Trump Agriculture Department’s Proposed New Swine Slaughter Inspection System Will Endanger Public Health, Worker Safety, and Animal Welfare

We deserve safe food, and America’s workers deserve safe workplaces. A hog slaughter rule proposed on February 1 by the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS), which the agency has misleadingly titled the “Modernization of Swine Slaughter Inspection Rule,” is a radical change in food safety protection. The new proposal decreases and privatizes food safety inspections and allows for an unlimited increase in swine slaughter line speeds, endangering workers, consumers and animal welfare.

The data is clear that the food processing industry is a high hazard industry and that workplace safety is a key concern. Even at current line speeds, pork slaughter and processing workers face many job risks that can lead to severe injury, illness, and death.

This new proposal also jeopardizes consumer health and animal welfare. A report from Food & Water Watch found that in the five hog plants used as pilots for this program, there were more regulatory violations than in other plants. Additionally, a review by the Office of Inspector General found that the USDA failed to provide adequate oversight of the pilot plants testing this system, and those plants “may have a higher potential for food safety risks.” Further, increasing line speeds will roll back progress on the humane treatment of hogs and jeopardize animal welfare.  

Jobs inside pork plants are some of the most dangerous and difficult in America, and the risk to food workers and our food supply increase as line speeds increase. With the proposed rule, the Trump administration has decided to sacrifice worker and consumer safety and animal welfare in order to line the pockets of already rich corporate executives.

For the sake of keeping hard-working families and the pork we eat safe—tell the USDA now to maintain current line speed limits in swine slaughter plants and withdraw their proposal.

After multiple requests from consumer, worker, and animal welfare organizations for a 60-day extension of the short public comment period, the USDA extended the comment period by 30 days to May 2, 2018. The agency has not yet responded, however, to multiple requests from organizations to hold a public hearing on the proposed rule.

Increasing Swine Slaughter Line Speeds Is Dangerous for Workers, Consumers, and Animal Welfare

The proposed swine slaughter rule removes all limitations on line speeds in hog slaughter plants, which will endanger the health and safety of tens of thousands of workers in meatpacking plants.

  • The USDA states that this new proposed swine inspection system is like the new poultry inspection system adopted in 2014 (NPIS). That is untrue. The USDA did not allow any increase in line speeds in poultry plants in the final rule in 2014, because the agency recognized the serious adverse consequences to worker safety, specifically more worker injuries. There was also, as with the new hog rule, little data on whether plants could maintain food safety process control at greater line speeds.

Any increase in line speeds will result in an already dangerous industry becoming more dangerous.

  • Hog slaughter workers already endure exceedingly harsh working conditions to provide cheap meat to American consumers. They work in cold, wet, noisy, and slippery conditions. Workers on the slaughtering and processing lines make tens of thousands of forceful repetitive motions on each and every shift. They work with large and dangerous hooks, saws, and knives to cut and break down the hogs. They process thousands of hogs per hour. Hog slaughter and processing workers also push huge dangerous trolleys and vats of meat, clean and maintain very dangerous equipment, and pack 40 to 50 hams per minute.
  • According to the Bureau of Labor Statistics, based on a voluntary survey of pork processing plants, meatpacking workers are injured at rates that are more than 2.4 times higher than the national average for all industries. The rate is nearly 3 times higher for those injuries that require workers to lose time from work or restrict their duties. Meatpacking workers also experience an illness rate—such as for disorders like carpal tunnel syndrome—that is almost 17 times as high as the average for all other industries.
  • The high injury and illness rates in meatpacking plants contribute to staggering worker turnover running at 60 percent annually per plant.

There is no evidence that the increased line speeds can ensure public health, worker safety or animal welfare.

  • The proposed rule is modeled after a pilot program called the HACCP-Based Inspection Models Project (HIMP), which began in 1997 and involves five hog slaughter plants.
  • USDA’s Inspector General (IG) issued a report in 2013 that widely criticized HIMP. The IG found the USDA failed to assess whether HIMP improved food safety at the five plants. The IG said: “Since FSIS did not provide adequate oversight, HIMP plants (the pilot plants) may have a higher potential for food safety risks.”
  • Further, an analysis of FSIS data by Food & Water Watch found that the five HIMP plants had more regulatory violations than five comparably sized non-HIMP plants.
  • Study after study confirms that fast line speeds already lead to high rates of serious workplace injuries in hog slaughter plants.
  • As the director of the National Institute for Occupational Safety and Health explained to FSIS recently, processing line speeds are a key cause of musculoskeletal disorders among food processing workers: “Line speed affects the periodicity of repetitive and forceful movements, which are key causes of musculoskeletal disorders.” In other words, the faster the line speed, the greater the risk of harm.
  • The safety record of the five HIMP plants in the pilot program also reveals serious safety issues because of fast line speeds:
    • In a 4.5-month period in 2017, two workers from the Clemens Food pork plant in Pennsylvania suffered injuries that required hospitalization, while another worker suffered an amputation. (osha.gov)
    • In 2016, the Occupational Safety and Health Administration (OSHA) found that the managers at the JBS plant in Illinois imposed unreasonable restrictions on the use of toilet facilities. (OSHRC Docket No 16-0510). In other words, in order to keep the lines running so fast, the company was denying and delaying workers’ access to bathrooms.
  • The USDA has misleadingly titled its rule “Modernization of Swine Slaughter Inspection,” yet expanding HIMP will actually roll back progress and jeopardize animal welfare by speeding up slaughter lines.
  • The proposed New Swine Inspection System (NSIS) would jeopardize the welfare of over 100 million pigs each year. Standard, non-HIMP plants already handle 1,100 pigs per hour—a speed that severely threatens animal welfare. Market pigs weigh hundreds of pounds each and are not easy to handle or move, inviting humane handling violations, yet USDA wants to increase slaughter line speeds even further.

