes.
- I also have many friends among you who share a common commitment to worker
protection -- Jim McCauley, Chip Christian, Heath Smitherman, David Wiley, to name a
few. But I'm also glad to be here because there are others among you -- who shall go
nameless -- who need some help getting your corporate leadership to make safety and
health a higher priority within your company. OSHA and I are committed to helping you
get their attention!
- Not so long ago, prosperity meant a chicken in every family's pot every Sunday. By this
definition, Americans -- with the help of your industry -- are prosperous indeed. Because
chicken is no longer just for Sundays, and turkey has become a year-round staple instead
of a once-a-year special.
- That appetite is bringing rapid growth in poultry processing -- averaging nearly 6 percent
each year, and that's good news for your industry. But it also creates a challenge to
ensure that as your plants and your workforce expand, employee safety and health receive
the attention they deserve. And we have some work to do.
- Under OSHA's strategic plan, we are focusing on reducing injuries and illnesses by 15
percent in five high hazard industries by the year 2002. Food processing is one of them.
For every 100 employees in food processing there were 15 occupational injuries and
illnesses in 1996 -- that's nearly double the average rate for all industries. We want to see
that high rate come down, and I know you do also.
- Last year we began a serious dialogue on worker safety and health issues with poultry
processors. We met with some of you here in Washington. Others joined us in Atlanta,
Baltimore and Little Rock. Along with the Wage and Hour staff at the Employment
Standards Administration, we surveyed 51 of 174 poultry processing plants in the U.S.
last fall.
- We wanted to assess the status of worker safety and health in the industry. Our purpose
wasn't to issue citations. We wanted to identify what kinds of problems you're facing,
what kinds of progress you're making and what we need to work on.
- Our specially trained inspectors walked through the plants, talked with employees, visited
with managers -- and filled out a 250-question survey form. Let's talk about the findings.
We were somewhat surprised at the results.
- We thought repetitive motion problems would be the biggest issue. But what really
stood out is that 40 percent of the injuries in your plants were back injuries. Some came
from lifting. But most resulted from slips, trips and falls. Preventing those injuries
means paying attention to the basics: Keep floors cleared of fat and water. Add friction
through grittier floors or buy high traction boots for workers.
- These are simple, common-sense fixes of traditional hazards. Finding a high-grit floor
that can be easily cleaned isn't a simple task, but it isn't rocket science either. I have
confidence you can do it. And it could significantly reduce injuries in your plants.
- Housekeeping requires constant pressure. After the poultry initiative was over, we
received a complaint about one plant we had visited. Everything appeared in good shape
during our survey tour. But when we returned to investigate the complaint, our
compliance officers found water ankle deep, workers without protective gear and pipes
with labels peeling off. There was no excuse. The plant manager knew what to do.
We'd seen the very same plant in good shape -- when they knew we were coming for the
survey. But cleaning is a daily, hourly issue that demands nonstop attention. And we
will insist on it. Don't let down your guard, don't get sloppy. The little things can get
you in big trouble.
- Other problems we saw in the survey are directly related to your rapid expansion. For
example, we found exit doors blocked by newly added conveyor belts. After the Hamlet
fire seven years ago this month, I thought we'd never see blocked exits again. The danger
here should be clear.
- We also spotted narrow aisles and crowded equipment. Squeezing in extra lines and
equipment puts workers close together. Workers aren't cutting themselves as much as
they are lacerating their neighbors! People on the line need more space, more protective
gear or both. And let me remind you: PPE must be provided by the industry; workers
can't be required to pay for it.
- When it comes to PPE, don't forget the chicken catchers. They need gloves and
respirators. Catchers who do your work at your direction must be considered your
employees -- not contractors. You have an obligation to protect these people as well.
- In addition, we noted that poultry processors are just becoming aware of the need to
implement lockout/tagout procedures. Some processors are just now recognizing that
OSHA's process safety management standard applies to ammonia refrigeration systems.
So we found a number of plants not in compliance with these requirements.
- Language difficulties posed problems in many facilities. Supervisors had trouble
communicating with and providing training to workers who spoke little English.
This problem is not unique to your industry; it is something we all need to work on.
- These findings from our survey, which many of you heard at our outreach meetings in the
spring, will be published in more detail later this year. We expect to publish this
information on the Internet so that it will be broadly available.
- In short, we found problems with worker safety and health in poultry processing. The
good news is many can be fixed easily. The best news is the positive response we've
received from you in the industry.
- My staff tells me they've had numerous calls -- probably from some of you here
today -- asking us to repeat the survey. That tells me you found it helpful. It tells me you
want to address these issues -- and you want to verify the progress made since last year.
Let's find a way to do that.