The proposed rule will privatize the food safety inspection system in hog slaughter and reduce inspections.

  • The proposal would reduce the number of government food safety inspectors in the plants, turning that function over to a reduced number of company employees.
  • Additionally, the proposed rule does not require any training for the plant employees who will take over trained FSIS inspector duties.

The proposed rule will not lead to safer food.

  • With fewer government inspectors on slaughter lines, there will be fewer trained workers watching out for consumer safety. Faster line speeds will make it harder for the limited number of remaining meat inspectors and plant workers to do their jobs.
  • USDA claims that the new proposed inspection system can increase food safety by removing FSIS inspectors from the slaughter line and allowing FSIS inspectors to conduct more offline pathogen testing. But that has not been proven to be true for poultry plants in the New Poultry Inspection System (NPIS). The agency’s recent release of testing data in poultry plants shows that 30 percent of the NPIS chicken plants failed the agency’s performance standard compared to only 13 percent that are still using traditional inspection. Further, the USDA admits in the preamble to the proposed rule that the increase in offline FSIS activities in hog plants will not be much greater than is done now. In addition, the agency stopped collecting salmonella samples at hog slaughter in 2011, so the agency’s risk assessment for the New Swine Inspection System needs to be questioned.
  • The pilot project failed to show that allowing companies to police themselves produces safe food.
  • USDA failed to include the data to support claims of possible increases in food safety.

Background on Worker Safety Concerns

  • The pork processing industry is one of the most dangerous for workers. FSIS’s proposal to lift the cap on line speeds will increase the risk of serious injuries and illnesses to workers in pork processing plants.
  • The new proposed rule by the Trump administration will result in workers in both the slaughter and processing ends having to work even faster in a highly dangerous work environment. USDA calculates the economic benefits of the proposal in terms of higher profit for pork processing companies. “Assuming establishments increase their line speeds by 12.49 percent and have a packer margin of $4.10 per head, an average large establishment’s surplus could increase by approximately $2.04 million.” (83 Fed. Reg. 4813)
  • In calculating the benefits and costs of the new proposed rule, the USDA analysis assumes that plants will not hire more workers if line speeds are increased (except for a few workers who will perform some of the tasks currently conducted by FSIS inspectors). Their assumption means that slaughterhouse workers are expected to process more hogs per hour. Meatpacking workers will tell you that they can barely keep up with line speeds at their current rate.
  • The USDA has drafted a rule that would increase profits in the industry by sacrificing the health and safety of tens of thousands of our nation’s workers and the safety of our food.
  • Almost 30 years ago, OSHA published Ergonomics Program Management Guidelines for the meatpacking industry to address the high rates of carpal tunnel syndrome and other musculoskeletal disorders in the meatpacking industry (hog and cattle). Though musculoskeletal disorders (or cumulative trauma disorders, or CTDs) are present in other industries, the high rates in meatpacking plants prompted OSHA to issue these guidelines. The guidelines made clear that the high injury rates are due to high production rates in pork and cattle plants (e.g., already high line speeds). OSHA says in the introduction to this guide:
    • “Why meatpacking? Most importantly, CTDs are particularly prevalent in the meatpacking industry. Although ergonomic hazards are by no means confined to meatpacking, the incidence and severity of CTDs and other workplace injuries and illnesses in this industry demand that effective programs be implemented to protect workers from these hazards.”
    • The guidelines also state that one way to decrease the rates of these injuries and illnesses in meatpacking plants is by reducing the total number of repetitions per employee by such means as decreasing production rates.
    • The OSHA recommendations that were made over 30 years ago remain the same today. Still, the new USDA proposal ignores these recommendations and the science they are based on, and gives a green light to pork plants to speed up the lines, which will lead to a devastating increase in injuries.
    • There are scores of studies listed in the guidelines and others in later reports by OSHA and National Institute for Occupational Safety and Health that demonstrate that already breakneck line speeds, coupled with the forceful and repetitive nature of the jobs, lead to high rates of musculoskeletal disorders for the workers.
    • Epidemiological studies also reveal that fast line speeds in pork processing plants lead to other serious injuries—such as lacerations. (Kyeremateng-Amoah E, Nowell J, et al. Laceration injuries and infections among workers in poultry processing and pork meatpacking industries. Am J Ind Med. 2014. 57:669-682. Lander L, Sorock G. A case-crossover study of laceration injuries in pork processing. Occup Environ Med. 2012. 69:410-416.)

Background on Food Safety Concerns

  • The agency has not divulged all of the data that supports the proposed rule, so it is impossible to comment intelligently on the New Swine Inspection System (NSIS) until that information becomes available. For example, many of the tables provided in the agency’s risk assessment are cut off, so it is difficult to assess the accuracy of the agency’s assertions. In addition, the agency has been collecting establishment generated microbiological testing data from the HIMP plants in exchange for line speed waivers, which is not publicly available. Furthermore, the agency makes numerous assumptions in the proposed rule that have no data to support them.
  • There is no requirement that plant employees (who will be doing the tasks previously done by trained government inspections) under NSIS be trained in inspection activities that USDA inspectors normally performed. Not being able to identify and contain animal diseases could devastate the domestic livestock industry.
  • Based on data gathered from a series of Freedom of Information Act requests that cover the period January 1, 2012 through November 30, 2016, Food & Water Watch has found that the five HIMP pilot plants had more regulatory violations when compared to five comparably sized non-HIMP plants in the following key areas:
    • 84 percent of the citations for not following the plant’s food safety plan were in the HIMP plants;
    • 73 percent of the citations for the carcasses/organs being contaminated with fecal material, bile, hair, dirt, and other foreign matter were in the HIMP plants;
    • 65 percent of the citations for general carcass contamination were filed in the HIMP plants;
    • 61 percent of the citations for unsanitary equipment and utensils were filed in the HIMP plants;
    • 54 percent of the citations for plant employees not following hygienic practices while on duty were in the HIMP plants;
    • 52 percent of the citations for food contact equipment and utensils not being properly sanitized were in the HIMP plants;
    • 51 percent of the citations for non-food contact surfaces for unsanitary conditions were in the HIMP plants;
    • 50 percent of the citations for the plant not implementing its own sanitation standard operating procedures were in the HIMP plants;
    • Of the 22 instances in which an on-line FSIS inspector found that an on-line plant employee failed to identify that a carcass was so infected that consumption of the meat could cause food poisoning, all 22—100 percent—occurred in the HIMP plants.

Background on Animal Welfare Concerns

  • The New Swine inspection System (NSIS) would jeopardize the welfare of over 100 million pigs each year.
  • Under this rule, NSIS would place key animal welfare inspection duties into the hands of slaughter plants themselves, while these facilities operate at dangerously high line speeds, and many problems will likely go unnoticed.
  • Fast line speeds invite rough animal handling, as plant employees experience pressure to move animals quickly through the slaughter process. HIMP plants have been found using excessive force in efforts to make pigs move faster.
  • A faster slaughter line also invites improper stunning of pigs as required by the Humane Methods of Livestock Slaughter Act. Pigs may never lose consciousness, or may regain it during slaughter.
  • Improper stunning can ultimately cause animals to be slaughtered while conscious, violating the Humane Methods of Livestock Slaughter Act. Fast line speeds may leave plant workers unable to detect signs of consciousness, or unable to stop the line in time to intervene.
  • Reducing the number of FSIS inspectors at pig slaughter plants will make an already precarious animal welfare situation worse. More federal oversight, not less, is needed to ensure adequate animal handling, welfare, and compliance with federal law and regulations.
  • The NSIS proposal would shift some on-line inspection roles from FSIS to plant employees. It is crucial that USDA inspectors oversee key aspects of pig welfare throughout the slaughter process, including both off-line activities such as pigs being held and moved before reaching the slaughter line, and on-line activities such as stunning and slaughter.
  • By allowing facilities to operate at increased slaughter speeds combined with reduced oversight, the USDA is essentially giving the profit-driven pork industry a free pass to monitor itself. This will produce devastating consequences for animals, as well as workers and consumers.

Take Action

Let USDA know​ they must not increase line speeds in hog slaughter plants. For the sake of public health, worker safety, and animal welfare, they must withdraw their proposed rule.

NELP sincerely thanks Food and Water Watch, ASPCA, and Celeste Monforton, Ph.D for their contributions to this policy brief.

© 2018 National Employment Law Project. This report is covered by the Creative Commons “Attribution-NonCommercial-NoDerivs” license fee (see http://creativecommons.org/licenses). For further inquiries, please contact NELP (nelp@stage.nelp.org).

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