- More and more, OSHA wants to partner with those who are committed to reducing
injuries and illnesses in the workplace. We've developed national partnerships with trade
and union groups. We've expanded individual site partnerships focused on
excellence -- our Voluntary Protection Programs. We have had poultry processors in our
VPP, and we'd like more.
- At the other end of the scale, through our Cooperative Compliance Program, we've
identified sites that most need our help. And once CCP is vindicated by the courts, we
hope to get it back on track to offer partnership to sites with high injury and illness rates.
Nearly 1,100 sites in food processing were invited to partner with OSHA last year under
CCP. While we cannot offer partnerships to employers at these sites, we are proceeding
with inspections of those sites in poultry processing with higher than average injury and
illness rates. You know who you are, and you need to be working to eliminate your
hazards.
- While it is the cooperative efforts, the education, the partnerships that will change
corporate cultures to be more proactive about safety and health, sometimes it takes
inspections to get people's attention. And have no doubts about it: I make no apology for
a strong enforcement program. We will continue to do inspections with significant
penalties where needed. But once we have people's attention, let's work together to
change cultures.
- The key to all OSHA partnerships is effective safety and health programs. If you are
interested in developing a partnership with OSHA on the basis of an exemplary safety and
health program, I would be delighted to talk with you further. We are working closely
with ConAgra right now in a variety of settings, and that process might be instructive for
others.
- In discussing the poultry initiative, we also need to talk about musculoskeletal disorders.
We didn't find as many repetitive motion problems as we'd feared, and I'm very
encouraged by that, but we still found plenty of opportunity for improvement.
- It tells me that your industry is moving forward in dealing with repetitive motion and
overexertion. You're using curved knives to reduce exertion. You've adjusted work
station heights. You've reduced heavy lifting. In some cases you've made major
investments in redesigning your lines. You've adapted the workplace to fit your
workers -- and you're beginning to win the war on MSDs as a result. But much more
remains to be done, and too many plants are focusing on production at the expense of
employee health.
- That's a mistake for many reasons. Protecting employees is not only the right thing to do,
it's the profitable thing to do. For example, Perdue has proven the payoff from
establishing an ergonomics program. Following an OSHA inspection in North Carolina,
the company installed new deboning and cutting workstations. It added wellness
programs at its plants. Success with these changes led the company to implement similar
programs in other states. And the benefits have been substantial -- fewer injuries and
higher employee morale. From 1991 to 1995, the company reduced workers'
compensation claims from $4 million to $1 million -- more than paying for the investment.
- Like poultry processing, nearly every industry has a need to address ergonomics. We
know that because nearly one-third of all occupational injuries and illnesses stem from
overexertion or repetition. That percentage has remained the same even though overall
injuries and illnesses have declined.
- MSDs are costly. For a worker who experiences carpal tunnel syndrome, it means an
average of 25 days off the job. That's part of the reason a work-related MSD costs
$8,000 or more in workers' compensation costs -- twice the cost of the average claim.
- Many other nations are ahead of us in establishing standards to reduce work-related
musculoskeletal disorders -- European countries like Germany, Finland and Britain. Latin
American nations like Brazil, Guatemala and Ecuador. African countries like Egypt,
Cameroon and the Ivory Coast. Japan, Australia and New Zealand also have standards.
In fact, just about all industrialized nations, except the U.S., have addressed ergonomics.
- There are not many fields of industrial endeavor where we fall behind Guatemala,
Ecuador, Cameroon and the Ivory Coast. And we won't be behind long.
- OSHA has been concerned about MSDs since the early 1980's. In 1986, the agency
published a request for information on reducing back injuries involving manual handling.
In 1987, OSHA cited auto manufacturers for "recognized ergonomic hazards." And in
1990, the agency issued its ergonomic guidelines for meatpacking plants. In 1992, OSHA
announced its intention to develop an ergonomics rule. We prepared a draft, but in 1995,
Congress told the agency not to publish a proposal or final standard.
- That prohibition, removed during Fiscal Year 1997, was restored for the past year.
Although Congress prohibited us from issuing an ergonomics proposal before October 1,
1998, we have been free to research one, and we have been doing that. Provided that
Congress does not use the appropriations process to prevent publication of an ergonomics
proposal in Fiscal Year 1999, we plan to publish our proposal next summer.
- I also believe that most members of Congress have concluded that the science tying
MSDs to work activities is sound. The National Institute for Occupational Safety and
Health completed an extensive evaluation of the literature on work-related MSDs last
summer. NIOSH's findings were peer-reviewed by 27 scientists.
- In addition, the National Academy of Sciences just spent nearly half a million dollars
convening leading ergonomists and other scientists at a workshop last month to further
examine the research in this area. And the chairman of the Senate Appropriations
Committee for the Departments of Labor and Health and Human Services has declared
that enough studies have been done, it's time to get on with solving the problem.
- We can always learn more. But we know enough to act right now. And we need to act
to protect workers today.
- In fact, companies that have already acted have reaped benefits. For example:
- OshKosh B'Gosh redesigned workstations and cut workers' comp costs by one-third -- down by $2.7 million.
- San Francisco General Hospital reduced back injuries among its health care
workers by 94% saving $135,000 per year.
- Sara Lee modified line speeds and material handling equipment and procedures,
saving $750,000 in workers' comp costs and reducing workdays lost to carpal
tunnel syndrome from 731 days to 8 days.
- Let me tell you where we are in acting on the standard. As we've been saying for some
time, we're planning a program-oriented rule. That means employers who are covered
will need to determine if they have ergonomic hazards and find ways to address these
problems to prevent employee injuries.
- We're still wrestling with the scope of that proposal. Perhaps the initial scope should be
limited to manufacturing operations and workers involved in manual handling throughout
general industry. Or perhaps it should cover all of general industry with some triggering
mechanisms to determine when employers would need to establish programs.
- In any case, we're not looking at a one-size-fits-all approach. We're considering a
flexible framework. We want to give employers the tools to solve the ergonomic
problems they face. We don't need a prescriptive standard, but a descriptive one.
- And that's the right way to go. We will not say that someone can lift 42 pounds, but not
43. Or that 10,000 repetitions are okay, but 12,000 are not. What we do know is that
more force and more repetitions make injury more likely.
- Let's use common sense here. If people are getting hurt, you need to analyze the situation
and find ways to prevent those injuries. Many of you in poultry processing have done
that. An OSHA standard would simply formalize the process that employers with good
safety and health programs are already following.
- The alternative is an assortment of different standards at the state level. This is not an
issue that is going to fade quietly into the background.
- California has adopted a standard, and North Carolina has held hearings on ergonomics.
Washington state has meetings planned for next month. Other states are considering the
prospects of moving forward on their own. I commend them for their efforts to deal with
a serious workplace hazard. However, as 3M ergonomics expert Nancy Larsen recently
told Congress, employers don't want 50 different standards -- that would mean having to
do business differently in each state of the union. I continue to believe that the nation
would be best served by one national standard.
- Toward that end, OSHA's ergonomics team has met with stakeholders several times -- in
February in Washington and in July in Kansas City and Atlanta. Before regulatory
language is ever written, we've been seeking input on the tough issues from employers,
employees, unions, academics, trade association representatives and others. We're
meeting again next week here in Washington with stakeholders -- including some of your
members.
- We've also been offering an opportunity for employers to share their successes in
reducing musculoskeletal disorders through our regional best practices conferences over
the past year. These one-day sessions offer participants practical advice on improving
their operations to reduce repetition and overexertion.
- We will move forward this fall to decide who should be covered, what components every
ergonomics program should include, what situations trigger additional requirements and
how OSHA can determine compliance with program requirements.
- Of course, there's a lengthy process ahead before we actually have an OSHA ergonomics
standard in place. After we draft the proposal, we will conduct a small business review
process and then have an executive review by the Office of Management and Budget.
That's why you won't see it in the Federal Register before next summer. Once it's
published, we will take public comments and hold hearings to permit a full public
discussion and develop the best possible standard. I hope you will take part in that
process.
- Beyond ergonomics, another issue that is a top priority for me is safety and health
programs. Every business wants to be successful. And success means more than just
making a profit. It means being a good corporate citizen, a caring employer and an
industry innovator. Having a strong occupational safety and health program can
accomplish all three -- and boost your bottom line as well.
- Safety and health programs are the critical difference between employers with high injury
rates and those with low rates. In North Carolina, we found the biggest difference in
sites with high workers' comp claims and those with low rates of claims was the lack of
attention to everyday reinforcement of good safety and health practices -- in short, the lack
of an effective safety and health program. It wasn't so much the hazards that were
present as it was the practical efforts of management and employees working together.
That finding made me a believer. And OSHA is doing everything it can to encourage
employers to establish strong safety and health programs.
- Before I leave office, I want an effective safety and health program to become a
fundamental responsibility of every employer in the country. That's the only way to
ensure ongoing progress in workplace safety and health. We will have begun the review
process on our safety and health program standard by the end of this year. We welcome
your comments and suggestions.
- The Occupational Safety and Health Act of 1970 promises every worker a safe and
healthful work environment. That's a goal we can all endorse.
- As head of OSHA, I want every worker to go home whole and healthy every day. As
safety and health directors, I know you do also. Let's find ways to work together to make
it possible.
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